Document gDJ9rbb1bkQyqBdGXjDzyYVea

STATE OF AIABAMA IN THE CIRCUIT COURT OF CALHOUN COUNTY MARS HILL MISSIONARY BAPTIST CHURG33 9; -- ^ versus Plaintiff*, MONSANTO COMPANY, et al., CIVIL ACTION NUMBER CV-95-243 ___ _____ / CONTINUATION OF TH1 DEPOSITION OF JXRJtY BROWN The continuation of the deposition of JERRY BROWN, taken before Deborah Salsrs Garrett, Certified Shorthand Reporter, Registered Professional Reporter, as Convnissioner, commencing at 9:1$ a.a. on May 12, 1999, by tbs Plaintiffs, at the law office* of Merrill, Porch, Dillon & Fite, Suite Soo, 1000 Quincard Avenue, Anniston, Alabama, pursuant to the stipulations set forth herein. Regional Reporting Service, Inc. 755 Walnut Street Gadsden, Alabama 35901-0755 * i f y si 3 1 EXH I B ITS 2 Plainciffa' 3 Marked Offered 4 Seven 25 34 5 Eight 6 Nine 7 Ten 39 Si 49 53 S9 94 9 Tea-A 9 Eleven 10 Twelve 51 94 57 94 70 94 11 Thirteen 12 Fourteen 13 Fifteen 14 Sixteen 15 Sevent een 72 74 92 ' 94 a 94 94 94 94 "4 15 Eighteen 17 Nineteen 112 127 129 19 Twenty 19 Twenty-one 12% 132 20 Twenty-two 144 21 No other exhibits were marked for 22 identification, offered or attached as exhibits hereto. 23 REGIONAL REPORTING SERVICE, INC. 4 1 STIPULATIONS 2 IT IS STIPULATED AND AGREED by the 3 parties, through their respective counsel. 4 that the deposition of JERRY BROWN, may be S taken before Oeborah Salers Garrett, CSR, RPR, 5 as Cassias loner and Notary Pub*.*c, Alabama at 7 Large, at Anniston, Alabama, on May 12, 1999, 9 at 9:15 a.m. 9 IT IS STZPUIATED AND AGREED that the 10 signature to and reading of the deposition by 11 the witness is waived, the deposition to have 12 the sate force end effect as if full 13 conpllanca were had with all laws and rules of 14 court relating to the taking of depoeitions. 15 IT IS STIPULATED AND AGREED that it 15 shall not be necessary for any object lens to 17 be made by couneel co any gueaciona except: aa 19 to form or leading questions and that counsel 19 may make objection, and aaaign ground* at tbe 20 elm of trial or at tbe time ,aid dapoaitltm 21 la offered in evidence or prior thereto. 22 IT IS STIPULATED MID AGREED that notice 23 of filing by the Conmiseloner is. waived. L REGIONAL REPORTING SERVICE, INC. ADAD21-003701 HARTOLDMON0033657 5 1 STATE OF ALABAMA- ANNISTON. MAT 12- 1998 2 3 TOOOT DB/MI 4 after having been first duly sworn, was S examined and testified as follows: 6 7 BY MR. STEWART: 6 Q9 10 Mr. Brown, if you recall, we were taxing your deposition seme time ago here, and I wanted to cover some things and get an 11 s<xne new things that you. were talking to 12 me about last time. 13 If your lawyer won't take so many 14 breaks to go to the bathroom, we' 11 try IS to get through by twelve o'clock. 16 Mr. Brown. 17 A. Well, I'll have to go to the bathroom 16 19 Q30 21 A, 22 too, somewhere along the line. Well, i certainly want you to be as comfortabls as you can be. I've been ready since nine o' clock, ready to go. 23 <2- Well, I apologize to you. I'll do my regional reporting SERVICE, INC. 1 Q. 2 3 4 S A. 6 7 6 9 10 11 13 13 A. 14 IS 16 Q. 17 18 A 19 Q 20 A 21 22 Q 23 7 Well, what kind of readings were they getting of PCBs in the eediment as it applies to Snow Creek testing and Choccolocco Creek testing? Well, the Choccolocco Creek testing# the average over this section of stream -- MR. PECK: Are you talking about the early '70s? MR. STEWART: That is exactly what I'm talking about, and I appreciate you saying that. I'm talking about the '70s. Well, I was starting to answer you in the '80s, because that's what I'm familiar with.. Are you not familiar with what kind of test results they got -No. -- in the '70s? No. I was not working that part of chat in the * 70s. Let ms ask you this: Didn't you become the enviromsntal officer sc Monsanto REGIONAL REPORTING SERVICE, INC. 1 2 3 4 S 6 7 8 A. 9 Q10 11 A. 12 Q* 13 14 IS 16 A. 17 Q. 16 19 20 21 22 23 A. best to get you out of here as quickly 4 as I can. tou indicated earlier that you started at Monsanto -- And I don' c remember the exact date. But you were working there sometime in the '70sj is that correct? That's correct. What was the exact date you went there, if you can recall? August the 26th, 1967. So you were there when this testing that you previously cold us about was done along Snow Creek and Choccolocco ami that area in the '70s? Yes. I believe you mentioned last time In ' your deposition that you didn't necessarily participate In that. But did you know enough about it to know what kind of teec results they were getting along that area? Well, I need you to be more specific. REGIONAL REPORTING SERVICE. INC. 1 2 A. 3 4 Q. S 7 8 9 10 A. 11 12 Q13 14 IS 16 17 18 19 A. 20 Q21 22 23 9 sometime in '74? I became the chief chemist with some environmental responsibilities in 1974. That would have had to do with testing of PCBs, whether it came from the plant or from the landfill or whatever. wouldn't it, Mr. Brown? We covered chat before, and that's what 1 thought you had previoualy told ma. The PCS testing that was dons in the '70s was done prior to '76. I understand that. Sac your job would have entailed, would it not, when you took it in 1974, testing for emissions from the plant, whether it be PGSi or whatever it be for? MR. PECX: Object to the Com of the question. That aa pact of eba inwolwenaat, ye*. Okay. And is it my understanding -This is what 1 wanted to clear up. Ie It ay understanding that nobody from St. Louis - - And you indicated REGIONAL REPORTING SERVICE. INC. ADAD21-003702 HARTOLDMON0033658 A W 1 2 3 4 A. 5 Q. ft 7 8 9 A. 10 11 Q. 12 A. 13 14 Q. 15 IS 17 A. 18 Q. 19 A. 20 21 Q22 A. 23 Q. there were tom* people from sc. Louis 9 who were involved in this testing, did you not, who sort of managed it? That* * correct. And exactly who was that person? That was a Landwehr, I believe you mentioned# and a Mr. Garrett and some other people who were involved in that? Joe Landwehr was located at the Anniston plant. Okay. Mall, oho -- Joe left the company in -- sy recollection la about '72, *71 or '72. Well# during the -time he wes there# wasn* c he Involved in the testing? I vent over your deposition -- People who reported to him were. Okay. He was not personally involved# but people who reported to him did. Well, he would have known the results? More than likely. Did he say anything to you about them? KKOIOHAL REPORTING SERVICE. INC. 1 2 Q. 3 4 5 c 7 ft 9 A. 10 11 12 13 Q. 14 A. 15 1C Q. 17 1ft 19 20 21 22 A. 23 doing. U Weren't you aware, Mr. Brown, that there was a substantial smcmne of PCB waste and waste materials buried ac a landfill sits that was operated by Monsanto at the time? MR. PEOC: Object to the foxm of the question. I was aware chat sene PCS residue had bea di,poa4 of ac the landfill alca prior to the time the plant was shut down# yes. Okay. And you were aware -- But that was - - I mean# that was shut down and closed in '74. Let me see if I can get at it this way: You did not see it as a part of your responsibility as chs environoental officer -- By the way# hov long did you serve in that capacity? Well# you say that capacity. I worked to some degree or another with REGIONAL REPORTING SERVICE# INC. 1 A. 2 3 Q. 4 S ft 7 8 9 10 11 12 A. 13 14 Q. IS 1C 17 1ft 19 20 A. 21 22 23 10 I didn't have any reason to talk to him about them, no. Well# now, let me see if I understand your statement there, because I want to be sure I understand this, Mr. Brown. It was your position chat after that testing was dots, you as the environmental officer there at Monsanto had no reason to talk to him about anything that ha might havs found in the testing? I had nothing to do with environaantal work while he was there. Hell, I mean after you did chat, did you have any contact or conversation with anybody# whether it's Mr. landwehr or anybody slss in the coopany, a Mr. Jack Garrett? Hasn't he involved in chat at chat time? I recollect Jack being involved. I don't know to what degree. I wasn't involvsd l don't know -* I bad no personal involvement with what Jack wae REGIONAL REPORTING SERVICE# INC. 1 2 Q. 3 A. 4 Q. 5 ft 7 ft A. 9 Q. 10 11 12 13 14 15 1ft 17 1ft A. 19 Q. 20 A. 21 g. 22 A. 23 ` 12 environmental work into the mid '80s. well# was it past 'fts? Probably '87, '88. Well# you sort of took the lead or at least participated fairly actively in the problem that occurred in the 19ft 0s, didn't you? Tes. Now, 1st ms ask you. Ac any point in time did you ever consider it to be something that you should have known about, Mr. Brown# as to what the teet result* were that were obtained by these people out of Snow Creek and choccolocco Creek# whether it's out of sediment or fish, at the time you took chat position in 1974? Mr. Scaware, lac ma axplain to yai -- Please do. -- my situacloa la 1174. Please do. 1 was working for Monsanto Agricultural Produets Company. The Aroclor operation REGIONAL REPORTING SERVICE# INC. ADAD21-003703 HARTOLDMON0033659 13 1 * .hue down io '71 and '72. All that 2 casting had bean brought to closure with 3 the appropriate scats agsaclss by che 4 appropriate people. The plant eae S closed. The landfill was closed from a s PCS standpoint. To the best of people's 7 knowledge in 1974, when took that job, A chac was closed. That was then history. 9 Okay? 10 In 1974 there were new regulation# 11 coming down the pike that we were 12 working very actively an, both air and 13 water regulations as new federal 14 regulations developed. That's where my IS emphasis was. 1 was not working on 16 phosphorus for the parts of the plants 17 that were closed in che '30s or ia screeching chat had been brought to 19 closure in '72 or '71, '72, '73 by the 20 appropriate agencies and the appropriate 21 people. 22 MR. STEWART: Excuse me just a 23 minute. REGIONAL REPORTING SERVICE, INC. 1 2 A. 3 4 5 Q. 6 A. 7 9 Q. 10 U 12 13 14 A. tc 16 17 Q. ia 19 20 31 A. 22 Q. 33 A. is involved in it. How do you know that? Mr. Stewart, I think I've explained chat there were people whose job it was to address chose issues. Sue if you -- In my position in 1974, I had emerging regulations, the compliance of che ongoing operations of the facility. I understand what you did after '74. But what X*m asking you, Mr. Brown, is how do you know, first, what steps they took if you don't even know what readings they got? * What I'm telling you is that it was to them to do their job. I had my job to do. ` Well, did anybody from that group ever sit down with you and brief you on what was dona, Mr. Brown, before you took your position? No, sir, bad no reason to. How do you Imow that? Just as I've explained. It had been REGIONAL REPORTING SERVICE, INC. 1 2 Q. 3 4 S 6 7 9 10 A. 11 12 13 14 15 16 17 IS 19 20 Q. 21 22 23 14 (Discussion held off record.) Let me eee if I underwtand what you're aaying. Tou felt no responsibility to find out what those test results were? Zs that what I'm understanding you to be saying, Mr. Brown, since you took the position as esvlroiaiisntal officer. because you felt like che whole problem bad been taken care of? The problem had been brought to appropriate closure by the regulatory people and the people working cm chat problem. The most responsible action that any mind could conceive of at that point ia time had been taken. There was no further action from a regulatory or any -- any need that any human mind could conceive that needed to be done in 1974. Mr. Brown, you seem to be a pretty bright fellow, but I don't know how you understand that If you don't know what the test results were and you weren't REGIONAL REPORTING SERVICE, INC. 1 2 3 4 Q. 5 o 7 S 9 A. 10 u Q. 12 13 A. 14 15 16 17 IS Q. 19 20 21 22 23 16 brought to complete closure che best anybody could know at chat point in time. Well, what particular thing was done, as you understand it, that would have closed out chat problem in i971, '72, *73? What did cha company do? Other than the testing, what did they do? Closed the plant, tore down the facility, closed the landfill. And that's all you understood that they were required to That ... uh praeey dun dxamtic actions. Tss, sir. That was about as responsible and dramatic as the human mind could conceive at that point in tima. Tea, air. Mow, you had mentioned previously, Mr. Brown, that there was some work dons ia the 1970s with a Mr. Crockett. Do you know -- Is chat the same fellow who vaa eh* chi.f aeglaaar with eh* Alabana Msear Inproaaaaae Ccomii.lan? REGIONAL REPORTING SERVICE, INC. ADAD21-003704 HARTOLDMON0033660 1 A. 2 3 4 Q5 6 7 9 A. 10 11 Q. 12 13 14 IS 16 17 16 19 A. 20 21 Q22 23 17 It'* ray recollection that Mr. Crockett *aa beading up tbe eater division at that point in time. What did you understand was th* standard at that tine of parts per million pCBs in fish or wildlife that would have required some action by the Conservation Department? I do not know of any standard at that point in time. Are you telling me, Mr. Brown, as a person who became the environmental officer for Monsanto in 1974, which would have been two or three years after these tests vsrs done and this plant facility was closed, that you don't have any idea what any standards ware at that time? I have no idea what a standard was at that point in time. what about later? Do you understand that there were any imposed at a later time? REGIONAL REPORTING SERVICE. INC. 1 2 3 4 A. S Q7 A. 6 Q. 9 10 A.__ 11 Q. 12 13 A. 14 Q. IS a. 16 Q* 17 16 19 20 A. 21 22 Q. 23 point in time? 19 MR. PECK: Object to the form of the question. I remember conversations to that effect. yes. In the '70s? Tes. Who did you have chose conversations with? I don't remember. What was the substance of the coavereacloos? I don't remember. Were they employees of Monsanto -- r. -- that you bad the conversations with? Would they have been one of the people chat I talked about or one of Che people involved in the study? Could have been. X Man, that's been twenty-five years ago or more. Mr. Brown, during the elms that you were involved as the envlrosmental officer. REGIONAL REPORTING SERVICE, INC. l A. 2 3 4 Q. S 6 7 A. 6 9 10 11 Q. 12 13 A. 14 Q. IS 1C 17 16 19 20 21 22 23 I have hsard standards. 16 1 cannot repeat a standard to you. I don't know what it is. So you don't know of any standards that would have been applied to PCBs, 1st' say in fish, after -- I'm iwarc that standards are in existence fox PCBe In fish, yes. But 1 don't know what it is. is what I'm telling you. And you didn't know what they were at that time, when you took the job? That's correct. Did anybody ever tell you that y'all might have contaminated Choccolocco or contaminated -- aa it spills into Martin, where it would have caused a fish advisory to be issued and Logan Martin being closed to commercial fishing? Did any of the people chat I mentioned earlier, Mr. Tucker, Mr. Oarrete, or Mr. Papageorge even, any of them talk to you about chat at chat REGIONAL REPORTING SERVICE. INC. 1 2 3 4 5 6 7 A. S Q. 9 10 11 12 13 14 A. IS 16 17 Q. 16 19 A. 20 21 q . 22 23 A. 20 did you submit reports to Mr. Crockett or those people who were in his position or working with the Alabama Water Improvement Coa&ission or ADEM later on? Old you submit reports to them on a confidential basis? X did not submit reports, no. Do you know if it was the policy of ywir company to attempt to limit the dissemination of information about PCB contamination or any other kind of contamination and juse to do that on a confidential basis? Well, during that period of time it was very typical that all communications be done on a confidential basis. Why is it you understand it had to he done on a confidential basis? That is just the way it was at that point in time. And why did you understand it was confidential? I don't -- That'* ju*c tfca my ic ma. REGIONAL REPORTING SERVICE, INC. ADAD21-003705 HARTOLDMON0033661 2 Q. A. Q. A. Q. A. Q. A. I mean, I cas'c answer you. 21 That is the way your company did business with the Alabama water Improvement Caranlssioa ac that time? Hell, what I'm telling you is it wasn't just that. It was typical that most communications were listed as company confidential. Even information chat you would glre to regulatory agencies such as the Alabama Hater Improvement Commission, a public body? MR. PECX: Object to the form of the question, calls for speculation. I can't answer. Now, did you knew anything about any kind of cleanup program that was instituted in the 'IOs by Monsanto at the Anniston plant, PCB cleanup program? In the '70s? Oh-huh (indicating yes). The only thing I remember is the REGIONAL REPORTING SERVICE, INC. 1 A. 2 Q. 3 A. 4 S 6 7 Q. S 9 A. 10 Q. 11 12 A. 13 Q 14 15 A. 14 17 Q. 18 19 20 A. 21 Q. 22 23 I have no idea. 23 How did you meet him? He worked on the -- The specific place I met him was doing waste treatment studies as part of the biological waste treatment plant. And of course Mr. Jessee was the plant manager at that time, was ha not? He was during a period of time, yeah. And was Mr. Hosaer located at this Anniston plant? Not in my era. He was prior to my time. Okay. And do you know who a Mr. 8. P. Hheeler was? I've heard the mane, but don't knew anything more than that. Did any of those people -- And of course you have mentioned you know who Mr. Landwehr was, didn't you? Tes. Old any of y* all ever * - Or did any of those people ever cosnunicat* with you about a PCB cleanup program that was REGIONAL REPORTING SERVICE, INC. 1 2 3 Q. 4 5 6 7 9 A. 10 11 12 13 14 Q. IS u A. 17 Q. IS A. 19 Q. 20 A. 21 Q. 22 A. 23 Q. 22 dismantling cleanup of the facility when it was torn down. Here you ever told ac any point in tins. after you took the position that you did, chat there would be a cleanup program or there was a cleanup program that taken place there ac the Anniston plant? Hell, I don't really know what you're talking about specifically. I mean, you say cleanup program. That's a general That's so general, I don't really know what you* re calking about. Are you familiar with a Mr. Paul B. Hodges? I remember meeting Mr. Hodges, yea. And where was he located? In SC. Louis. And do you know what his job was? He was in the engineering section. Of Monsanto Chemical or -- I don't -- -- the agricultural company? REGIONAL REPORTING SERVICE, INC. 1 2 3 A. 4 S S Q. 7 8 9 10 A. 11 12 13 Q. 14 IS IS 17 18 19 A. 20 Q. 21 A. 22 Q. 23 24 instituted by Mr. Hodges and others in che Anniston area? I do not recollect anything specific that Paul Hodges was working on with PCBs. So nobody ever cold you about anything like that? . MS. PECK: Ob] act co tha torn at the question. I haaa aaaaared you aa booaatly aa I know how. Hhether anyone told me, I don't know. I don't ramamber. Okay. Now, you say Mr. Jessee was the plant manager at that time. Tell me, if you would, if he ever talked to you about -- Has he the plant -- Let ae ask you this: Has he the plant manager when you cook over? You mean in '74? Oh-huh (indicating yes), Z believe he was. Ha m aclll chara. Did ba avar talk with you or diacuaa vltb you any REGIONAL REPORTING SERVICE, INC. ADAD21-003706 HARTOLDMON0033662 2S --' 1 confidential memorandum chat he sent 2 to Mr. Crockact or Anybody alaa? 3 A. I have a recollection of anything like 4 thee. S Q. 6 A. who mi A Mr. G. w. Mtllr? That vaa orld Millar. 7 Q. Gerald Miller? 9 A. Tee. 9 Q. What did Mr. Millar do? 10 A. Well, when I came on board, he was the 11 plant chief chemist. 12 Q. He wee a person who preceded you? 13 A. well, no. I mean, there were several 14 ocher movement before my time. IS Q. Who took Mr. Miller** place? 15 A. Toby Bell. 17 Q- You had told ue about that. So 10 Mr. Miller and Mr. Bell and then you or 19 somebody else? 20 A. Well, see, when everything was downsized 21 in *7i and `72, there was a lot of 22 reorganization. It wasn't necsssarily. 23 you know, a direct replacement thing for REGIONAL REPORTING SERVICE, INC. 1 2 A. 3 Q. 4 5 7 0 9 10 11 12 13 14 15 10 17 10 19 20 21 22 23 look at that? Yes, I have. 27 What struck me - - If you will take a look at this Plaintiffs* Exhibit Seven. It appeared that Monsanto was aware of some pollution chat had been caused by your plant in Snow Creek, Choceolocco Creek, and elsewhere at that particular period of time, but there was an sffort being made at that particular period of time to do what you had mentioned a minute ago. And this may have come from the regulator, or lc may have come from a combination of both. But 1 vane what the source of the statement is, if you know. It says, "Give no statements or publications which would bring the situation to the public's attention." That's paragraph three. What I would like to know. Mr. Brown, if you know what the source of that was. Is that what you indicated earlier, where things were confidential? REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 5 7 o. S 9 10 11 12 13 14 15 15 A. 17 Q. IS 19 20 21 Q. 22 23 change. 25 But that's the general concept, yes. MR. STEKART: Mark that. (Plaintiffs' Exhibit Nisober Seven was marked for identification.} Let me let vnu take a look at Plaintiffs' Exhibit Seven to the deposition. I'll ask you if you ever remember seeing that memo, which is a memo from Mr. G. W. Miller to Mr. G. L. Jeseee. It's called Aroclor Pollution, AMIC Contact, up there at the top, dated May 7, 1970. No, X do not remember ever seeing this. Tell me, if you would -- MR. PECK: Feel free to read it. if he is going to ask you about it. Okay. If you want to read it, go ahead. I'm sorry. Have you had an opportunity to REGIONAL REPORTING SERVICE, INC. 1 A. 2 Q. 3 A. 4 5 c Q. 7 t 9 10 A. 11 12 13 14 15 Q. IS 17 10 A. 19 20 21 Q. 22 23 20 7 hava no Idas. Is chat what you meant by chat? No, sir. I'm telling you that stamping something like this confidential was a routine procedure. A routine procedure. You did it every time you had something to eay that had to do with something that you sent to a regulator? You did that yourself? Everything I wrote was strictly of a technical nature, had nothing from a regulatory standpoint. It had confidential marked on it. It didn't natter *hat It wai. This to do with information, I balla.a, about Aroclor pollution. That is PCB pollution, isn't it, Mr. Brown? Hell, Aroclor was the product that was being produced, which has later been dubbed PCBe. So you ara laying at that particular time anything that y*all did you put confidential? REGIONAL RESORTING SERVICE, INC. ADAD21-003707 HARTOLDMON0033663 1 A. 2 Q. 3 4 5 6 7 8 9 10 11 12 13 A. 14 15 IS Q. 17 18 19 20 21 22 23 7sail, it m a rcftitins procedure. 29 Hell, this also says, `Give no or publications which would bring the situation to the public's attention.* Back up there it refers to Mr. Crockett's receusendatioae were that that be done. why is it chat y all had worked this particular situation out. Mr. Brown? MR. PECK: Object to the Corn of the question. Anything I give you would be totally speculation. I told you I know nothing about it, end 1 hare no idea. When you took over in 1974, did you follow chat same policy if y'all had found or discovered chat chare was contamination of the stream there, the ditches chat led into the scream? And by streaiu z mean Snow creek or Choccolocco Creek. Wae ic y*all's policy at the time you cook over to keep REGIONAL REPORT!HG SERVICE, INC. 1 2 3 Q. 4 S 6 7 A. 9 Q. 10 11 12 13 14 i IS 17 18 19 20 A. 21 22 23 31 MR. PECK: This time would be in 1970? Well, che dace is May 7, 1970. Apparently Mr. Miller is referring -Old you read che letter? He is referring to conversations he had with regulators, is he not? I'm assuming he is, yeah. Okay. And a subject chat they discussed was giving no statements or publications which would bring the situation to che public's attention. And all I'm asking you, Mr. Brown -- it's real simple -- is was chat y' all's policy during chat clme chat you all had or you took she position? MR. PECK: Object to che form of the question, asked and answered. My answer is very staple. I don't know what the policy was at that tins. I *asn't involved, and you know, I have sworn here to tell you the truth, and REGIONAL REPORTING SERVICE, INC. l 2 A. 3 4 S Q. 8 7 e 9 10 11 12 13 14 IS 18 A. 17 Q. ie 19 20 22 22 23 30 that from the public? We didn't have any particular policy. Our policy was to ro--mmloacs openly with regulators, and that's what we did. Well, if -- So y'all would be opposed to giving those statements or publications which would bring the situation to the public's attention, that Mr. Crockett had apparently suggested in conjunction with somebody from Monsanto? 1 guess he was working with Mr. Millsr and Mr. Jssses and chsm. MR. PECK: Object to the form of the question, ic's unintelligible. I don't understand your question. Well, I will break it down so both you and your lawyer can understand it. I know ic was a little complicated and convoluted at some times, but let me make it as simple as I can. 7'all had conversations at this tims with the regulators, didn't you - - REGIONAL REPORTING SERVICE, IRC. 1 2 3 Q. 4 A. 5 s 7 e 9 10 Q. 11 12 13 14 15 18 17 18 19 A. 20 21 22 23 32 I'm telling you the truth as much as I know how. well -- And you can ask it fifteen more times. but i don't know how to answer it any dearer than 2 just answered it. I do not know. (Mr. Taylor Stewart entered the deposition proceedings.) Ac the elms you took that positicn, it's my understanding that you, Mr. Jerry Brown, stashed all those reports that you might have made to regulators as confidential? MS. FECK: Object to the form Of ths question. mischaractexizes prior testimony. Mbac I-., cold you i that .camping communications as confidential was a routine practice on practically all coosnuications that we did. Now, as tims evolved, this REGIONAL REPORTING SERVICE, INC. ADAD21-003708 HARTOLDMON0033664 1 2 Q. 3 A. 4 5 6 7 8 Q. 9 10 A. 11 12 Q. 13 14 IS A. 16 17 18 19 Q. 20 21 22 23 33 practice changed. When did that happen? Well, throughout the '70s and into the '80s. I mean, it's -- To give ycu a specific dace. 2 can't do it. There were different nays of addressing chose kinds of things. 3o that changed sometime in the time frame you are talking about? From a standpoint of putting that stamp on there, yes. What about letting the public know about information that you had gathered like this? Well, during the period of time that 1 was involved, we dealt openly with dll regulators, agencies, and people who guesttoned. Okay? Let me ask you, Mr. Brown. Do ycu know of any public meeting that was had by Monsanto, or even Mr. Crockett in conjunction with Monsanto, about the findings chat Monsanto made in 1970 in REGIONAL REPORTING SERVICE, INC. 1 2 3 4 S A. 6 7 6 9 Q. 10 11 12 13 A. 14 IS 16 17 Q. 16 A. 19 20 Q. 21 22 23 35 just read? Did a Mr. Scott Tucker ever tell you anything about that before you took your position as the chief chemist out here? Scott Tucker developed the analytical methodology for determining this. This was totally new technology in the '69, *70, '71 era. You cold us about that before. l*m just asking if ha cold you -- MX. PECK: He is crying to answer your question. So far as knowing the significance of that number at chat point in tins, Scott Tucker nor anybody else knew the significance of that number. He did not? That was developing, emerging Information technology. Who told you that, Mr. Brown? Is that just something you know by your experience with Monsanto, or did somebody specifically tell you, "Mr. REGIONAL REPORTING SERVICE, IRC. 1 2 A. 3 4 S 6 7 9 Q. 10 11 12 13 14 IS 16 VJ It 19 20 A. 21 22 Q. 23 34 Snow Creek and Choccolocco creek? I know of nothing. MR. STEWART: Let's just offer thee. (Plaintiffs' exhibit Nmnber Seven was offered end attached as sn exhibit hereto.) Let toe ask you, Mr. Brown. Did anybody ever say to you at any point in time during this elms frame we are calking about, before yen* took this position. that there were fittings in Snow Creek -- in the sediment in Snow Creek of fourteen hundred and thirty parts per million or Snow Creek near -- below the plane ac aixteen fifty-.lx part* pec million -- Did you ever know anything about that? I remember findings. I don't remember the specific numbers. Did anybody swer cell you the significance of those two numbers that I REGIONAL EIwGkTXKG SERVICE, INC. 1 2 3 4 A. S 6 7 9 10 11 12 13 14 15 16 17 19 Q. 19 20 21 22 23 36 Brcnm, I don't too. tbe .ignificanc. of fourteen hundred and thirty parts per million in the mud"? Mr. Stewart, if you can conceive of developing s database from nothing, from the development of technology, through the development of technology, to the generation of some numbers, then the evolution end the procese is as you learn more sod more and more, you learn more more about the potential significance. And you know, to say at that point in time that Scott Tucker knew the significance, ! can't say he did or didn't. I naan, chac *a dv.loping, emerging knowledge. Okay. Let ms ask you if you know. Mr. Brown, if any of that information. whether it be those numbers I mentioned to you or any other numbers that wars received by Monsanto at that time as a r.aulc of sampling, .r. mad. toou co REGIONAL REPORTING SERVICE, INC. ADAD21-003709 HARTOLDMON0033665 '-- 1 2 A. 3 Q. 4 S 6 7 A. 8 9 10 Q* 11 12 A. 13 Q14 IS 16 17 A. 18 Q. 19 A. 20 Q21 22 A. 23 Q. che public? 37 I do not know. How exacely, if you know, Mr. arown, did the Aroclors or che PCB* chac were In che edimenc in Snow Creek -- how did ic gee chore? Hell, ic wee generally assumed from che waste water discharge leaving Che facility. Prom che waste water discharge leaving che facilicy? Tes. Well, you have previously mentioned that they were burying PCS waste in certain cells in the southern landfill. Has chat being done at that cine? Mot after che plant wae shut down, no. Before chat, though? Tee. In the '60s and '70a ic was buried over there? Tee. Has there any effort made at chac poinc REGIONAL REPORTING SERVICE, INC. 1 2 3 4 S 7 9 10 Q. 11 12 13 14 IS IS 17 A. 18 19 Q. 20 21 22 23 39 MR. PECK: Tou have marked che same exhibit, I chink, before ae Plaintiffs' Exhibit Three, and he marked it on chac exhibic. MR. STEWART: Hell, want Co make sure that -- I naan. I'm not trying to trick him, just to keep this clsan if we can. Tall me, It you vould, Hr. Brows, wbara y' all -- where you understood chose hogs were being raised chac Honsanco purchased because of PCS contamination in 1970. Where were chose being raised? Has ic south or north of chac discharge poinc one? It was my understanding it was semewhers in this area here (indicating). All righc. Why don't you put "hogs* up there. Just mark 'bogs.' Just spell that word up there. And 1 want you to mark this as discharge poinc one, if you could. REGIONAL REPORTING SERVICE, INC. 1 2 3 4 A. S 6 7 0. 9 10 11 12 13 14 15 16 17 Q. 16 19 20 21 22 23 38 in time to crack che source of che PCBe chac had been found, to your knowledge. in Choccolocco Creek? To my knowledge it was tracked from discharge 001, which was the direct discharge poinc out of the facility. Hell, let me ask you this: Tou have told us about it, and X want to be sure chat X understand it. X have a map here that I want you to cake a look at chat might help me in understanding what you ars tailing us. There is a MR. STEMART: Mark Chat. (Plaintiffs' Exhibit Nwber Eight was marked for ident 1 ficat ion.) This is Plaintiffs' Exhibit Bight. Tou had cold us previously chac chare was sons -- Can you first marie for us with chis pencil here che discharge poinc chac you are calking about? Or take this pen here, and it might be a littls easier. REGIONAL REPORTING SERVICE, INC. 1 A. 2 Q. 3 4 5 6 7 A. 6 Q. 9 10 11 A. 12 13 14 Q. 15 A. 16 17 Q. 16 19 20 A. 21 22 Q. 23 40 (Executed by the witness.) Is it fair to say that the terrain chat we see out there on che ground, the place where the hogs are, would be uphill or upgrade from che discharge point od? Tes. Is there not a ditch that runs near that hog area, near where the Mars Hill Missionary Baptise Church laT There is a drainage ditch that runs somewhere down through here. I'm not sure exactly. Can you mark it for us, please, sir? Well, i can draw something general. It would be something like so (indicating). Does it go back up to the road? Ooes it come from under the road in a culvert over there, now that 202 is in there? Hell, there is a culvert there somewhere. I'm noc sure exactly where. Hell, does it feed into che ditch, is what I'm asking you? Do you know REGIONAL REPORTING SERVICE, INC. ADAD21-003710 HARTOLDMON0033666 1 2 A. 3 4 S Q. s 7 A. ft 9 Q. 10 11 12 a. 13 Q. 14 IS 16 17 16 19 20 A. 21 22 Q23 whether or not it does? Well, the drainage haa got to -- What 41 era of time? i mean, it obviously doesn't anymore. Since remediation is there. But I meant -* The drainage was in this direction (indicating). Can you draw a little line where the direction was? didn't you? Tou just pointed there. uo you mean like that (indicating)? Mo. Back up there toward the southern landfill is where I'm trying to see. Let me just ask the question. Is there any drainage to your knowledge that came off the southern landfill that fed into the ditch chat you hare drawn here? Well, the surface water is flowing in this direction (indicating) . Can you draw a line in the direction where you would be calking about REGIONAL REPORTING SERVICE, INC. 1 Q. 2 3 A. 4 S Q6 A. 7 9 Q. 9 10 11 12 13 A. 14 01$ 16 A. 17 Q. 16 19 20 A. 21 22 Q. 23 A. 43 Well, it didn't stay that way, did it. Mr. Brown? What do you mean, it didn't itay that way? Stay a totally overgrown area. Cargrcsa until it sss cleared out tor remediation. There was a ditch -- Tou weren't surprised by the fact that there was a ditch located n*sr the Mars Hill Missionary Baptist Church and down, near Bethel, were you? No, no* ' That is something you knew about, wasn't it? Tes, yes. Tou knew about that when you were the chmist out there and took over that job in 1974, didn't you, Mr. Brown? 1 knew there waft a ditch that cams down through here. And ultimately fed into Snow Creek? But ao far ae walking hack up through REGIONAL REPORTING SERVICE, INC. 1 2 A. 3 4 Q. S 6 7 6 9 A. 10 Q. 11 12 A. 13 14 Q. IS 16 17 16 19 20 21 A. 22 23 connected to the ditch, Mr. Brown? 42 Well, I mean, I don't know where to draw the line. Okay. Would it be in the general direction you have drawn there? Can you just put Mitch* along there and just spell chat out for us so we can see that in your own handwriting? (Executed by the witness.) la that correct, about right where it would be, Mr. Brown? Well, I'm telling you to the best of my knowledge. Well, Mr. Brown, you worked out there for a good period of time, and you were the environmental person out there as the chief chemist. Are you telling me sitting here today that you don't have any idea of where the surface water goes off the southern landfill? I'm telling you that this was a totally overgrown area, and I never walked back up in there to see exactly where it was. REGIONAL REPORTING SERVICE, INC. 1 2 3 4 Q. 5 6 7 8 9 10 A. 11 12 13 Q. 14 A. 13 Q. 16 17 18 19 20 A. 21 22 23 44 hers, I never did it and never even thought about - I mean, I never even conceived the idea of doing it. Old anybody connected with this particular project in 1971 ever cell yew about having these real high readings in the sediment in Snow Creek and say, "Tou know, we better look and find the source of that"? Hall, cha aourca, aa uadercood by everybody that X ever ns connected with, was the discharge point, 001. But that came out of the plant sice? Tes. And when you quit, I guess, the simple answer for y'all to say at this point in time, when you quit making it, it stopped coming out of there? Is that what you*re celling me? Well, that's the purpose of shutting the plant down, to shut it down. I mean, chat was the most responsible action that any human mind could conceive of in REGIONAL REPORTING SERVICE, INC. ADAD21-003711 HARTOLDMON0033667 1 2 Q3 A. 4 S a6 7 8 9 10 11 12 A. 13 14 Q. IS 1 A. 17 Q18 19 20 A21 22 23 1971, '72. 4S A* you understood it? Well, I'm jiving you answers as I understand them. Okay. None of these other people. Mr. Papageorgs, who was a former plant manager and then connected utu the PCS problem, he never cold you, "Mr. Brown, 1 think you perhaps need to check someplace ocher than this discharge point"? Mr. Papageorge- was gone at that point in time. He did or did not tell you? He didn't tell you that? Ho. Did Mr. Scott or Mr. wheeler or Mr. Hodgee or any of cboee people ever tell ycu to check up above there? Nobody told me to check anyplace when I started working. That had already been taken care of. 1 think I have explained that one cirae. REGIONAL REPORTING SERVICE, INC. 1 2 A. 3 4 S 6 7 Q. 8 A. 9 10 11 12 13 14 <3. IS 16 17 16 20 21 <322 23 47 sauries of the water: is that correct? When I became involved in 1974, that work had been brought to closure, arid the sample* chat we took in here of water were directed toward phoephate concentrations. Didn't even Involve PCBs? It was the The concern at that point in time was chat the phosphate level did not meet the new standard, we started embarking on a program to eliminate the phosphates from that discharge. All right. Tell me, if you would. Mr. Brown, if there was some comnunication made to y' all by the EPA after you took over. MR. PECK: Any particular subject W4 JtW ysilB441jrr MR. STEHARTt Well, in 1975. Was there some concern expressed by the EPA to the plant about PCBs at the Anniston plant? Do you remember REGIONAL REPORTING SERVICE, INC. 1 Q. 2 3 4 5 A. 6 Q. 7 A. 8 Q. 9 10 11 12 13 14 IS A. 16 17 18 19 20 21 22 <323 46 And you were checking water, weren't you, over there? Tou weren't checking sediment. Tou were checking water discharge from the plant, weren't you? When? In this time frame we are talking about. In 1974? From site one, or what did you call that, discharge point one? Fran that discharge point, y'aXX were checking water, weren't you? You weren't checking sediment? MR. PECK: In 1971? MR. STSMART: '71 or '74 -Well, eee, I don't know what they were aoug. ujiayr im group Liwi. >* xo charge of doing chat job, I do know they were analyzing water. I do know that some sediment samples were being analyzed. But I don't know specifically where they took chose sediment samples. When you took over or when the people under you cook samples, they cook REGIONAL REPORTING SERVICE, INC. 1 2 A. 3 4 Q. S 6 7 8 9 10 11 A. 12 13 14 IS U 17 a18 A. 48 anything about it? I don't remember anything specifically in 1975. Are you telling me that as the person responsible for the environment there that you didn't know anything about that, that It didn't happen, or are you just having seme trouble remembering it? Would refreshing your recollection help you a little bit? It may. MS. STEHABT: Mark Chi*, if you would. (Plaintiffs' Exhibit Number Nine was marked for identification.} Have you had a chance to look at that? X scanned it. I didn't read It in 20 Q. 21 22 23 Do you remember ewer seeing this Exhibit Nine, this letter dated October 17, 1J7S, from Mr. Stanley M. Legro, ho la the assistant administrator for REGIONAL REPORTING SERVICE, INC. ADAD21-003712 HARTOLDMON0033668 1 2 3 A. 4 Q S 4 7 9 9 A. 10 Q. 11 A. 12 13 14 15 16 17 19 19 20 SI 22 23 enforcement Cor the United state* 49 Environmental Protection Agency? 1 do not remember seeing this. As the envirozsnental person who was involved in this particular facility as of 1974, do you Clad it surprising. Mr. Brown, that you weren't included in on this kind of thing? No, sir, 1 do not. Tell me why. And let me explain one more time. He were - - we were Monsanto Agricultural Products Plant in 1975. I was working with the compliance activities oC the ongoing operations at tha plant. PCB Issues were consolidated in St. Louis with the people who were working with PCB issues all over the country. wherever it might have been involved. And it was their job to handle the PCB issues related to the Conner operations at the Anniston plant. My job was addressing the ongoing operations at the REGIONAL REPORTING SEkVI^, INC. 1 2 3 4 5 A. s 7 4 9 10 Q. 11 12 13 14 14 17 14 19 20 21 A. 22 23 51 Creek? MR. PECK: Object Co the form of the question, calls Cor speculation by this witness. Hell, l assumed they were knowledgeable issue and they could handle their job and that wae deCined as part oC their job. What I'm asking you was, Mr. Brown -I'm not trying to be cuts or anything. I'm just trying to ask you. Don't you think it would be la^ortane to let the EPA know at this particular point in time what they Ccuad in Snow Cresk and what they Sound in Qioccolocco Creek? MR. PECK: Object to the Cora of the question, calls Cor speculation from this witnsss. I don't understand enough about what you' re talking about to answer the question. REGIONAL REPORTING SERVICE. INC. 1 2 Q. 3 4 5 9 A. 7 9 Q. 10 11 A. i2 Q. 13 14 A. 15 Q. 14 17 19 19 20 21 22 23 50 plant. Tell me, if you would, whose responsibility was it at that particular time. If you know, of handling the response to that question? I believe Mr. Papageorge was coordinating that at that point in time. That is based strictly on ay memory. Do you know who responded to this lectsr? NO. sou don't have any idea who responded to it? I answered no. To your knowledge, Mr. Brown, would it not be important in responding, as a person who knows or at least is responsible for dealing with these regulators -- Do you think it might be important at this particular point in time tor s person woo wee coapuiiuiuy Lw the EPA, to let them know what y'all had found in Snow creek and Cboccolocco REGIONAL REPORTING SERVICE, INC. 1 Q. 2 3 4 S c 7 A. ' 9 10 11 12 Q. 13 14 ie 14 17 19 19 20 21 22 A. 23 52 Hell, if Mr. Papageorge answered it. would Mr. Papageorge have been required. as you understood it, as an environmental person at the plant here. working for Monsanto Chemical Company at I didn't work for Monsanto Chemical Coaqpany at that time, as I told you previously. Z worked Monsanto Agricultural Products Company at Chat elms. well, for that company, do you think it would be important for him to let this particular inquirer, the EPA, know about what y'all had found is the '70s, which is just about two or three years before this, in Snow Crsek and Cboccolocco Creek? MR. PECK; Object to the form of the question, calls for speculation. Z can't answer that question. I don't know. REGIONAL REPORTING SERVICE, INC. ADAD21-003713 HARTOLDMON0033669 1 Q. A. <3. Well, take a look again -- I chink ic 53 ays the United States Environmental Protection Agency. They ver there, of course, Mr. Brown -- and I hats to b single above it -- to protect the environment, were they not? Nell, they had certain rules and regulations that ic was their duty to carry out. And they were crying to find out if there was some exposure or contamination of sstar bodiaa, I think ho says, fish. things like that, of PCBs in the environnent. were they not? Take a look at paragraph one of the letter. Read it again, Mr. Brown, and tell me if that is not exactly what they were looking for. MR. PECK: Object CO the form of the question. The doctsaenc speaks for itself. If he's going to ask you about the documents, you REGIONAL R&k-ORiiNG SSkvxua, ISC. 1 2 3 4 Q. 5 6 7 S A. 9 Q. 10 11 12 13 14 IS 16 17 18 19 20 21 22 A. 23 Q. Che question, calls for 55 speculation about what somebody wanted. Hell, look at page -- It is Bate scamped 216. Look at 216, Mr. Brown, paragraph C. Read that to yourself, and then let me ask you some questions about it. Okay. Tell me, if ycu would, Mr. Brown, if chat is not asking for the concentrations of PCB compounds or mixturss in the water, receiving waters. both upstream and downstream, of say discharge the company has at the Anniston plant. MR. PECK: That is a continuation. It's part of paragraph seven. Okay. It's fair that the witness have an opportunity to read the whole paragraph. MR. STEWART: All right. Okay. Okay. REGIONAL REPORTING SERVICE, INC. 1 2 3 4 S 6 7 Q. a A. 9 10 Q. 11 12 13 14 15 16 17 It A. 19 20 Q. 21 22 23 ought to read the whole S4 document. MR. STBcajETz Nell, Z thought he had. MR. PBOCi He said he glanced at it. Go ahead, and read the whole thing. Okay. I "re looked at it in a little bit more detail. Okay. Tell me, if you would, Mr. Brown, If he ie not asking for, in this particular document, exactly the effect chat the emissions from the plant had on the environment. MK. PSCXi Obj act to ebs font of the quest ion. Tha document speaks for itself. The request that 1 see is for a very specific list of requests here. Are you saying chat he didn't want to know what effect the releases of PCS* from tha plant had on the environment? MR. PECK: Object to the fora of kjsuXuHAL kju'uiiTXmv SbkVxub, xmu. 1 A. 2 Q. 3 4 5 A. 6 fl. 7 A. 6 g. 9 10 11 12 A. 13 g. 14 ie 16 17 18 19 20 21 22 23 X. 56 And what's your question? Isn't that asking for what effect your discharges from the Anniston plant have had on tha receiving streams? No. It asks for concentrations -- Tn raeciT^na aeraani? In receiving waters. Well, what would Snow Creek be. Mr. Brown? Isn't that a'receiving water that would receive discharge from the plane? Teah, yeah. To your knowledge did Mr. Brown * or did you, Mr. Broim, or did Mr. gapagsorgs. saer sabs knosn to tbs appropriate authorities, the Environmental protection Agency, what fiwlings they had made in the 1970s? MR. PKCRt Objact to tba fora of the question, calls for peculation from this vltSMS. Mall, you knou, Mr. Stattart, I think I REGIONAL REPORTING SERVICE, INC. ADAD21-003714 HARTOLDMON0033670 1 2 3 4 QS c A. 7 8 Q. 9 10 A. 11 12 13 14 Q. IS IS 17 A. 18 Q19 20 21 22 23 57 have answered before chat -- I do noc Know. I have never seen thJ* before. Z do not Know now chat was answered. Don't you cblnk chey should have. Mr. Brown? if you knew - - I can't put myself In cheir position in the 1970s. Oh, you mean they shouldn't have? Are you saying they shouldn't have? I would have expected that this questionnaire was answered with the best available data ac that point in time, but I do noc know. Do you know whether or not the fieh data and the ocher data was provided to the EPA by Mr. Papageorge? No, I do not know. Hell, if he had responded to this question at this time, in October of '7S, he certainly should have done that. shouldn't he, Mr. Brown? MR. PECK: Object to the form of che question, calls for kSwxoKAL reporting service, inc. 1 2 3 4 Q. S 7 8 9 10 11 12 13 14 15 A. 15 17 Q. 18 19 20 A. 21 Q. 22 23 . 59 (Plaintiffs' Exhibit Number Ten was marked for identification.) Let me give you Plaintiffs' Exhibit Ten. If you will look on page - - I think it's the first -- I mean, it's called potential hazardous waste site inspection report. I think it's about the fifth page, at the top. And your -- This is a bad copy to begin with. Mr. Brown. 1 apologize. But there should be down there, about three-quartara of the way down the page, Jerry Brown and Bill Taffee. What page are you os? They have numbers at the bottom. Teah, this one right here, it may be put together - - Tours may be put together different. I apologize. Okay. ` There is a Darrell Baker. And he Is che person * Does that rsfresh your recollection? Do you remamber now REGIONAL REPORTING SERVICE, INC. 1 2 Q. 3 4 5 A. 6 7 8 9 10 11 Q. 12 13 14 A. IS Q. IS 17 18 19 A. 20 21 22 Q. 23 58 speculation from the witness. To properly comply with Che requests of the Environmental Protection Agency? MR. PECK: Same objection. I would assume so. MR. STEHART: Offer that. (Plaintiffs' Exhibits Numbers Bight and Nine were offered and attached as exhibits hereto.) Now, Mr. Brown, do you remember sometime in 1981, in January of 'si, calking to a fellow from the EPA named Darrell Baker? I vaguely remember che name, yes. Do you recall giving him ac that particular point in time same information about the amount of PCBs that were buried on the plant site? It's possible, as part of a survey or request, that information was submitted. I simply don't remember specifics. Let me give you Plaintiffs' Exhibit -- MR. STEHART: What would chi. be? rbGiONAL RjsyuKriNG Skhvich, IHC. 1 2 3 4 A. 5 Q. 7 A. 8 9 Q. 10 11 A. 12 Q. 13 14 is 18 17 18 19 20 21 22 A. 23 Q. 80 having a conversation with him in 1971, when he made an inspection of the plant site? Right. what was this in conjunction with? Do Well, he was with the solid waste group of che state, as it shows hare, not EPA. Hicb cm Alabama Oapaxcmanc of Public Health? Teah, the solid waste division. What X have reference to in the earlier things that I had calked with you about ie there is an estimation made at some _ - , _ -- J. -- _ 2___ l _ .VI -- J---T it's in yours. It was in mine. It's supposed to be in yours --of the amount of the -- it may be a front and back kind of ctaing -- of PCB. cbac ar buried there, parathiou and others. Do you see cbac? I. cbac cbac pag. (isdicacing)? I believe so. REGIONAL REPORTING SERVICE, INC. ADAD21-003715 HARTOLDMON0033671 1 2 3 4 5 6 7 Q. ft 9 10 A. 11 12 y13 A. 14 <3IS 16 17 18 19 20 21 22 23 81 MR. STEWART: Can just mark that as Ten A so we have got Chae turkd? (Plaintiffs' Exhibit Number Ten-A was marked for idenc it icat ion.) Can ycu tell us bow much in tbs way of parachion was buried there in the landfill? Well, this says ten thousand pounds -- ten million pounds. What about pcbs? The sans. Now, do you know what you and Mr. Taffee had reference to by way of a landfill at that particular point in time, because you have previously mentioned to us that it was your guesstimation or your understanding, rather -- i will withdraw that -- your understanding that the PCBs were buried in this southern landfill over there. Was that what you were talking about at that point in time? REGIONAL REPORTING SERVICE, INC. l 2 3 A. 4 Q* S 7 8 9 10 A. 11 12 13 Q. 14 is 18 17 18 A. 19 20 Q. 21 A. 22 Q. 23 63 that he had looked at and hia knowledge of the residue? I do not know. Is it not a fact -- I believe you cold us last time that it was, Mr. Brown -that y* all kept manifests of the waste chat you - Mr. Taffee did on a regular basis while be was aanagsr of the landfill operation? Well, that started At a particular point, but that was wsll aftsr the Aroclor operation was closed. Okay. But you also mentioned last time that he had production records sad y'all could calculate fairly accurately the residue or the wests chat would coos off of that system -I mentioned that was one way. But in 1962 or whenever this survey was dons -- I think it was *61. -- all those records were long gone. Where were they? You indicated earlier they were archived? Have you come to a REGIONAL REPORTING SERVICE. INC. 1 A. 2 3 Q. 4 5 6 A. 7 Q. 6 9 A. 10 Q. 11 12 13 14 15 16 A. 17 Q. 16 A. 19 20 Q. 21 23 A. 23 Q. 62 Well, I mean, it was -- it was both whet la called the western and the southern. When you say western, are you talking about the landfill area that is south of 202 now? No. West of the plant. West Of the Blanc and south Of the plant? Right, right. How is it, Mr. Brown, that you arrived at what was there? Maybe I misunderstood you last time. If I did, I certainly apologize to you. But how did you arrive at this figure? Let me ask you that first. This figure? Uh-huh (indicating yes). That was just slowly Bill Tsffee's best guess. So Mr. Taffee is the one who mads that assessment at the time for Mr. Baker? As a ballpark guess. Was chat based on production figures REGIONAL REPORTING SERVICE, INC. 1 2 3 A. 4 Q. 5 6 7 6 9 A. 10 11 12 Q. 13 14 15 18 17 A. 18 19 Q. 20 21 A. 22 Q. 23 64 different conclusion sines you and I met last time? * No. They were archived. So at that point in time they vers in existence? Would you assume chat Mr. Taffee lied to the man about the ten million, or is that as accurate a figure as he could get? No. Htaae I'm tailing you i tor chc puzpoaa ot chi* it ,t up .a somebody's best ballpark estimate. Who other than Mr. Taffee would have a clear understanding of what was buried out there? He had been there for a while, hadn't he, at the time that this report was mads, at the plant? Yeah, he had been there for several years. How long had he been there at the time this report was mads; do you remember? Probably twelve or thirteen. Would there bay, bn p.cpl. h* could have contacted or talked to or had REGIONAL REPORTING SERVICE, INC. ADAD21-003716 HARTOLDMON0033672 --" (S 1 conversation* with ac chat point in 2 time? ' 3 A. Twenty. 4 Q. Sir? 5 A. S 7 Q~ 8 9 10 A. More than chat. He had been there about twenty years at that point. He had been there about twenty years? So he had been there since onetime in the '60s, the early '60s? Tes. 11 Q. So he had a pretty good knowledge of 12 bac suriaa tbr, t*r you low*; 13 is chat correct? 14 A. IS Q- A much better knowledge than I did, yea. Is that why you pulled him in to assist 16 17 A. in making this assessment? No. He had the direct landfill 19 responsibility 19 Q. So it va> -- 20 A. -- in operating the Landfill. 21 Q. And it was his responsibility to know 22 how much was buried there? 23 A. As much as we had knowledge at that REGIONAL REPORTING SERVICE, INC. 1 2 A. 3 4 5 6 Q. 7 8 9 10 11 12 13 14 IS 16 17 19 19 20 21 22 23 67 what you had said last time? Well, to say sicced on -- I mean, he made them aware chat tha potential for PCBs further upstream in Snow Creek existed. I mean, to his knowledge. Let me show you something that we will mark as Plaintiffs' Exhibit Eleven and ask you if you recall -- ask you if you recall seeing this exhibit ac some point in time around that period of time. (plaintiffs' Exhibit Nusaber El even was marked Cor identification.) MR. PECK: Donald, Z think you have got nan-sequentiai documents there. I chink the document marked as the first page is a single-page letter from the Attorney General, aad it*, clipped co nN other stuff that I don't think necessarily goes with it. REGIONAL REPORTING SERVICE, INC. 1 2 Q. 3 4 5 6 7 9 9 ID A. 11 12 13 Q. 14 15 16 17 It 19 20 A. 21 Q. 22 23 point in time. <6 Now, Mr. Brown, you have mentioned chat your next involvement, I believe, was a situation chat cook place sometime in 199S or '94. Do you remember what we had talked about last time in connection with that, the problem with er Koeisei and tboee kind of folks? Do you renumber that? Hell, I remember the situation that led co an analysis program on Snow Creek, if that's what you're asking about. And I believe last time you indicated co us while we were here that there was a situation chat occurred at another facilitv that is the reason v*a11 got involved in it, a facility owned by a gentleman named Tull Allen. Do you recall telling me about that last time? Tes. That he sort of sicced y'all on them -- sicced them on you. Is that your understanding of the situation? Is that REGIONAL REPORTING SERVICE, INC. 1 A. 2 Q. 3 4 5 6 7 A. 9 Q. 9 10 A. 11 Q. 12 13 14 A. IS Q. 16 17 19 A. 19 20 g. 21 22 23 68 This document is a stand-alone document. Okay. I'm sorry. I thought they were connected. That's the way they were in my little thing. Do you remember seeing that letter? Tes, I do. Of course, that's to Mr. Richard Mahoney; is that right? Tes. Now, Mr. Mahoney is or was at that time the president of Monsanto Chemical Coepany, wasn# t he? Tes. Did you work for that chemical company at that time, or were you still working for the ag company? I still worked for the ag company ac that point in time. put was he the president of the whole operation Has he ultimately your big boss, Mr. Brown? Lee me ask It that way. j REGIONAL REPORTING SERVICE. INC. ADAD21-003717 HARTOLDMON0033673 1 A. Q- A. Q. A. Q. A. Q. A. Q. 69 I believe to, at that point in tima. H vaa corporate president. Mail, ha put something together at chat particular period ot cime called the Monsanto Pledge, dicin' t he? Are you familiar with chat? Tea, I am. Wasn't it about this same time, Mr. Brown? That's likely. And did that have anything to do with the enviromenc, Mr. Brown? Tee, it did. It was setting standards for operational facilities. Which was to -- One of the tenets of that pledge, which I assume all of y'all took -- You were familiar with it. weren' t you? Tee. -- was to reduce sll toxic and hazardous releases and emissions, working toward an ultimate goal of zero effect. Is that what y'all decided to do under that REGIONAL REPORTING SERVICE, INC. 1 2 A. 3 Q. 4 5 5 7 8 A. 9 10 11 12 Q. 13 A. 14 Q. 15 1C 17 A. 18 19 20 Q. 21 22 A. 23 71 frame? Tes. Okay. Now, were you the one, Mr. Brown, who was assigned by Monsanto to take care of this thing in that time frame? Mere you the person who was sort of set up to do that? Well, I mean, no one person was set up to take care of it. It was a team kind of effort to pull together to try to address the situation. Were you on the team? Tes, I was. Okay. And tell me, if you would, if you later put together a plan to take care of this, a sediment removal plan? Well, we put together some studies that led to the development of a sediment removal plan, yes. That you sent to Mr. Kneisel at some point in time? It was sent to several people, EPA, Kneisel, ADEM. REGIONAL REPORTING SERVICE, INC. w l 2 A. 3 Q. 4 S C 7 a A. 9 Q. 10 11 12 13 14 15 q. 1C 17 18 19 20 21 22 23 70 pledge, pledged to do? Tes. And you were aware of that when Charlie Oraddick -- the Attorney General'# letter came to y' all here at the plant? I assume this ultimately made it to the plant. Tes. And then there was another letter that was dated February the 2Cth, 198S. And I will give you this c^y of it. (Plaintiffs' Exhibit Number Twelve was msrVart for identification.) z don't have a copy of that, if you want to look on with him. Do you want to take a look at that? That is a letter to Mr. Broadwater from -- who is director of the Alabama Department of Saviroxmental Management, from Mr. Craig Kneisel. Do you remember seeing that letter at some point in time during this time REGIONAL REPORTING SERVICE. INC. 1 2 3 4 S Q. c 7 8 9 A. 10 9. 11 A. 12 13 14 15 1C 17 q. 18 19 20 21 22 A. 23 Q. 72 MR. STEWART: Mark that. (Plaintiffs' Exhibit Number Thirteen was marked for identification.) Let me show you Plaintiffs' Exhibit Mlok Ju b-- n__a__1. in m, .y-u--u. wAv .w.1a1i* M. 4# ,<.mV. . 1. tbs thing y'all aanc or you put together. Hall, I didn't put thia cog.char. Who did? Okay. We had a group of consultant# in St. liouia -- I aay conaultantsj they were Monsanto people -- whose specialty it was to work in these kinds of areas. ao they put vu -- protocol. And you sent it on to Mr. James Moore, who was an engineer and head of the Industrial Branch ot tba Hatar DWiaion of tha Alabama Dapartmant of Snvlromental Management? That's correct. By this lattar datad May ISth. ISIS? REGIONAL REPORTING SERVICE, INC. ADAD21-003718 HARTOLDMON0033674 1 A. QA. QA. Q* A. Correct. 73 MR PSCIt: Just for clarity, Don, I chink you have - - THE WITNESS: I chink you haTe 90c things confused here. MR STEWART: Tell me. I certainly don't want that exhibit to confuse anybody. MR PECK: Never mind. We just had extra documents attached that weren't related. ME . PSC3C: That's not part of it. MR . STEWART: All right. Thank you. When did y' al1 do the work on this tuff? Do you specifically mean the sediment removal? Tee. In about 1989, '90, something like that. Weil, now, you had a different Attorney General after that, didn't you? I think so. KEUIUNaL REPORTING SERVICE, INC. 1 2 A. 3 Q. 5 Chemical Association Is? Simply a trade group of chemical manufacturers. And what is the government relatione group from Monsanto? 75 7 8 9 10 11 12 13 14 1 2 14 17 18 19 A. 20 Q. 21 A. 22 Q. 23 representatives frcm all facilities in the state who met periodically. We had representative. And he coordinated this group, with a meeting in Montgomery once or twice a year, to stay up to dace on what was happening on the state scene from a state regulations standpoint. Were you at the meeting on March the 2 9th, when Attorney General Siegelman met with the government relations group frcm Monsanto? I just answered previously, no. Well, now, the'-I don't remember being there. The meeting with the Alabama Chemical Association was on March the 23rd. That REGIONAL REPORTING SERVICE, INC. 1 Q. 2 A. 3 Q. 4 A. 5 Q. 6 A. 7 Q. 8 A. 9 Q. 10 11 12 13 14 Q. IS 18 17 18 A. 19 Q. 20 A. 21 Q. 22 A. 23 Q- 74 Who became Attorney General after that? I don't remember. . Do you remember Don Slegelman? Tee. who is David Denner? He was plant manager at Che time. Of Monsanto? of the plant here. of Monsanto's Anniston plant. MR. STEWART: Mark Chat. (Plaintiffs' Exhibit Mtsober Fourteen was marked for identification. \ Now, this is a letter from Mr. David Denner, which ie addressed to Don Siegelman. Do you want to take a look at that? You are copied on it. Okay. Did you go to the dinner? That particular dinner? Yes. No. Can you tell me what the Alabama REGIONAL REPORTING SERVICE, INC. 76 1 was a dinner that the Attorney General 2 poke at. The meeting on March the 29th 3 was a meeting that y' all had with your 4 government relations group just with the S Attorney General? 7 8 9 10 11 12 Q. 13 14 15 16 17 11 19 A. 20 g. 21 22 23 present in that meeting. Back during chat era semetimes I went to meetings sometimes I didn't. That specific meeting, I don't think X was chare, but I'm not sure. Do you know whether or not, Mr. Brown -- I believe you have already said this. 0 1st me withdraw that guest ion. The work was dose after these two IQ..C ing. and aft.r chi. l.cc.r vaa aanc on April tha ISth of 1)11, on Snow Creek, wasn't it? Oh-huh (Indicating yM). Ia 1C hoc a face, Mr. Brown, that all y'all did ac Chat point in cima waa taka away about fifty feet of -- take soil away from about fifty feet of Snow REGIONAL REPORTING SERVICE, INC. ADAD21-003719 HARTOLDMONOQ33675 1 2 A. 3 Q. 4 A. 5 Q. 6 A. 7 8 9 Q10 11 12 A13 Q. 14 IS 16 17 18 A. 19 Q. 20 21 22 23 A. 77 Creak? Mo. How far down did you go? Gosh, aeveral hundred -feet. Weil, how many hundred feet? Mow, the protocol -- We are talking the tributary leading Cron Mara Hill all the way down to Snow Creak. Did y'all cake stutt awey from Che tributary that came by Mara Hill? MR. PECK: Bethel. - Bethel, Bethel. Bethel. Okay. So you came down paac Bethel. But I'm talking about an. Snow creek itaelf, after you got paat that tributary, you just did fifty feet of Snow creek? Something like that. Didn't y'all know at chat time. Mr. Brown, that there was coneiderably more chat y'all should have done in Snow Creek than that fifty feat? Mr. Stewart, I don't know what the REGIONAL REPORTING SERVICE, INC. 1 0. 2 3 4 5 A. 7 6 9 10 11 12 13 14 IS Q. 16 17 14 19 20 21 22 A. 23 i 79 Didn't you know that there was a problem further down the creek than what y'all did remediation on aa early -- You knew as early aa '93, didn't you -- I mean. '83. Didn't you? Mr. Stewart, we put this sampling protocol together to determine what should be remowed. And baaed on the data from that, the removal plan was put together based on the beat information we had at the time. We were working with the generally accepted fifty part per million guideline at that point in time. Now, Mr. Brown, U it your statement that there were no levels of PCBs in the sediment below that fifty foot deal that was more than fifty parts per million at that partioil&r point in time, based on studies that y'all had done at that time? Based on che sampling protocol, that's my - - REGIONAL REPORTING SERVICE, INC. l 2 3 4 Q. 5 A. 6 7 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 78 correct protocol is here, but we spent three years trying to gee permission to do what wa had proposed in 1986. And worked hard at it. And from three groups, the SPA, Alabama Deparoaanc of Enwironmantal Nuigmu, and the Attorney General's office. And finally, the lecter you've got there la an attempt to try to bring some raaolucion Co chi. thing. And finally. aa a last resort, we made a phone call and said, 'Okay, we are going to do this as proposed unless we hear otherwise.* And the answer was, *Okay." And aft.r chra. you. of crying co g.t agreements on what co do, that's what we did. And chat was baaed on the best knowledge chat wa bad at cbac point in time. I was expecting to be asked why tbe delay from '86 to '89. But we spent three years trying to get approval to carry out this. REGIONAL REPOSTING SERVICE, INC. 1 q. 2 A. 3 4 q. S 4 A. 7 8 Q. 9 A. 10 11 12 Q. 13 14 IS 16 17 A. 18 q. 19 20 21 22 23 80 The sstapling you did at that time? Well, it was a joint --It v&a a three-way effort. with the Environmental Protection Agency and ADOT? Well, the Attorney General'a office. ACEH, and ua. Oh, che SPA wasn't involved? They were involved as observers, hue they didn't split the samples. The samples were split three ways. Nall, lac aa juac aak you it in face. Mr. Brown, you had not been involved in sons testing of Qioecolocco Creek before chat and (pacifically soaseisa ia Match of 19*3 or mayba araa hatora. Choccolocco Creek, yes. Okay. And y'all had found, in conjunction with cha Cooaarratioa Department. PCBs in acme of che core san^les that were taken adjacent to Choccolocco Creek as early as March of 1983? REGIONAL REPORTING SERVICE, INC. ADAD21-003720 HARTOLDMON0033676 l 2 3 Q. A A. 5 Q` 4 7 A. ft Q. 9 10 A. 11 Q. 22 13 14 A. 15 Q. 14 17 1ft A. 19 20 Q21 22 A. 23 HR. PECK: 1 Object co che Corn of the question. Did you not? Tss. And you were involved in thee, were you noe? Tes. And yen had received sons sampling results, didn't you -Tes. - - that indicated to you there were sons fairly high levels of PCBe in some of thae sediment? No. Did you receive sampling, Mr. Brown from an individual named Robert Thompson, sampling information? It's possible. I don't remember the name. Tou don't remember meeting with a Mr. Robert Thcnpsan? It's possible be wee included in a lot of Chat group in the early 'SOs. REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 c 7 ft 9 10 11 12 13 Q. 14 A. 15 Q. 14 17 A. 1ft 19 20 21 22 23 there was evidence of a PCB ft3 contamination of Choccolocco Creek at Chat time? MR. PECK: Tou have got documents mixed up again. MR. STEWART: I do? THE WITNESS: Teah. This is not choccolocco Creek. Tou have things confused. MR. tztXi Plaiacltfa' Exhibit Fifteen, I believe, is just a one-page letter. That's your little creek survey? Huh? Is that your little survey you did of Snow Cr)c? That is Snow Creek. MR. STEWART: Why don't we just hay* chi* nuked? Lec'e get chat in and let him identify that. That is something I do nc co puc la chore. I don't want to make a mistake REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 Q. 4 7 ft A. 9 10 Q. 11 12 13 A. 14 15 14 Q. 17 1ft A. 19 Q. 20 21 22 A. 23 Q. MR. STEWART: Mark Chat. 82 (Plaintiffs' Exhibit Number Fifteen was marked for identification.) Let ms shoe you this, Mr. Brown. And I'll ssk you to identify it If you would. Okay. No, X never met with. Robert Thompson. Who is Jerzy Brown? It's dated November the 14th, 1983. It's a letter to a Jerry Brown. If you will look, it says assistant state conservationist. I met with Torbit Henry. Oh, I'm sorry. I told you guys. Tou renumber Mr. Torbit Henry? Tes. I apologize. Did y'all meet at that time to talk about PCB sampling on Choccolocco Creek? Tes. And did y'all find in chat sampling that REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 Q. 4 7 ft 9 10 11 Q. 12 13 14 A. 15 14 17 Q. 1ft 19 A. 20 Q. 21 A. 22 Q. 23 A. 84 and not put it in there. (Plaintiffs' Exhibit Number Sixteen was marked for identification.) That's what you found on Snow Creek? That's Exhibit Sixteen. Is chat the testing that was dons, the test results. just so we can identify chat? MR. PECK: It's a multi-page document, Jerry. Teah. Please be sure and identify it. I went co make sure ws get ic while ws have got you here. Tou travel a lot. My recollection. ch*c chi* i ch grab sampling that they did, and this was the sampling from the protocol. So the first part of that thing is grab anpling that the stats did? That's ay recollection. That's tbs map and tbs dark thing? Tes. And chen y` all did a protocol? Ws proposed we go in and sample that REGIONAL REPORTING SERVICE, INC. ADAD21-003721 HARTOLDMON0033677 1 2 3 Q. 4 S 6 A. 7 0. 8 A. 9 10 Q11 A. 13 Q. 13 A. 14 Q. 15 15 17 A. 18 19 20 21 22 23 area. And this is che collective S sampling chat 1 referred to. Old y'all do any sampling, Mr. Brown, below che fifcy feec -- Did y'all do any sampling below che fifcy feec? Yeah. How far down did vn*i go? Well, I guess a quarter mile, a half mile. Old you get near Mr. Tull Allan's place? That's still down here (indicating). It'e furchsr on.down? Yea. So there's no quescioa that the PCBe that were found, wherever they were. from Hosjsttc, right? Well, this grab sampling was used to define cbe area for more intensive sampling. And so then che intensive sarapling was defined in the area as shown on this nap. MR. PECK: By this map, you ara referring to DSW 024508? REGIONAL REPORTING SERVICE, INC. 87 1 this point in time the Toxic Substances 2 control Act was in place, which 3 epeeifled a limit of fifty parts per 4 million on PCBa. Anything above chat S had to be specifically handled in 6 accordance with Chat set of regulations. 7 Q. And y'all are telling me and anybody 8 else that might want to know that what 9 y'all did at that time was remove 10 anything that was above fifty parts per 11 million to Eaelle. You told us that 12 previously, didn't you? 13 A. That's in this sampling protocol, yes. 14 Q. And you didn't put that, except for a 15 short period of time to have It 14 analyzed, on your property, did you. 17 Mr. Brown? 18 A. That's correct. 19 Q.______All right. Maw. lee me when you ehle 20 exhibit. 21 Did you have anything to do with a 22 preparedness atatamanc that y'all put 23 together at that time, Mr. Brown? REGIONAL REPORTING SERVICE, INC. 1 2 Q. 3 4 5 5 7 A, 8 Q. 9 10 11 12 13 14 IS is 17 18 A. 19 q. 20 21 22 23 A. TOE WITNESS: That's correct. 84 So for all practical purposes, the answer to my question wculd be yes. which was the PCBa that you found in Snow Creek, whatever che level, came from your plant? Probahlv, All right. Now, you mentioned that y' all were the ones who had che capability to teat. Y'all also were the ones who had pretty good capability or knowledge about what you did to do away with them, is that right, to gst rid of them from Snow Creek or Choccolocco or on somebody's property or anywhere else. vmi. Mr. Brown? ME. PECK: Object to the form. Knowledge of how to do away with them? i don't -- How to dispose of them. T'all had a plan on bow to dispose of chemicals like this, didn't you. toxic chemicals? What is done is very specific. And by REGIONAL REPORTING SERVICE, INC. 1 A. 2 3 4 5 5 A. 7 8 q. 9 10 11 12 13 14 A. 15 q. 14 A. 17 18 19 o. ' 20 21 22 A. 33 Q. 88 I read it. MR. STEWART: Mark Chat. (Plaintiffs' Exhibit Number Seventeen was marked for idantifieatlon.) You have still got ms hanging with a question on this document (indicating). I'm going to ask you about that in a few minutes. I appreciate that, Mr. Brown. Lee me get to this one now. Exhibit Seventeen. Do you remember chat as being the preparedness statement? Just cake your time and read it. Okay. Mho put that together? I'm assuming toosbody in St. Louie. Nobody at the plant. Me didn't do this kind of stuff at th* plane. This was prepared by somebody in 3t. Lcrui.. Do you knov .pacifically vho it wae that prepared it? No, I do not. Did you bav any input in it? REGIONAL REPORTING SERVICE, INC. ADAD21-003722 HARTOLDMON0033678 1 A. 2 Q3 A. 4 5 < 7 8 9 Q. 10 11 12 13 A. 14 Q. 15 16 17 18 A. 19 20 Q. 21 A. 22 Q. 23 No, I did not. 89 Ac che cop of It -- If I had any input, it may have been to give a range on -- I mean, somebody gave eight of twenty-two core amnplea. Tou Know, some -- I don't remember if 2 gave any information like that or not, but that's possible. On page one it says Preparedness Statement, Anniston Plant, PCS Incident. And that was prepared by somebody in Monsanto in St. Louis? Tes. And then chore i a little missing thing in chars. It says creek feed# the -- Should that be Choccolocco Creek, Mr. Brown? That's probably the case. Whoever wrote this didn't know what it was. And ultimately flows to the Coosa River? Tes. So the creek they are talking about in that sentence first, when they say athe REGIONAL REPORTING SERVICE, INC. 1 2 3 Q. 4 5 5 7 a A. 9 10 Q11 12 A. 13 Q. 14 15 14 17 18 A. 19 Q. 20 21 A. 22 23 Q. 91 on snagging and dredging of Choccolocco Creek. I guess what I mean, that sentence says. "The creek feeds the* -- Would it be Choccolocco Creek there? MR. PECK: Object to the form of the question. well, Choccolocco creek is the creek chat was under study. Wall, char* la a Mask there. Should Choccolocco have appeared there? I'm guessing. All right. And tell me, if you would - Read paragraph - - On the laet page, read it to yourself. Did you have anything to do with that, or was that put together in St. Louie? No. That wae put together in Sc. Louis. Did Mr. Papageorge work with y'all on chia? Mr. Papageorge was long retired by this time. In !? REGIONAL REPORTING SERVICE. INC. 1 2 3 4 S 4 Q. 7 8 A. 9 Q. 10 11 12 13 14 15 14 17 18 19 A. 20 Q. 21 A. 22 23 90 creek," that would be Snow Creek? Is that your understanding of it? MR. PECK: Object to the form of che question. The document speaks for itself. Just so we understand it, is that Snow Creek, Mr. Brown? Could you repeat the question? Hall, In tha last aentsmce of cba fine paragraph of Plaintiffs' Exhibit Seventeen it says, "The creek feeds the blank creek and ultimately flows to the Coosa River.* Tou indicated you had some input at least into a portion of that paragraph where you talked about core wangles. Is the first creek there -- Can we assume that's Snow Creek? No. What would it be? This work was cor the dredging of Choccolocco Creek, che program that the Soil Conservation Service was proposing REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 A. 7 8 9 q. 10 11 12 13 14 A. 15 Q. 14 17 18 11 20 21 22 23 q. 92 Was this for the press? Old y'all release this to che press? ' MR. PECK: Object to the form of the question, calls for speculation. I don's Sosos vSsst ::: dons vis's is. 1 remember reading it, but I don't ever remember it being used. Nell, was this a preparedness statement from up top celling y'all what to do? MR. PECK: Object to the form of the question, calls for speculation of this witness. I don't know. Based on your previous testimony, Mr. Brown, you have indicated that the FCSe chat were found in Choccolocco Cre.lt came from y'all's plans. HR. F8CK1 Object so she form of the question, incorrect characterization of hie former testimony. Tou can go ahead and answer it. REGIONAL REPORTING SERVICE, INC. ADAD21-003723 HARTOLDMON0033679 I A. 2 Q. 3 A. 4 5 Q. 6 7 A. a Q9 A. 10 Q. 11 A. 12 13 14 15 Q. 16 17 18 19 20 21 22 23 You said Ghoccolocco Creek? Tea. 93 I don't, think I testified to affect. I did Saov Creek. And where is it that you think it cane from in Choccolocco Creek. Mr. Brown? well, from our plant and from Tull. okay. From yc*ir plant and frem Tull? And possibly other sources. Which are what? Well, you know, for many, many years PCBs were used in many, many, many applications, including paper, copy paper, and roofing materials. Sort of like the little boy who got in trouble out in the front yard. That's your story, and you are sticking to it. isn't it, Mr. Brown? MR. PEOC: Object to the form of the question. You don't have to answer that. MR. STEWART: All right. We will offer Chat. REGIONAL REPORTING SERVICE, INC. l 2 Q. 3 4 5 6 7 A. a Q. 9 10 11 A. 12 Q. 13 14 A. 15 * 16 17 It 19 20 21 22 A. 23 done in 1989. 9S 1989? How were they informed? Is that what you previously told us? I don't want to go through chat. You hare previously cold us there were seme landowners. Yes. Is chat tbs extent of it? Other than chat, there were no other means done about the dredging chat was done there at Snow Creek in the 1980s? Newspaper articles. But you didn't have say coauuaity meetings, did you? No. 1 believe you previously told us you didn't have any in 1970, when y'all had those findings. Prankly, they didn't even make those findings available to you, did ebay, cha people in St. Louia? MR. PECK: Object to the form of the question. Could you be more specific with what you are ..king? REGIONAL REPORTING SERVICE. INC. 1 1 2 3 4 5 Q. 6 7 8 9 10 11 12 Q. 13 14 IS 16 17 18 A. 19 Q. 20 21 22 23 A. 94 (Plaintiffs' Exhibits Numbers Ten through Seventeen were offered and attached as exhibits hereto.) Now, Mr. Brown, what did y'all tell the coomunicy in -MR. PECK: Why don't we I know you don't like bathroom breaks, Mr. Stewart, but occasionally we need them. (A break was taken.) Do you recall, Mr. Brown, any meetings that y'all had where you arrived at any -- or stated any of your findings to members of the coonmity, either in Cobb Town, Sweet Valley, any part of that area out there in 1983? I do not remember a meeting. Do you know whether or not Monsanto informed those people who lived in that area in 1983? Is it your statement they did not? They were informed when the dredging was REGIONAL REPORTING SERVICE, INC. 1 Q. 2 3 4 S A. 6 7 8 Q. 9 10 A. 11 Q. 12 13 14 IS If 17 Q. 18 19 20 A. 21 22 Q. 23 96 You previously told us here today chat they didn'e cell you what their findings were, chat you didn't know what they were in 1970, '71? Yeah. X was working something else. j. didn't have any particular reason to -- And they didn't make those known to the public then either, did they? Not to my knowledge. So when Mr. Maymusky or Mr. Jones cams here aid they saw the information -MR. PECK: Xou are not calking about You don't want to know about newspaper articles? Did they report the findings in '71 and *72 in newspaper articles, as you racial, Mr. Brevn? I recollect some news articles. I don't remember specifically what was -- Did y'all disclose what the findings .are about PCBs? REGIONAL REPORTING SERVICE. INC. ADAD21-003724 HARTOLDMON0033680 1 A. 2 3 Q. 4 5 6 7 8 9 10 11 A. 12 13 14 Q. IS 16 17 A. 19 19 20 21 22 23 Q. 97 1 cia't remember specifically what vai there. Okay. What did you cell specifically Mr. Jonas, Robert Jones, who took over as the environmental person out here, or Mr. Jack Mayausky, when they both came to the plane? Let's take Mr. Jones first. What did you tell him about the history of the PCS problem at the Anniston plant? Well, you know, with Robert -- when Robert came in, the dredging had been completed. I'm not just talking about the dredging. I'm talking about the history of the problem, Mr. Brown. And he was responsible for coordinating the disposing, and he did chat. So far as history of the operations, we talked many times about history of operations of the facility as best I knew it. Mow, chat pertained to the whole plant. But what did you specifically tell him REGIONAL REPORTING SERVICE, INC. 1 Q. 2 A. 3 4 S 7 Q. 9 9 10 . 11 12 13 14 IS 14 17 18 19 20 A. 21 22 23 99 At the Anniston plant? Tea. And it didn't taka any brain surgeon then to figure out that out of a discharge point some -- that there were some PC8s. And that is the reason the plant was shut down. Tell me, Mr. Brown, if you can, if you and Mr. Jones discussed chat particular discharge point that you have indicated to us previously on Plaintiffs' Exhibit Bight is tbs -- I guess the sole source of these KSa that you found in Snow Creek. Xa that your position, and is that what you told Mr. Jones? sea if i understand it. I want to MR. PECK; object to the form of the guestion. aischaracterizes prior testimony. Well, I had no reason to tell him one way ox the other. But you know, that was my knowledge based on what the source of PCBs out of the plant was, was REGIONAL REPORTING SERVICE, INC. l 2 3 4 A. S 6 Q. 7 9 A. 9 10 11 12 13 14 q. IS 14 17 A. 19 q. 19 20 21 A. 22 23 98 .bout PCBe ul the problem, of -- potential PCS contamination of chat area out there adjacent to the plant? X don't resiember what I specifically cold him. Did you tell him anything, Mr. Brown. about it? Well, I went over this dredging protocol that we had been going through for three or four years, attempting to gee it approved and Because basically hs picked it up at that point and moved forward with it. so you talksd to Mr. Jones about what finding* y'all had made down there on Snow Creek; is that right? Tes. old y'all discuss in that conversation the source of the PCBs and where they came from? nr. Scesart, you tasov, it m kamm by everybody in the country chat PCBs were produced from 1929 or *30 to 1971. REGIONAL REPORTING SERVICE, ISC. 1 2 Q. 3 4 A. S q. c 7 A. 9 9 Q. 10 11 12 13 14 it 1 17 A. 19 Q. 19 A. 20 Q. 21 22 A. 23 100 discharge 001. And thac'a har you told bin on that occasion they came from? Tes. When he was involved in the dredging nf Snow Creek? Tes. MR. PECK: Object to Che form. Do you remember the previews document ve Introduced here today where you showed him --or you showed me a figure here of -- that '81 document where the ten thousand pounds -- or ten million pounds of PCBs were buried? Did you cell vim about chose landfills where the PCBa were buried? Tes. When he came on board? Tes. Old you cell him how much .as buried there? Probably not, because, you kno, I had forgotten about that particular REGIONAL REPORTING SERVICE, INC. ADAD21-003725 HARTOLDMON0033681 1 2 3 9. 4 5 4 7 0 A. 9 Q. 10 A. 11 Q. 12 13 A. 14 15 Q. 16 17 16 19 20 21 22 23 101 estimate, and z didn't know bow much was burled there. Did you tell Mr. Mayen*icy at any point in time about the testing that was - Mr. Jones, rather, at any point in time about the testing that other people had don* in '70. '71, and '727 No. You didn't tell him about that? No. Again, you didn't figure that was important cor him to know? Well, I didn't know enough about it to tell him anything of eubatance. Okay, weren't there some people who had taken over Papageorge's position and -- Who would it have been in '85 that would have been connected with Monsanto that would have known about that teeting in St. Louis? MR. PECK: Object to the form of the question, calls Cor speculation about what REGIONAL REPORTING SERVICE, INC. l 2 3 4 S A. c q. 7 A. 6 Q. 9 10 11 12 A. 13 Q. 14 15 A. 16 17 Q. 18 A. 19 Q. 20 21 A. 22 Q23 103 been the person who succeedsd Mr. Papagsorgs who handled the enviromental problems and in particular PCBs, if you know? Probably John Craddock. was ka around in '85? Tes. Did you all seek to find out fret* him in that particular period of time. Hr. Brown, what CMC results -- you and Mr. Jones, what test results - Mr. Jonss wasn't hers in *85. Well, whenever he earns. When did he come? Well, Craddock was gone by the time Jones came. Well, who took his place? I guess Bob Kaley. Did y'all calk Co Hr. Kaley about choee results? No. Did you ever ae any time talk to Mr. Papageorge during that period of REGIONAL REPORTING SERVICE, INC. 1 2 3 4 S 6 7 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 Q. 102 somebody else knew. MR. STEWART: That means you are not supposed to answer it? That i* not an objection that we have agreed to. Is chat seme signal you are giving him so that he doesn't answer the quaetion? MR. PECK: So. I object co che question because it can't be answered. He can't know what else thinks. if you that statement in court. I would stand up and make the same objection. I'm allowing you to straighten out your question if you listen to my objection. But if you don't wane co, thae'e your choice. That is what this is about. MS. STBKART: I understand. Thank you. Who in Monsanto in SC. Louis would have REGIONAL REPORTING SERVICE, INC. 104 1 2 A. 3 4 Q. 5 A. 6 7 q. time Mr. Jonss came in hers? Did X calk co Mr. Japagaorga- in Che else Mr. Jones was hers? Absolutely. No. I've not seen Bill Papageorge in fifteen years or more. Did you know at chat point in time chat 6 he was doing consulting work for 9 Monsanto on PCBs? 10 A. 11 Q. 12 13 14 i No. old you have any kind of understanding at that point in time -- Nell, withdraw that question end let me ask you. Can you tell us what you told ur, Mayausky when he came in the plant? 1C Did he talk to you about the hiecory of 17 PCBs and other wastes thae wars 18 19 A. discharged from this plant? No more than talking about the history ' 20 of ch* entire plane. 21 Q. Mbac specifically, if you racall, did 21 you call him about PCBs, Mr. Brown? 21 A. Z don't remember telling him anything REGIONAL REPORTING SERVICE, INC. ADAD21-003726 HARTOLDMON0033682 105 1 ocher chan the history of the plant. 2 Did you ever talk to him at any point in t*5iS auiAv vac*. M&yauSjiy was uere toouc 4 PCBs? 5 About the history of the plant, yes. 4 But I'm talking about specifically about 7 the - 8 The history of the manufacture of PCBs. 9 Did you tell Him anything about where 10 the waste was buried and how touch was 11 buried out there? 12 13 All right. Let me see if I understand 14 you. I'm trying hard to. 15 Tou didn't see any reason to tell 1 Mr. Mayausky about the fact that there 17 waa about ten million pounds of PCBs 18 buried in the southern landfill and this 19 weat end landfill? Tou didn't think he 20 needed to know that? mo ovnr. *-v._ 22 the question. 23 I had no reason to tell him that more REGIONAL ogpooTTBr SSSVIC2 INC. 1 2 3 4 5 8 7 8 9 10 11 12 13 14 IS 1C 17 18 19 I 20 21 22 23 107 levels. Of PCBs? Of PCBS. And than in 1985 y* all actually removed sediment from a part of Snow Creek and a tributary that led into Snow Creek, didn't you. with PCBs? Me did in '89. In '9 9. fine. But you started talking about it la '85. and the Attorney General raised some question about it? Tee. As a matter of fact, wouldn't that be enough. Mr. Brown, to make you. as the environmental person who was working here at Monsanto, want to cell Mr. Mayausky - I wasn't the environmental person. Nell, didn't he seek you out and aek you about the history of the plant and what -- He has indicated in his deposition that he did. MR. PECK: Object to the form of REGIONAL REPORTING SERVICE, INC. 1 2 3 4 Q. S < 7 8 9 10 A. 11 Q. 12 >. 13 Q. 14 15 1C A. 17 Q. 18 19 A. 20 2i q^ 22 A. 23 1G than any ocher tidbit of history that was associated. If the subject came up f=- sir,- -hy=a or esm -Hadn't y'all had a recurring problem with them? Tou had closed the plant down in the '70s, and you tasted at that time. They were even talking about a fish advisory at chat time, weren't they, Mr. Brown, in the '70s? Tea. About PCBs, right? Tes. And you had the problem in '83 with the dredging in Choccolocco Creek, didn't you? Isn't chat correct? The dredging in Qioccolocco Creek? Teah. T'all were involved in thae, and that involved PCBs, didn't it, in 1983? tf.ll, em did * casting protocol on Choocolocco Creek. For PCBs? In conjunction with the Soil Conservation Service that shoved low BBflTAlnr. OWOrtO'TTMrt QffOVTfTf INC. 1 2 3 4 A. 5 8 O. 7 8 9 10 11 12 13 14 1$ A. 14 17 Q. 18 A. 19 Q. 20 21 A. 22 23 Q. ioe the question. It is inconsistent with* Mr. Mayausky*s testimony. I discussed any history that there was a need to discuss. Okay. Nov, can you remember -- Let's go back to Plaintiffs' Exhibit Fifteen. Can you remember anything. Mr. Brown, about what the soil aanple levels were or the sediment levels were, the levels of PCS in the sediment that y* all took saaq>les of in 1993 in connection with the Conservation Department? This is the exhibit. The average was less than ten parts per million on the several miles of stream. The average wae lees than that? Tea. Mas thera anything above fifty at any point In time? No. My recollection is the highest was in the order of eighteen to twenty. Parts per million in the soil? REGIONAL REPORTING SERVICE, INC. ADAD21-003727 HARTOLDMON0033683 1 A. 2 Q. 3 4 S 6 7 A. a Q. 9 10 11 12 13 14 IS 16 17 it 19 20 21 22 Q. 23 , 109 Yea. Oo you know anything about any fish tests that were made by the Conservation Department or ceace in fish that vers made hy the Conservation Department at that particular point in time? No, I do not. Now, Mr. Brown, you have at some point in time in your previous deposition indicatsd -- Let me look at this before I get to the other. On page two pV4v,1/.I>im a# ^>19, ilMna^rlAfl __ MR. STEWART: Oo you have a copy of the depoeitioa? MR. PECK: X do. Thanks. MR. STEWART: It may not be two thirty-two. Wait just a minute. It may be somewhere else. I'm crying to find the page mnber. Maybe I wrote it down. Well, what I'm asking about -- And I'm trying to find the place so you can look REGIONAL REPORTING SERVICE, INC. 1 2 3 A. 4 Q. S 6 7 a 9 A. 10 11 12 13 14 Q. IS A. 16 17 ia 19 20 Q. 21 22 23 because it wasn't clear in my mind. Ill You indicated that there was -I think what I indicated to you was -- You were trying to remediate more than a PCB problem, is what you indicated to me last time In your deposition testimony. And I want to be sure I understood exactly what you ware talking about. Well, in all the studies that started in <79 and led on through the 'to* and into the < 90s, tbs only underground movement of any material involved organophosphat es. So that was -And have done several Brosrwu to remediate that, and the laat of which Involved the capping as part of this remediation effort that Alan Paust has been doing. I guess thst is whst I'm asking about now. MR. STEWART: And let me have marked here Plaintiffs' REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 4 7 9 10 11 12 13 A. 14 Q. IS 16 17 It 19 20 21 22 23 119 at it. It's not fair to aek you about it without giving it to you. You indicated whv work started on the southern landfill over there. And I gu. chat's whae I'm crying co find out about. You Indicated that there wae a reason other than PCBa. And I'm crying to - - That's the pare I'm trying to find. I thought I had it marked. Do you remember what that problem was, Mr. > other than the PCBs? When you say that work, I mean -- The remediation work that was done on the southern landfill that is being dons now by Alan Fauat. In response to my question last elms -- And I apologise to you Cor not being able to find it. I will keep looking and see if I can find it, if that doesn't refresh your recollection. But I thought you indicated to me last time -- I want to get it clarified. tswf-T/wsT onnPTTHn enirrn? tmp 1 2 Q. 3 4 $ 6 7 t Q. 9 10 11 12 13 A. 14 IS 14 q. 17 It 19 20 21 22 23 112 Exhibit Eighteen. And you had previously -- * MR. STEHART: How about marking that. {Plaintiffs' Exhibit Number Eighteen was marked for identification.) You had previously indicated, I believe. that there were certain celle that sulfur or phosphate, rather, were located. Can you tell us where they were? Mark it on that Exhibit Eighteen. It would have been here and this general area, these cells, and some went into this csll. (Indicating.) so a I to understand, Mr. Brown -- And it's your statement here. And I don't want to put words in your mouth. I just want to be clear about this -* all the capping that is being done on these cell* chac ara la what you called and had previously dssignated and marked wlcb llccla Xa on Plaintiffs' Exhibit REGIONAL REPORTING SERVICE, INC. ADAD21-003728 HARTOLDMON0033684 1 2 - A* 4 Q. S 6 7 a 9 10 11 12 13 A. 14 15 16 17 IS 19 Q. 20 21 22 23 A. 113 Eighteen era primarily in cha western sector of the landfill? Uh~hvih (indicating yes) . And all the capping that is done over there doesn* t have anything to do with the PCB problem; it has to do with the phosphate problem, the movement of phosphate underground? MR. PECK: Object to the form of the guestion. mischaracterizes his prior testimony. There are no PC3s at all in this section. It was the organophosphate movement in this general area here (indicating), and the capping is designed co totally shut off any water flow. So it doesn't have anything to do with PCBs, as you understand it, over there. Mr. Srown, in that western side, in these cells over there? That's my'understanding. SSQICnAl REPORTING SERVICE, INC. 1 2 3 4 5 6 Q. 7 A. a 9 Q. 10 11 12 13 A. 14 Q. is 14 17 IS 19 20 21 22 23 1 115 practices as near as possible to zero effect, it's put in place. And thac's very consistent with everything that has been dene in the operation within Monsanto that I know of. So all -- It's a matter of doing the best technology for final closure on that. So all the capping that is going on over there on the western seetor of And I assume -- Can I mark on this? Is this 202 hers? Tes. And then this would be the western, and Mtia K rh* <a all pSr' done on the western section over there of those cells or capping of those cells has nothing whatsoever to do with PCBs in your understanding? MX. PECK: Object to the form of the question, lack of foundation. MR. STEWART: Do you want to keep REGIONAL REPORTING SERVICE, INC. * 1 2 Q. 3 4 s 6 7 A. Q. 9 10 11 13 14 15 16 17 Q. 10 A. 19 Q. 20 A. 21 22 23 114 MR. PECK! Object co the fora. How many millions of dollars do you know are devoted to that ^articular oroblsm there? MR. PECK: Object co che form ot the question. Z have no idea. Now, what did you understand was the reason they chose to do that, Mr. Brown, In connection with those organophosphaces? Why is it that Monsanto chose to do that? Are they prohibited from affecting, say, ground water or the air or the soil ~~ MR. PECK: Object to the form of the question. -- under TOSCA? It has nothing to do with TOSCA. What does it have co do with? If you go bade co .hat ye broughc up earlier the Monsanto Pledoe, workincr toward a total zero effect, that is -- as technology develops to move past ngrrrnMRT. pgpfiPTTMQ SERVICE, INC. 1 2 3 4 A. 5 6 0. 7 A. 9 q. 10 11 12 13 14 is g, 14 17 A. 14 Q. 19 A. 20 Q. 21 22 23 116 your witness -- MR. PECK: I 3>4STi, ha* s not the witness who knows about this. Z know of no reason to do it, other than che organophosphatee. Thank you. There may be something. I don't know. I*m giving you my best answer. All right. Where are the PCBs? I want you to point those out again for us on chi. exhibit (indicating), Plaintiff.' Exhibit Eighteen. MR. PECKi Do you mean where they are buried? Where chav are buried, based on your understanding. (Indicating). And is that in cell 2-B and 3-B? That's correct. And it*s my understanding -- Let me just ask you. Were these capped too, those two landfills capped in this latest remediation effort Chat began in the REGIONAL REPORTING SERVICE, INC. ADAD21-003729 HARTOLDMON0033685 1 2 A. 3 Q. 4 A. S Q. 6 7 A. 8 Q. 9 10 11 A. 12 13 14 15 16 17 18 Q. 19 20 21 22 23 early '90s? 117 Probably so. Do you know whether cbwy war* or not? Specifically, I don't know. Hera they a part of Alan Faust's work that ha' a doing out thera now? r--, yes. So he capped those two landfill* too. MR. PECK: Object to the form of the question -- You can ask him that. I don't know. MR. PECK: You need to let me nuke the objections, Jerry. Object to the fora of the question, lack of foundation. You can now answer. Lee me ask you chis, Mr. Brown: Do you remember seeing any capping of those two cells in your observation of the remediation site? MR. PECK: Dona by Alan Pause? MR. STEMART: Tee. REGIONAL REPORTING SERVICE, INC. 1 Q. 2 3 4 5 6 7 8 9 10 . 11 12 A. 13 Q. 14 A. 15 Q. 1 A. 17 Q. 18 A. 19 Q, 20 21 22 23 119 And maybe I misunderstood. I read over it again, and I cried to get it down. Mr. Brown. But 1 understood Chat parathion material was placed in Bmsile, that y'all couldn't put it in ens of these cells because you couldn't do that under the regulations. If I misunderstood, then I apologize to you. MR. PECK* Back whan 202 was put in, you lira talking about? MR. STEMART; Yes. You said put in Baelle? Yes. Baelle didn't even exist then. So y'all put it in your own facility? Yes. And y'all had the right to do that? Sure, we did. okay. And I want you to clarify this for me. Why is it that you couldn't put PCBs that you slight haws dug up at some point in time in Alan Faust's remediation in any of these landfills, REGIONAL REPORTING SERVICE, INC. 118 1 l A. 2 Q. 3 4 A. S 4 Q. 7 A. 8 Q. 9 A. 10 11 12 13 q. 14 A. 15 q. 14 17 18 A. 19 Q. 20 A. 21 g. 22 23 A. I think so. During CDs time that Alan wae working out there? I Chink ie haw all bawn capped, except those two. And thoae two you are referring to -4*8 and S~B. What's in chose? Ae discuaaed before in -S. primarily the relocation from Highway 202, parathion wests, and debrie from demolition of the parathion operation. in those two cells? Yes. Now, which ones of the cells that you had indicated prewiouely went out into 202? Can you mark that on thara? 1-W. can you mark where it went? It went something like eo {indicating) . And it's your statement previously that all of that was taken out? Yes. REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 A. s 7 8 Q. 9 10 11 12 13 A. 14 is 18 Q. 17 18 A. 19 20 21 22 Q. 21 120 solid waste management units? HR. PECK; Object to the form of the question, lack of foundation of this witness. Are you referring to the residue that we pulled out of the tributary of Snow Creek? Or any that you might have pulled out of ths west end landfill. MR. pscKt Object to the form of the question, lack of foundation. X can answer specifically to the residue of Snow Creek, the tributary of Snow Creek* The other part I cannot answer. Hell, tell me about the tributary to Snow creek* He picked it up in one area. He mowed it to another area. He analyzed it to see what we had and then disposed of it accordingly. Hell, you had to diepoee of it at Emelle because it bad a certain level of PCBs REGIONAL REPORTING SERVICE, INC. ADAD21 -003730 HARTOLDMON0033686 1 2 i Av 4 Q. S 6 A. 7 Q. 9 9 10 11 12 A. 13 Q. 14 IS 16 17 19 A. 19 20 21 A. 22 22 121 ia ic tint vers wine you would call actionable] ie that correct? Tee. What did you understand chat to be, over fifty part* par million? Tee. So you had to move that to Email#? If something va three percent PCBe, that would certainly be more than fifty parts per million, wouldn't it. Mr. Brown? Tee. If you found that in the 1990a, are you Baying that the regulations changed that would allow you or Monsanto Chemical Company to bury that in your own landfill? No. MR. PECK; Object to the form of che question. Go ahead. What I'm saying is there is regulatory guidance and interpretation on actual ratroval and generation of wasta or REGIONAL REPORTING SERVICE, INC. 1 2 Q- 3 4 S S 7 a 9 10 11 12 13 14 15 16 A. 17 ia Q. 19 20 21 22 A. 23 not Know. 123 OJcay. But if you -- Tour statement to me last time was that these -- I remember this, I think, fairly clearly. If I misspeak, you correct me. But these landfills that y' all had permitted, you weren't allowed to put in these, in che western landfill. substances that you found such as P8s that you found out hers that had what you would call actionable levels, over fifty parts per million in che soil. Tou couldn't take that and put it in these cells where the PCS* were previously dumped? We could noe import waste into here and bury it, no. Okay. And I'm going to put PCBa here and then parathion here. That's my healwriting. And thia is what, phosphates? Well, it was sulfur and organophosphaces. REGIONAL REPORTING SERVICE, INC. 1 2 2. 4 S 6 7 a 9 10 11 12 13 A. 14 15 16 a. 17 IS 19 20 21 X, 22 23 122 simply capping in place. That's two different things. I thought you indicated to us previously -- I want to be sure I understand you, Mr. Brown -* that if y'all dug it up -- not if you found it In place; but it you dug it up, then you had to move it to fissile, which is vhsc you did on the west end landfill, just like you did a portion of that, Ju,c like you did tha atutf that you found In Snow Creek, in that sediment down there. I don't know what was done on the west landfill. But I know what was done on Snow Creek. I was involved in that. Becauaa you followed tha regulation. there? MR. PECK; Because he did what? MR. STSHART: Followed the regulations. Because I was involved *nrf knew what was going on. I do not know -- I was not involved in the west end landfill and do j REGIONAL REPORTING SERVICE, INC. . 1 Q. 2 3 4 5 6 7 a 9 10 11 A. 12 Q. A, 14 is o. 19 17 A. IS Q. 19 20 21 23 23 ' 124 Sulfur and organophosphaces. Now, Mr. Brown, let me ask you to take a look at another map, if you can. Well, maybe w already have ic hero. It', Plaintiff,' Exhibit Eight. Tell me, if you can There is a section marked off here which i> east of the. plant, which looks like a remediation area. Where did y'all have pCBs chat were buried in that area? I don't too. of tarrying PCT, anyplace. Sir? I do not know of burying PCBs anyplace in that araa. To your knowledge there are none buried in that area? Hot that I'm aware of. Mould that be againat th lav. to bury than ia chat ana, Mr. Brown? I mean. ie then a regulated eolid vaata unit that ia permitted and owned by Monsanto in any part of thia area here chat ia marked with a dark line around it. REGIONAL REPORTING SERVICE, INC. ADAD21 -003731 HARTOLDMON0033687 1 2 3 4 S A. 6 7 Q. 8 9 10 11 A. 12 13 Q. 14 15 IS A. 17 Q. 18 A. 19 20 21 22 23 Q. Mr. Brown? MR. PECK: 12S Object to Che fora of foundation. Tou cannot import vaete for disposal purposes in Chat area. Hell, is it your statement to me today. then, the reverse of that is true, that you can just leave it there if it's there? That'a acmething that's up to the rurtiil arnra Well, wouldn't you hare to report it to the regulators if you found it. Mr. Brown? That is normally the case. Well, aren't you required to? Tou know, when you aek me are you required to, I cry to think of a specific eec of regulations chat reoui rea rhar nr vnu Irnnn mir nrjff *-<* is to report everything that we find. Didn't you do that? REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 6 Q. 7 8 9 10 11 12 13 a. 14 Q. 15 A. 16 Q. 17 A. 18 19 20 21 22 23 . 127 public health department. MR. STEMART: Mark that, please. (Plaintiffs' Exhibit Number Nineteen was marked for identification.) I'd ask you to identify that. It's a letter dated February the 7th, 1980, to Darrell Baker. Do you remember sending that letter to Mr. Baker in February on February 7th of 1980, that is identified ae Plaintiff*' Exhibit Nineteen? Okay. Do you remember sending that letter? Well, frankly, no. But I remember -Is that your signature? I remember the deealls of It, after I read it. MR. STEWART: We'd offer that. - (Plaintiffs' Exhibit Number Nineteen was offered and attached as an exhibit hereto.) REGIONAL REPORTING SERVICE, INC. s 1 A. 2 Q. 3 a.. 4 q. S 6 7 8 A. 9 10 Q. 11 12 A, 13 0. 14 15 16 A. 17 18 19 Q. 20 21 22 23 126 Pardon me? Didn't you do chat? Tee. Aid if you had found parathion on the right-of-way outside the landfill area of 202, you would have had to report chat coo, wouldn't you, Mr. Brown? Have to by -- I mean, it would be our practice to report it. It certainly wouldn't be your practice to hide it, would it, Mr. Brown? No, And that is because of regulations as well as y'all's practice, isn't it. Mr. Brown? Well, that's generally the two things that set standards like that for chat. yes. Now, Mr. Brown, there are a couple of documents I wane you to identify, if you would. Thera is a document that you sent. It's just a follow-up document that you sent to Mr. Baker with the BROTQtiAL REPORTING SERVICE, INC. l q. 2 3 4 5 6 7 8 A. 9 Q. 10 11 12 13 14 IS 16 A. 17 18 Q. 19 A. 20 21 Q. 22 A. 23 128 Now, Mr. Brown, I want you to cake a look at a document dated April the 27ch. MR. STEMART: Let me have chat marked. (Plaineiffa' Exhibit Number Twenty was marked for identification.) Old you have a question on this one? No. I just wanted you to identify it. Take a look at chat. It's to J. L. Brown. It's from, I assume, a Mr. Gene L. Arnett, and there is a copy sent to Mr. Cheever. And I want to ask you if you ordered this test and what was the purpose of the test. Okay. Tour first question, did I order the eest? Right. Tfcia aa, again, datelopisg cactmology. Okay? Uh-huh (indicating yes). When pipelines, vessels vers pulled out of the parathion operation and were REGIONAL REPORTING SERVICE, INC. ADAD21-003732 HARTOLDMON0033688 I 2 3 Q. 4 A. S Q6 A. 7 Q. 9 A. 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 129 contaminated, they either had to be disposed of as contaminated waste -- Where would you have disposed of then? At Smells, in this period of time. In 1984 -In '64, some of it's still on-site. How was that? What could hare been disposed of on-sice? Well, if ~ Just as an example, if that cup was used in che parathios operation and for some reason it had to be taken out of service and it still had some surface contamination, just like that cup has got surface contamination of coffee on it -- To get that coffee off. you put it in the dishwasher. To get parachion off that surface -- If you don't get it off, it had to be disposed of as hazardous waste. If you do get it off, it becomee detoxified and goes into --it could be melted down for scrap. This was a test to use this technology for cleaning the surface of the metal REGIONAL REPORTING SERVICE, INC. 1 Q. 2 A. 3 Q. 4 S A. ' 8 9 10 11 Q. 12 13 14 IS 16 17 18 A. 19 20 21 Q. 22 23 A. 131 And did it work? Sure, it worked. And what did you do with the metal after you put it through thie detoxification process? It was tested, i^nd when suitably detoxified and you determined that the detoxification had work, it could be melted down and recycled as metal scrap then. Did you understand that Monsanto at that point in time, Mr. Brown, had a preference as to what you did, which is this process here, this detoxification process? Was that a preferential process with the waste water or with the parachion equipment or whatever? Well, when it would work, yes. I mean. there are times when chemically it just won't work. It's just -When chemically it would, that was the preferred method; is that right? In this case, we had organisms that REGIONAL REPORTING SERVICE, INC. l 2 Q. 3 A. 4 Q. S A. 6 Q. 7 9 A. 10 Q. 11 12 13 A. 14 IS 16 Q. 17 18 A. 19 20 21 22 Q. 23 A. 130 parts. That were used? That were used in parathicaa service. Manufacture? Yes. And *o y'all talked abouc the feasibility of a biological detoxification process here? That's correct. Why is it that you chose to take a look ac the biological, detoxification process? Well, we had a biological waste treatment facility there for treating waste water. And you wanted to see if this would work? And this concept wae to simply put these pieces of pipe or whatever down into the biological basins and let it become detoxified. And did you do that? Yes. REGIONAL REPORTING SERVICE, INC. 1 2 q. 3 4 S A. 4 o, 7 8 9 10 11 Q. 12 13 14 IS 16 A. 17 Q. 18 19 20 A. 21 0. 22 A. 23 q. 132 would eat the parathion waste. When chemically okay, that was the preferred process, to detoxify it in che manner in which you are calking ibwc? Yes. All right. Are you familiar with a document - (Plaintiffs* Bxhlbie Nu&ber Twenty-one was marked for ldanclfication.> Let me show you a document. Plaintiffs' Exhibit Twenty-one. Are you Cmalliar with this document here, Mr. Brown? It appears to have been prepared by Mr. E. L. dxeever in November of 1984. Tee, I remember chie. And did you aaaiat -- It aaya *.taff* on that. Did you aaaiat in preparing that document? Mo, I did noc. You did not? No. Were you working ae a member of the REGIONAL REPORTING SERVICE, INC. ADAD21-003733 HARTOLDMON0033689 1 2 A. 3 g. 4 A. 5 6 7 Q. 0 A. 9 Q, 10 11 12 A. 13 14 IS 15 17 18 019 20 21 22 A. 23 Anniston staff on that dace? 133 7a. Do you know who did prepare that? To a large degree, the training staff in conjunction with the environmental specialist. The training staff? Tee. who were the training staff? Where would they cone out of? Would they coots out of -- I don't remember who epecifically would have been working on training in 1984, but training ie an ongoing part of the operation. 1 mean, it' e -- And this ie singly an internal training procedure for our employees. And Mr. Brown, when you say training staff, is that staff that is located here as opposed to somebody who came out of St. Louie? Tee. But see, this consultant, MIS, was a consultant who assisted in putting REGIONAL REPORTING SERVICE, INC. 1 Q. 2 3 A. 4 S Q. A. 7 8 Q. 9 A. 10 Q. 11 12 13 14 IS 15 17 18 19 A. 20 21 22 ZJ 13S Or who might have been involved just as an operator or anybody? Primarily the operators, the plant operators. Okay. And before I mean, try to train them on what is a waste, how to handle it. What to do with it? Just normal training procedures. Before this document wae prepared -- And I chink this is 1941. And there is a revision in November of *84. I sort of misspoke. Before this document was prepared, when did -- What did y'all follow in connection with the disposal of waste hers at the plant itself? Was there a document that preceded this? l' sure there was. Tou know. specifically it wae not called MTS document. It was a predecessor kind of document. But normally it's written as part of operating instructions. REGIONAL REPORTING SERVICE. INC. 1 1 2 3 24 S 7 8 A. 9 10 Q. 11 12 13 14 IS A. 1C 17 Q. 18 19 A. 20 21 22 Q. 23 A. 134 together the format of training procedures. okay. And did this becose a part of y'all's policy there, this hazardous waste management -- Wee this something that was a policy that was followed by y'all as to how to -Well, this wae part of the training procedures for employees. What I'm asking you is did this remain a part of your documents that you followed as far as policy was concerned hare at the Anni.coa plane afear it eas prepared by Mr. Cheever in November of 19847 Yeah. This is ths document that was used for this at this point in time. Who participated in Che training. Mr. Brown? Nell, any eegjloyee chat nl involved ... trained. I mean, that is normal procedure. Involved in doing away with waate? Well - REGIONAL REPORTING SERVICE, INC. .1 1 Q. 2 3 4 S A. 5 g. 7 8 9 10 11 12 A. 13 14 g. IS A. 1C 17 18 Q. 19 20 21 22 A. 23 g. 13C So there wae something that did exist before December o 1381 as Co c-hac y'ali should do in connection with the removal of waste or the disposal of wasts? Tes. avvi if you will look at page thirteen of this dociaaent, would Chat document have as part of it on-site methods of hazardous waste management? Do you. recall chac being a pare of char aarlier document? I can't epecifically anaeer ho* that ae set up. Well -I mean, it was normally written as part of operating Instructions for the department. tad what about containere? Cm page fifteen there is a Containsrs end Label ing." Do you renumber chat as being part of the -- Aa pare at hae? chac earlier document? REGIONAL REPORTING SERVICE. INC. ADAD21-003734 HARTOLDMON0033690 1 A. 2 3 4 5 6 7 Q. 6 9 10 A. 11 13 14 IS 1 17 19 19 20 A. 21 22 23 Q. Wall, when you say that earlier 137 document, we are really talking about E?uiubiva vj uwwuiueube. Z TM*rii if an ongoing chain all the time, being updated every year. He update documents and proceduree every year. Did y'all have a containers and labeling portion ot your operating inetructione - * I'm aeeuming eo. 1 don't remember specifical ly. .. . ... -- there ie a deal that says, "Treatment of Haxaxdoue Wastes," which telle you what ycu did with' vaete treatment. Tou take care of it biologically or how you claae It and those kinds of things. Do you remember the previous document containing aome of those things? The documents were routinely updated. you know, to the regulations iu place at the time, so yee. And then it talks on page eighteen and KSGICnAL REPORTING S&kVICS , INC. 1 Q. 2 3 A. 4 Q. 5 A. S 0. 7 4 A. 9 Q. 10 11 A. 12 13 Q. 14 IS A. IS Q. 17 A. It Q. 19 20 21 22 23 Who was responsible for doing that. Mr. Brown? In the '70s? Tee. 139 . Bill Taffee. And who did ha report to if he found any problem areas that might exist? Well, in the later '70s, to me. And after you left, who would he have reported to? He retired, end Bob Cbeever took the responsibility. Who would Bob Chsever have reported to. directly to you? Initially to And then to Mr. The plant manager. Okay. What testing, if any, was done during that period of time, prior to 1941, if you recall, of the landfill * area, either the water that came off the landfill or air tests or samples or things like that, soil samples? REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 < A. 7 Q. S 9 10 11 A. ,^ ** 13 14 15 ie A. 17 IS 19 20 21 0. 22 23 A. 13% nineteen about inspections and records. were those requirements in place before this document was put together, either in operating inetructione or another document that this replaced? In different forms, yes. How -Taka a look at tha area over there where it says "Landfill," and read that, if you would; not out loud, just to youreelf. Okay. understood those conditions to apply to ths landfill prior to the time this document wae put together in 1981. The landfill wae routinely inspected. from my personal knowledge, back into the early '70s. How, was it dona according to this specific routine. probably not to this specific routine. Sue it was doas on a regular basis before then? Tes. kSSICSAL urCKTIuG SERVICE, INC- 1 A. 2 3 4 Q. 5 C 7 A. S 9 Q. 10 11 12 13 A. 14 is o, IS A. 17 IS Q, 19 A. 20 21 Q. 22 A, 23 14 0 Well, we were routinely doing testing. 1 mean, we had catchment basins that we collscted storm water runoff in. Would that have been off the southern landfill, the landfill that we call the aouth landfill? Yeah. We had basiae to catch storm water, those were routinely tested. Now, tell me if during the time frame you are talking about, between the early part of the '70s up to 1941, did y'all tssc for PCBs? Well, in the '79 era we started the extensive boring program. Where did you bore? All over the place, all over the landfill. All over the landfill? And same of those coree were tested for PCBs, down gradient of 2-K and 3-8. Mho did chat c.sting? Gosh, the consultant at that point in time was Garricy and Miller. REGIONAL REPORTING SERVICE, INC. ADAD21-003735 HARTOLDMON0033691 1 Q. 2 - A. 4 Q. S 6 A. 7 8 9 Q. 10 A. 11 Q. 12 13 A. 14 IS 16 017 16 19 20 A. 21 22 23 And did y'all find any evidence dovn gradient of pea contamination? no, we did not. 141 And who were those teats provided to, to you? Well, they were provided to whoever vaa involved at the time, me and other people, yeah. Okay. And to the plant manager? Tee. And who vaa the plant manager at that time, if you recall? Let me think. I can see his face. I just can't -- Ben Boyen left in about '60, and Ed Jurevie came on board. Tell me, if you would, Mr. Brown, if you recall why y'all decided at that particular point in time to teet for PCBa. We were doing boring and looking for underground movement -- MR. PECK: Tou didn't take any of mine, did you? REGIONAL REPORTING SERVICE, INC. 1 Q. 2 3 4 A. S 7 Q. a A. 9 Q. 10 A. 11 Q. 12 A. 13 Q. 14 15 16 17 16 19 20 21 22 23 143 Old you ever assess any kind of surface runoff of the landfill during chat period of time? We were assessing the containment -- storm water containment basins that I msacionad earlier, yea. And you found no PCBs in that? We did not analyte chose for PCBs. So you didn't analyze those for PCBs? No. Just the core samples? Yes. All right. Let me ask you something. Mr. Brown. Tou* re in this plant from day to day and served as this environmental person out there. Tou were familiar enough with the vaacarn landfill to tell us sons things last time about It. Let me have chi. marked as Plaintiffs* Exhibit Twenty-two and ask you to tell ms somsthing. (Plaintiffs* Exhibit Nisnber Twenty-two was marked for REGIONAL REPORTING SERVICE, INC. l 2 3 4 5 6 7 Q. 6 A. 9 10 11 12 13 14 IS 16 Q. 17 16 A. 19 20 21 22 23 142 MR. STEWART* I don't think so. I brought all of mine in here. Are any one of cbeee yoursv That ie all I took off. I don't think it is. MR. PECK* No. Thanks. Tou were telling me why y'all did chat. Teah. We were doing assessment studies of any movement that may have occurred underground. And one question that we were assessing is whether or not there had been any underground movement of PCBs away from cells 2-B and 3-E. The borings closest to chose cells were tested for PCBs, and none were found. Any other form of testing you did other chan the borings? Well, that is what we -- Well, the borings and ground water is what we were looking at at that point in time. And the cores were -- There was so litcle water in those streams thac the cores were typically what we - - REGIONAL REPORTING SERVICE, INC. 1 2 Q. 3 4 S A. 6 7 Q. 6 A. 9 Q. 10 11 A. 12 13 Q. 14 A. IS Q. 16 A. 17 Q. 16 19 20 21 A. 22 Q. 23 A. 144 identification.) Is there a discharge point off the western -- the vest and landfill, not western, the weet end landfill? well, there is obviously storm vatsr that runs off of anyplace. And where does it go? It flows to the north. can you draw a line and show me where tbit flow co eba north, Mr. Broun? I think It's in a ditch along here (indicating). A ditch along where? Along -- I -There is a little dotted line -- I chink it'a along hara. I don't knoa. There is a little dotted line that runs down through there, Mr. Brown, all the way down through there to the railroad. le that the ditch you are talking about? I'm really not sure of the rcuta of it. Well, doee it go to the railroad? Tee. REGIONAL REPORTING SERVICE, INC. ADAD21-003736 HARTOLDMON0033692 1 Q. 2 i A. 4 QS 6 7 a A. 9 10 11 Q. 13 A. 14 Q. IS A. IS Q. 17 A. 1ft 19 Au Does it ultimately wind up in Snow Creek? 145 I6i. Noe, y*all found a eubecantial amount of PCBft on the top surface of that landfill in sort of a tarry form, did you not, at the time that this came up in 1993? Nell, I wasn't directly involved, but it'a my understanding, in areas that had been cut away by the switchyard, that eome was discovered. And when was the switchyard put in? I don't taow. Waa it in the '90s or -- Before then. In the rft0a? It waa put in and expanded. I'm not ure of when they did that expansion type work. mu you tenwabsr whether it was put in. 22 A. 23 Q- All I can tell you is che '70, *ft0 era. And that's the Alabama Power Company RSGICnnL REPORTING SERVICE, INC. 1 2 A. 3 Q. 4 A. S Q. 6 A. 7 ft Q- 9 A. 10 Q. 11 A. 12 Q. 13 14 IS 1ft 17 1ft A. 19 Q. 20 21 22 23 railroad track? Tea. 147 When did you do that? The early '40a. Why? Part of the overall assessment program that we have previously mentioned. Checking the ground water? Well, yes, uh-huh. Did you check it for PCSa, Mr. Brown? No. Do you ever remember being talked to by anybody from ADEN about some probin that might exist, Mr. Brown, as far as around water is concerned, for PCS contamination at any point in time in the '70s and the 'ft0? I do not recollect anything. Well, Mr. Brown, have y'all bought or purchased a piece of property that would be north of the railroad tracks over there because of PCS contamination? Tou have, haven't you? REGIONAL REPORTING SERVICE, INC. 1 2 3 4 A. S ft Q. 7 ft 9 10 11 12 A. 13 14 Q. 15 A. 1 Q. 17 IB 19 20 m ** 22 Q. 23 146 switchyard that is listed here on Plaintiff,' Exhibit Twenty-two ae 230 KJ Switchyard, in that little box there? Yeah. It was a small switchyard and axpandad somawhere along chiring -And it's your understanding chat this landfill, tha surface water of this landfill, goes down into a ditch. Is that also viewed as a discharge point off the plant of some effluent? It comes off a landfill, doesn't it? That wasn't part of the plant during that period of time. It wasn't? No. Did y'all ever test that at all. Mr. Brown, in any of the teste that you calked about chat might have been performed In che '70s or tha '60s that you knew about? Did you ever test that? ,, Did you ever put any wells in place across the railroad track, north of the REGIONAL REPORTING SERVICE, INC. 1 A. 2 3 Q. 4 A. 5 Q. ft A. 7 Q. ft A. 9 10 Q. 11 12 13 14 15 1< 17 1ft 19 20 A. 21 Q. 22 23 14$ In what era? Aa part of this remediation? " In the '90s. Ae part of this remediation? Tee. Mv uMarTanH <tw; M have = Isn't that because of PCB contamination? That's my understanding, but I have not been involved in that at all. Is the first time y'all have dona anything about that or calked to tha neighbors chat alight have been affected either to tha weat or to tha north of tha waat end landfill -- Was that in tha v* i i didbn* c talk to ssy of the neighbors en the western side of tha plant or tha northern side of the plant before that time about the possible PCB contamination, did you? NO. And you didn't do any testing over there until tha powar ecstasy reported the preeanca of PCBe in '93; la that not REGIONAL REPORTING SERVICE, INC. ADAD21 -003737 HARTOLDMON0033693 1 2 A. 3 Q. 4 S 6 7 8 A. 9 10 Q. 11 A. 12 N 13 14 A. 15 16 17 18 Q. 19 20 21 22 Q23 A. correct? 149 That'* what I guess, yes. Well, wasn't there somebody out there sc che plane, Mr. Brown, who was familiar with che face chac there was a fairly substantial amount of PCBs buried in che west end landfill? Tcu say was there somebody at che plant that -- Tea. I don't know. I mean, I did not know. tv uau IMJ 1UG >UCU JTWU NCLS UEU environmental -- or che chief chemist -- I was cold that chat was a previous disposal area chat was transferred to che power company back in the early '60e, late 'S0e, somewhere along there. Were you ever cold at any point in time. Mr. Brown, what was buried there? MR. PECK: Wait a minute. Can you let him answer? Okay. Go ahead. I assume, then, that it contained regional reporting SERVICE, INC. 1 2 Q. 3 4 S A. 6 7 0. 8 9 A. 10 Q. 11 12 A. 13 Q. 14 IS 17 18 19 20 A. 21 Q. 22 A. 23 Q. that he had conducted. isi And how much did be say wae buried there, based on those interviews that be conducted? ' 1 don't know -- He didn't tell me a auinrlev, What wae the nature of che waste that was buried chore, if you know -- I don't know. -- based on your conversations with Mr. Jones? 1 don't know. How, Mr. Brown, do you know -- during the time that you were there, did you t0 .. (f conjunction with Monsanto and anybody else before 1993 for PCB contamination in well wacer that wae off-site, oft the Monsanto site? Not that I'm -- Tou say well water? Absolutely, well wacer, not city wacer. Monitoring well wacer? Tes. REGIONAL REPORTING SERVICE. INC. i 1 2 3 q. 4 S A. 4 Q. 7 8 9 A. 10 11 12 Q. 13 A. 14 Q. 15 A. 16 17 it Q. 19 20 21 A. 22 Q. 23 A. repreeeatative waete of the plant ISO operations during that era of time. Did you assume that rui were buried there? Tee. What ocher kind of toxic waste did you understand was buried in the west end landfill, Mr. Brown? Nell, the plant produced phosphates for many, many years. I assumed slag from that operation was buried there. N&s located there? Ub-huh (indicating yes). What elae? ted X assumed that perhaps seme amall amount of parathion waste might have been buried there. Did you later learn that there was same small amount of parathion waste buried in the west end landfill, Mr. Brown? I was told that. Mho told you that? Robert Janes, based on same interviews REGIONAL REPORTING SERVICE, INC. 1 A. 2 3 4 S Q. c 7 9 10 A. 11 12 Q. 13 A* 14 Q. 16 17 18 19 20 A. 21 Q. 22 A. 23 . 152 I'm assuming that in all thoae very wide scans that were dona on the deep wells that that included PCBs, but I don't remember che specific details. When you say the wide scan of the wells, wells chat y'all had located north of che west end landfill and over there in that open field north of -- Nall, char. ware aavaral deep valla. deep monitoring wells. That y'all put in different places? Tes. . Where were they located, Mr. Brown? ...... 1,V'* "**w" **" ****** Iw" >(u4 1-1 Can wells to have been located either on your property or south of the railroad or on your property north of the railroad? 1*11 give you my best stab. Give it to me. Thar* la ona locacad rigbc In this araa (indicating). ' REGIONAL REPORTING SERVICE, INC. ADAD21-003738 HARTOLDMON0033694 1 Q. 2 2 4 A. S 6 Q. 7 ft 9 10 11 13 14 IS A. IS 17 Q. 1ft A. 19 20 Q. 21 A. 22 23 Q. 153 How about juat making it with a circle. *nd we will know chat'a a well. Mr. Sirova. All right. You know, it's -- I think it's right in here, taut I'm not -Okay. I'm going to put a little arrow out Cram that, and w will put M well. Where are the next one*, iC you know? MR. PECK: You are talking about welle that were put in in the ? THE WITNESS: Yeah, Che deep wells. And let's see. Let me get ray orientation now. All right. That's the railroad? Right, sir, yeah. There ia a couple back up in here (indicating) . Mark them on there, Mr. Brown. Well, one of them would he (indicating) -- Well, put a little arrow and send it on REGIONAL REPORTING SERVICE, INC. 1 Q. 2 A. 3 Q. 4 s ft 7 9 A. 9 Q. 10 A. 11 Q. 12 13 14 A. IS Q. 17 A. 1ft 19 20 21 22 Q. 23 A. 1S5 -- from the west end landfill? No. It's from the operations. Well, whet did you do -- If this was from operations, what did you do to monitor the waste you had buried in the west end landfill? Kow was it cowered up? Was it capped? It was back when it was closed, yes. When was chat? '50s. So it was closed in the '50s, and y'all didn*t monitor it at all after it was closed? ' Not until the fact that the cap bad been i,. i . i . j, ^ By the power company? Right. And that was not our property anymore. So the only time I was aver on tAe proparcy iu to taka -- I ebink Ala name was -- Darrell Baker up there as part of that assessment chat was done. Well -And we took him up there and walked it REGIONAL REPORTING SERVICE, INC. -1 1 2 3 4 A. S Q. ft A. 7 q. 9 10 11 12 a. 13 14 Q. 15 A. 1ft Q. 17 ie A. 19 Q. 20 21 22 23 A. off there. 154 I don't have any more page there. I'm doing the best I can with what have there. There are a couple in that area. Okay. Where else are they? On the deep wells, that's what I remember. Do you have any monitoring wells -- I believe you indicated previously you had some monitoring wells that were north of the railroad, in a field over there? xeah. We okt* omuiLuriog welle along here (indicating). North of the railroad? Tee. What were you monitoring? Can you put M wells for those, Mr. -- (Executed by Che witness.) Mf, that's fins. What were you monitoring for there? Is that again ground water contamination -- Yes. REGIONAL REPORTING SERVICE, INC. 1 2 3 Q. 4 5 A. & 7 ft Q. 9 A. 10 Q. 11 12 13 14 A. ** 16 Q. 17 It A. 19 20 21 q. 22 23 156 and showed him that this is that area. that old area. ' When the health department came in, Mr. Baker came in back In the 'sos? Solid waste was doing that assesement before. The 19S1 document? * SO, somewhere ia the early '60s, yeah. So when y'all went on the property at that point in time, y'all knew that that was one of your solid waste dumps as early as 1941; is chat correct? Well, we knew it from history all the WX klUWJMW . Do you remember a guy named Jerry Cheatwood? Hall. X know a J.rry chaatirood vary all, but I don't tAink it'a anybody you are referring to. Do you remember a regulator named Cheatwood who came from ADGM and diccusaed soma problem, icA you in the REGIONAL REPORTING SERVICE, INC. ADAD21-003739 HARTOLDMON0033695 i 2 A. 3 4 QS A. 7 a 9 Q. IQ 11 A. 13 V* 014 15 16 A. 17 18 Q. 19 20 A. 21 V 22 23 157 '8 0s? It seems like the name is -vaguely familix, but 1 cure recollect him. Do you remember PCS* being discussed at that time, Mr. Brown? Well, we -- You say at that time. We discussed PCBs anytime the question arose. Do you remember specifically discussing it with Mr. Cheatwood in the '60s? No. I can't -- I can't be -- I can't draw a bee to Mr. Cheatvocd, maybe. Ar** you familiar with any kind of work that y'all had done with the United Defeaae or FHC? I don't remember doing anything with them. Do you know or have you ever had any knowledge that they had a well? Tee. Ana do you 1U10W another Or not y an nu at any point in time informed United Defense or FMC that y'all had found REGIONAL REPORTING SERVICE, INC. 1 2 3 4 5 g 7 a 9 10 11 12 13 14 l< 16 17 16 A. 19 Q. 20 A. 21 Q. 22 23 IS 9 articles here -- that several monitoring wells near PCB sites on the Monsanto property do show concentrations of chemical greater than five parts per billion, ADD*'a drinking water standard. Tt* ngy rhif thif comes from The Anniston Star. And I will say without question, Mr. Brown, that that could or could not be true. So we will take it with that little caveat. But do you recall -- I mean, this is apparently a reporter who seems to have asked somebody at your company whether or net y'all found it. ! Just want to know if you know anything about that. And 1 just answered I did not. You don't have any idea? No. Well, they talk about deep monitoring wells. Would those be the wells that you have located for us hers? To your REGIONAL REPORTING SERVICE. INC. 1 2 3 4 5 6 7 4 9 10 A. 11 12 Q. 13 14 15 16 17 16 A. 19 20 Q. 21 A. 22 Q. 23 156 concentrations of PCBs in a fairly substantial amount in some of your monitoring wells that were os your property chat were also near chair property? MB. PBCKt object to the form of the question, inconsistent with prior testimony or evldsnce. I don't know of any substantial amount found in any monitoring wells. Well, do you know of any found is any monitoring wells chat y'all informed FMC about or United Defense at any point in tima during the time that you worked for Monsanto? MB. PECK: Same objection. Nhac I know about lc ie what I learned from the article in the paper Sunday. That's all you know about it? Tee, sir. Well, it indicated in the article in the paper -- and I have one of those p0/rrs<ai%r nunnoTrun eravrrs ruin 1 2 3 4 A. 5 6 7 6 9 q. 10 11 12 13 14 if 16 q. 17 16 19 A. 20 21 22 23 160 knowledge are chose the only deep monitoring wells that y'all have out there? Hell, I'm acruggling in crying to remember how many locate them. Z have not been involved with thone in so long, I eaa'C specifically cell you I'm totally accurate. You understand, Mr. Brown, it's just hard for me to get Adam and get one of y'all over here. MR. STEMART: I'm juat kidding. Adam. I'm just trying to get aame era ware, ia abac I'm crying to get. so you don't renumber anything about that, at least during the time that you were involved? No* MR. PECK: I cold him you would be asking about this since this ia tfca firat witness we have produced since chat article, REGIONAL REPORTING SERVICE, INC. ADAD21-003740 HARTOLDMON0033696 1 z 3. 4 S 6 7 8 9 10 11 13 13 Q. 14 15 16 17 A. 1ft Q. 19 20 21 22 23 161 Donald. MR. STSHARTj I think < have an obligation to aak about it. Ad . MR. PECK* I didn't say you couldn't ask it. MR. STEWART* I hope I ask about it. If I don't, somebody might be asking mo. And they are bigger than I ms. I don't want any problem with thorn. You don't know anything about any kind of concern about FMC that was expressed before you read that article in the paper? Heavens, no. Now, Mr. Brown, would you mind -because it's about twelve ten -- would you mind making available to Mr. Peck and Mr. Kelly, for their transfer to me. anybody chat might be over nineteen and eligible for jury duty that you might be REGIONAL REPORTING SERVICE, INC. 1 l Q. 2 A. 3 4 Q. 5 6 A. 7 Q. a 9 A. 10 11 Q. 12 13 14 A. IS Q. 16 A. 17 Q. 18 A. 19 20 21 22 23 163 Who else do yew have? Their kid, daughter, son-in-law. That's all. Tou said six. tha - - That's four. Who is Two little ones like that. I'm talking about over nineteen. What's the daughter's name? Gina -- Steve and Gina -- I'm trying to think of their last name. Why don't you just give chat to Adam. Just tell me where they work. That's what I'm looking for. He's a lawyer too. Here? (Witness shakes bead negatively.) In Calhoun County? I'm not sure exactly where he works. He lives In Jackaonvills. KK. STEHART: If y'all will gif. ms just s few minutes, I may be -- (Discussion held off record.) REGIONAL REPORTING SERVICE, INC. 1 2 3 4 S ( 7 A. ft 9 10 A. 11 Q. 12 A. 13 Q. 14 15 16 17 1ft A. 19 20 Q. SI A. 22 Q. 23 A. 162 related to in Calhoun County? Mould you mind making that list available to them? can go through in detail, and we can set another time, but I would prefer not to do that. If you don't mind doing that, I will appreciate it. Over nineteen and related to me? Mr. Pedes It ie for purposes of -- I can do that right now, two people. Okay. Mho Is that? Nell, ***** it sis with cousins. I'd rather you -- What I'm looking for is this information on them, just who they are and where they live. And if you know where they work, give me acne idea of where they work. James and Pearly Brown, Jacksonville, Alabama, retired. Where did they work? Ihey were school teachers. Who are they in your - My uncle and aunt. REGIONAL REPORTING SERVICE, INC. 1 2 3 4 S 6 7 ft Q. 9 10 11 A. 12 Q. 13 A. 14 14 16 g. 17 It 19 A. 20 Q. 21 22 A. 23 164 MB. STEWART: H tad Calked .bout acme teat results Bill Adams and Tom did in 19ft5 on Ghoccolocco Creek. Is there something that -- Have we gotten those results? Mr. Peck: les. (By Mr. St.wart) I wantad to know from you, Mr. Brown, If Mr. Landwehr la atiil alive. Do you know? The laat 1 heard, be was. Do you know whers he lives? It aeena like ha nay have bee: in Arkansas or something. I'm not sure. I naan, that's -- Do you know how old he would be? Do you have any idea how old Mr. Landwehr would be? Probably puahing seventy. la he atiil working with Konaaato or retired? He left the company at tbat point in time, *72. REGIONAL REPORTING SERVICE, INC. ADAD21 -003741 HARTOLDMON0033697 -a 1 Q. 2 3 A. 4 S 4 7 Q. 9 20 11 12 13 A. 14 Q. IS A. 16 Q. 17 A. IS Q. 19 A. 20 <5. 21 A. 22 23 Oo you know what part of Arkansas bs 1 ives in? 16 S I'm not even sura It's Arkansas. H left tbs company and went with somebody west of here. That's tbs best t can do for you. There was a James Sell and a Butene Wright and a Gerald Miller that participated apparently at that point in time. Do you know where those gentlemen are? I think that was the PCS testing that was done back in tbs * 70s. Toby bell is diseased. That * a Toby? Tes. Okay. Eugene Wright? Chattanooga. How old is he? Sixty-ish. Do you know who he works for? Well, I'm not sure he is working. He had a heart attack and almost died. I'm not sure if he - - I don't know if he's REGIONAL REPORTING SERVICE, INC. 1 2 A. 3 4 Q. 5 A. 6 Q. 7 A. a 9 Q. 10 A. 11 Q. 12 A. 13 Q. 14 15 IS 17 A. 10 19 20 21 22 23 167 testing or -He left the canpany in about *72 or something like that. 0o you know how old he would be? Pushing sixty. Whac about George Watson? The last I heard lie was retired, in tbs St. Louis area. Retired from the company? Uh-fauh (Indicating yes). Do you know bow old Mr. Watson would be? Probably high fifties. What about John Williford who was formerly with the Alabmsa Water improvement comission? Do you know where he would be today? The last t heard he was still working with ADEM. I don't know if he's retired or not. I haven't heard from him in probably three or four years. He was a long, long-time ADBt esployee. HR. STEMARTi I baliava that'a all I have. REGIONAL REPORTING SERVICE, INC. 1 2 3 4 Q. 5 A. ^( 7 1 q. 9 A. 10 11 Q. 12 A. 13 Q. 14 IS A. IS g. 17 IS A. 19 20 Q. 21 A. 22 q. 23 IS 6 able to be hack up and around or not. But he was working with the City of Chattanooga prior to his heart attack. What did he do for the city? Superintendent of their public works, their waste water, water treatment operations. What about Gerald Miller? Tba luc I heard, Gerald vaa around the Birmingham area. What was he doing there? He was running his own business. What's the r*"* of the business; do you know? Guardian. Guardian vhat, aecurity ayaeama or something? ' Guardian Associates or something like that. Guardian Systems, I guess it was. What kind of business was that? He ran a testing company. okay. Was he an employee of Monsanto at the time that he participated in that KuuiuNAL REPORTING SERVICE, INC. . 1 2 3 4 5 g 7 9 10 11 13 13 14 15 16 17 IS 19 20 21 22 23 166 (The depoeicion concluded at 12;13 p.m.) * REGIONAL REPORTING SERVICE, INC. ADAD21-003742 HARTOLDMON0033698 169 1 I do hereby certify thee the witness 2 whose Attached deposition was taken before me 3 was by me first duly cautioned and non to 4 tell nothing but the truth in the cause 5 aforesaid; that the testimony contained herein 6 was toy me reduced to writing in the pretence 7 of said witnesses by means of stenography and afterwards transcribed by means of computer 9 aided transcription. The foregoing is a true 10 and accurate transcript of the whole of the 11 testimony given by said witness, as aforesaid. 12 I do further certify that 1 am not 13 connectsd by blood or marriage with any of the 14 parties or their attorneys or agents and that 15 I am not an employee of any of them, nor IS interested in the matter of controversy. 17 IN WITNESS WHEREOF, I have hereunto set 18 ray hand and affixed ray notarial aeal at 19 Gadsden, Alabama, County of Etowah, this 26th 20 day of May 1998, 21 Deborah salers Garrett 22 Certified Shorthand Reporter Registered Professional Reporter 23 Notary Public, Alabama-at-Large My Commission expires: 3-7-2001 REGIONAL REPORTING SEKvwk, XK<j. ADAD21-003743 HARTOLDMON0033699 JRYBRN2.TXT '30 98:23 '30s 13:17 '50s 149:17; 155:10,11 '60s 37:20; 65:9; 149:17 '69 35:7 '70 35:8; 101:7; 145:22 '70s 6:6,15; 7:8,12,19,21; 8:11; 19:6; 21:19,21; 33:3; 37:20; 52:15; 106:6, 9; 138:18; 139:3,8; 140:11; 145:21; 146:19; 147:17; 165:12 '71 9:13; 13 :3., 3.9 ; 25:21; 35:8; 46:14; 96:4, 17; 101:7 '72 9:13; 13:1,19; 16:6; 25:21; 45:1; 96:18; 101:7; 164:23; 167:2 '73 13:19; 16:7 '74 8:1,11; 11:15; 15:9; 24:19; 46:14 '75 57:20 '7 0 TTT. X.UIrjt, 140:13 '80 141:15; 145:22; 156:9 '80s 7:14; 12:1; 33:4; 81:23; 111:10; 145:16; 146:19; i4.a^ n/ -i *a f At. n/ /. 153:12; 156:4,9; 157:1,10 '81 58:12; 63:20; 100:12 '83 79:5; 91:23; 106:13 '84 66:5; 129:6; 135:12 '85 12:2; 101:17; 103:6,12; 107:10 '86 78:21 '87 12:3 '88 12:3 '89 78:21; 107:8,9 '90 73:20 '90s 111:11; 117:1; 145:14; 148:3,15 '93 79:4; 148:23 0 001 38:5; 44:12; 100:1 024508 85:23 1 1-W 118:18 1000 1:18 112 3:16 1131 2:4.5 12 1:16; 4:7; 5:1 127 3:17 128 3:17,18 12:15 168:2 132 3:19 144 3:20 14th. 82:11 15th 72:23; n c . i -l 169 2:16 17 48:21 1929 98:23 1967 6:11 IAt A A / 4 p j/u 40:d; 31:2,3; 33:23; 39:14; 95:16; 96:4 1970s 16:20; r <** * pa a 30;10; o / : / 1971 16:6; 44:5; 45:1; 46:13; 60:1; 98:23 1374 8:3,14; 12:17,20; 13:7,10; 14:19; 15:6; 17:13; 29:16; 43:19; 46:7; 47:2; 49:6 1975 47:20; 48:3,22; 49:13 1980 127:7,11 1980s 12:6; 95:10 1981 58:12; 135:11; 136:2; 138:15; 139:20; 140:11; 156:8,13 1982 63:19 1983 80:16,23; 82:11; 94:17, 21; 106:18; 108:12 1984 129:5; 132:15; 133:13; 134:14 1985 66:5; 70:10; 107:4; 164:3 1986 72:23; 78:3 1988 76:17 1989 73:20; 95:1,2 1990s 121:13 1993 145:7; 151:17 1998 1:16; 4:7; 5:1; 169:20 2 2-S 116:18; 140:20; 142:13 202 40:19; 62:5; 115:12; 118:10,17; 119:9; 126:6 2Cth 2:9 218 55:5 21927 2:11.5 230 146:2 23rd 75:23 26 3:4 Page l 26th 70:10; 169:19 27420 2:12 27th 128:2 28th 6:11 29th 75:16; 76:2 3 3-7-2001 169:23.5 3-E 116:18; 140:20; 142:13 300 2:8.5 34 3:4 35203 2:9.5 35901-0755 1:22.5 36201 2:5 38 3:5 4 4 2:15 4-E 118:7,9 48 3:6 5 5 2:21.5_ 5-js 118:7 500 1:18 505 2:9 58 3:5,6 59 3:7 6 61 3:8 67 3:9 7 7 26:15; 31:3 70 3:10 72 3:11 74 3:12 755 1:22 7th 127:7,11 82 3:13 84 3:14 88 3:15 ADAD21-003744 HARTOLDMON0033700 JBYBKN2.TXT 9 94 3:7,8,9,10, 11,12,13,14, 15 9:15 1:15; 4:8 A a.m 4:8 a.m. 1:15 able 110:19; 166:1 above 45:19; 87:4,10; 108:19 Absolutely 104:4; 151:21 accepted 79:12 accordance 87:6 according 138.19 accordingly 120:21 accurate 64:7; 160:8; 169:10 accurately 63:15 across 146:23 Act 87:2 action 1:4.5; 14 :13,16 ; 17:7; 44:22 actionable 121:2; 123:11 actions 16:14 actively 12:5; 13:12 activities 49:14 actual 121:22 actually 107:4 ADAM 2:7.5; 160:10,13; 161:4; 163:11 Adams 164:2 address 15:4; 71:11 addressed 74:15 addressing 33:6; 49:23 ADSM 20:4; 71:23; 80:5, 7; 147:13; 156:22; 167:18,21 ADEM's 159:5 adjacent 80:21; 98:3 adminis trator 48:23 advisory 18:18; 106:8 afected 148:12 aecting 114:13 aixed 169:18 aforesaid 169:5,11 afterwards 169:8 ag 68:17,18 agencies 13:3, 20; 21:10; 33:17 Agency 49:2; 53:3; 56:17; 58:3; 80:4 agents 169:14 ago 5:9; 19:21; 27:12 agreed 4:2,9, 15,22; 102:5 agreements 78:16 agricultural 12:22; 22:23; 49:12; 52:10 ahead 26:21; 54:7; 92:23; 121:20; 149:22 aided 169:9 air 13:12; 114:14; 139:22 al. 1:3,6.5 ALABAMA 1:1, 19,22.5; 2:5, 9.5; 4:6,7; 5:1; 16:22; 20:3; 21:3, 10; 60:9; 70:19; 72:20; 74:23; 75:22; 78:5; 145:23; 162:19; 167:14; 169:19 Alabama-at-La- rge 169:23 Alan 110:16; 111:18; 117:5,22; 118:2; 119:22 alive 164:10 Allen 66:18 Allen's 85:10 allow 121:15 allowed 123:7 allowing 102:15 almost 165:22 already 45:21; 76:13; 124:4 amount 11:3; 58:17; 60:17; 145:4; 149:6; 150:16,19; 158:2,10 analysis 66:11 analytical 35:5 analyze 143:8, 9 analyzed 46:20; 87:16; 120:19 analyzing 46:18 Anniston 1:18; 2:5; 4:7; 5:1; 9:9; 21:20; 22:8; 23:11; 24:2; 47:23; 49:22; 55:15; 56:3; 74:9; 89:10; 97:10; 99:1; 133:1; 134:13; 159:7 another 11:23; 66:15; 70:9; 120:19; 124:3; 138:4; 162:4 answer 7:13; 21:1,16; 31:20; 32:5; 35:11; 44:16; 51:22; 52:22; 78:14; 86:3; 92:23; 93:21; 14n40o/*2::Ao3;,7; 117:17; 120:13,15; 136:12; 149:21 answered Page 2 24:10; 31:19; 32:6; 50:14; 52:1; 57:1,3, 11; 75:19; 102:11; 159:18 answers 45:3; 160:14 anybody 10:16, 17; 15:17; 16:2; 18:14; 25:2; 34:9, 22; 35:1b; 44:4; 73:8; 87:7; 135:2; 147:13; 151:16; Ibb:19; 161:22 anyplace 45:20; 124:11,13; 144:6 anytime 157:7 apologize 5:23; 59:11, 19; 62:13; 82:13? 110:18; 119:8 apparently 30:9; 31:4; 159:13; 165:9 appeared 27:5; 91:11 appears 132:14 applications 93:13 applied 18:5 applies 7:3 apply 138:13 appreciate 7:11; 88:9; xox ; o appropriate 13:3,4,20; 14:11; 56:16 approval 78:22 approved 33:11 April 76:17; 128:2 archived 63:23; 64:3 area 6:15,22 ? 24:2; 39:18; 40:9; 42:22; 43:5; 62:4; 85:1,18,20; 94:17,21; ADAD21-003745 HARTOLDMON0033701 JRYBRN2.TXT 98:2; 112:14; m.m-.i 120:18,19; 124:9,10,14, 16,19,22; 125:6; 126:5; 138:7; 139:2i; 149:15; 152:22; 154:4; 156:1, 2; 166:10: 167:8 areas 72:14; 139:7; 145:9 aren't 125:17 Arkansas 164:14; 165:1,3 Arnett 128:12 Aroclor 12:23; 26:13; 28:16, 18; 63:12 Aroclors 37:4 arose 157:8 around 67:10; 103:6; 124:23; 166: 1,9 arrive 62:14 arrived 62:10; 94:13 arrow 153:6,23 article 168:19,22; 160:23; 161:15 articles 95:11; 96:16, 18,20; 159:1 asks 56:5 assess 143:1 assessing 142:11; 143:4 assessment 62:21; 65:16; 142:8; 147:6; 155:21; 156:5 assign 4:19 assigned 71:4 assist 65:15; 132:17,18 assistant 48:23; 82:13 assisted 133:23 associated 106:2 Associates Association 75:1,23 assume 58:5; 64:5; 69:16; 70:6; 90:18; 115:11; 128:11; 149:23; 150:3 assumed 37:7; 51:5; 150:10, 15 assuming 31:8; 88:16; 137:10; 152:1 attached 3:22; 34:7; 58:9; 73:10; 94:3; 127:22; 169:2 attack 165:22; 166:3 attempt 20:9; 78:9 attempting 98:10 attention 27:18; 29:5; 30:8; 31:12 attorneys 169:14 August 6:11 aunt 162:23 authorities 56:16 available - 57:12; 95:18; 161:20; 162:2 Avenue 1:18; 2:4.5 average 7:6; 108:15,17 aware 11:2,9, 13; 18:7; 27:5; 67:3; 70:3; 124:17 away 76:22,23; 77:9; 86:12, 18; 134:22; 142:13; 145:10 AWIC 26:13 B back 29:5; 40:17; 41:13; 42:22; 43:23; 60:18; 76:7; 108:7; 114:20; 119:9; 137:12; 138:17; 149:16; 153:19; 155:8; 156:4; 165:12; 166:1 bad 59:10 Baker 58:13; 59:21; 62:21; 126:23; 127:8,10; 155:20; 156:4 ballpark 62:22; 64:11 BAPTIST 1:3; 40:10; 43:11 based 50:8; 62:23; 78:17; 79:8,10,19, 22; 92:IS; 99:22; 116:15,150:23; 151:3,10 basically 98:11 basins 130:20; 140:2,7; 143 :5 basis 20:6,13, 16,18; 63:8; 138:21 Bate 55:4 bathroom 5:14, 17; 94:8 became 8:2; 17:12; 47:2; 74:1 become 7:22; 130:20; 134:3 becomes 129:20 bee 157:12 began 116:23 begin 59:10 believe 6:17; 9:6; 24:21; 28:16; 50:6; 60:23; 63:4; 66:3,13; 69:1; 76:13; 83:11; 95:15; 112:8; 154:9; 167:22 bell 25:16,18; Page 3 165:7,13 below 34:16; 79:17; 85:4,5 Ben 141:14 best 6:1; 13:6; 16:1; 42:12; 57:11; 62:18; 64:11; 78:17; 79:10; 97:21; 115:7; 116:8; 152:20; 154:2; 165:5 Bethel 43:12; 77:11,12,13 better 44:8; 65:14 between 140:10 big 68:21 bigger 161:10 Bill 59:14; 62:18; 104:5; 139:5; 164:2 billion 159:5 biological 23:5; 130:7, 11,13,20 biologically 137:16 Birmingham 2:9.5; 166:10 bit 48:10; 54:8 blank 90:12; 91:10 blood 169.-13 board 25:10; 100:18; 141:15 Bob 103:18; 139:11,13 bodies 53:12 body 21:12 bore 140:15 boring 140:14; 141:20 borings 142:14,17,19 bOSS 68:22 both 13:12; 27:14; 30:17; 55:13; 62:1; 97:6 bottom 59:16 bought 147:19 box 2:11.5; 146:3 boy 93:15 ADAD21-003746 HARTOLDMON0033702 JRYBRN2.TXT Boyen 141:14 brain 99:2 Branch 72:19 breached 155:15 break 30:17; 94:11 breaks 5:14; 94 : 9 brief 15:18 bright 14:21 bring 27:17; 29:4; 30:7; 31:11; 78:9 Broadwater 70:18 brought 13:2, 18; 14:10; 16:1; 47:3; 114:20; 142:2 BROWN 1:10,12; 2:20; 4:4; 5 6: V- , 1 ; 8:7; 10:5; 11:2; 12:12; 14:6,20; 15:10,19; 16:13; 17:11; 19:22; 27:21; 28:17; 29:10; 31:13; 32:12; 33:19; 34:9; 35:20; 36:1, 19; 37:3; 39:10; 42:1, 11,14; 43:2, 19; 45:8; 47:15; 43:7; 50:15; 51:10; 53:4,16; 54:10; 55:5, 9; 56:9,13, 14; SIib,; 58:11; 59:11, 14; 62:10; 63:5; 66:2; 68:22; 69:9, 1^ . -** ; *71 . *| . 'a - , 76:12,20; 77:20; 79:15; 80:13; 81:15; 82:5,10,12; 85:3; 8> ; lu ; 87:17,23; 88:9; 89:17; 90:7; 92:16; 93:6,18; 94:5,12; 96:19; 97:16; 98:6; 99:7; 103:10; 104:22; 106:9; 107:14; 108:8; 109:8; 112:16; 113:21; 114:9; 117:18; 119:3; 121:11; 122:5; 124:2, 19; 125:1,15; 126:7,11,15, 19; 128:1,11; 131:12; 132:13; 133:18; 134:18; 138:12; 139:2; 141:16; 143:14; 144:10,18; 146:17; 147:10,14,19; 149:4,19; 150:8,20; 151:13; 152:14; 153:3,20; 157:5; 159:8; 160:9; 161:18; 162:18; 164:9 buried 11:4; 37:20; 58:18; 60:19; 61:8, 21; 64:13; 65:12,22; 100:14,16,20; 101:2; 105:10,11,18; 116:14,15; 124:10,15; 149:6,19; 150:3,7,11, 17,19; 151:2, 8; 155:5 bury 121:16; 123:17; 124:18 burying 37:14; 124:11,13 business 21:3; 166:12,13,20 C calculate 63:15 CALHOUN 1:1.5; 162:1; 163:17 call 46:8; 78:11; 121:1; 123:11; 140:5 called 26:13; 59:6; 62:2; 69:4; 112:21; 135:20 calls 21:14; 51:3,18; 52:20; 55:1; 56:20; 57:23; 92:4,12; 101:22 came 8:5; 25:10; 41:17; 43:20; 44:13; 70:5; 77:10, 13; 85:16; 86:5; 92:18; 93:5; 96:11; 97:6,12; 98:20; 100:3, 18; 103:13, 16; 104:1,15; 106:2; 133;20; 139:21; 141:15; 145:7; 156:3, 4,22 cannot 18:1; 120:15; 125:5 cap 155:14 capability 86:10,11 C&paCity 11:21,22 capped 116:21, 22; 117:8; 118:4; 155:7 capping 111:17; 112:20; 113:4,16; 115:9,17; XI t J..7 $ 16^ ; A care 14:9; 45:22; 71:5, 9,15; 137:16 Carolina 2:12 carry 53:3; Page 4 78:23 case 89:18; 125:16; 131:23 catch 140:7 catchment 140:2 cause 169:4 caused 18:17; 27:6 cautioned 169:3 caveat 159:11 cell 112:15; 116:18 cells 37:15; 112:9,14,21; 113:22; 115:17; 117:20; 118:13,15; 119:6; 123:14; 142:13,14 Center 2:8.5 certain 37:14; 53:7; 112:9; 120;23 certainly 5:19; 57:20; 62:13; 73:7; 121:9; 126:10 j mj UW.L UXi.1 2:16 Certified 1:13; 169:22 certify 169:1, t *"l AA chain 137:4 chance 48:17 change 26:1 changed 33:1, 0 - 1 ***! . *! A 01 AAA.A1 characterization 92:21 charge 46:17 Charlie 70:3 Chattanooga 165:17; 166:3 Cheatvood 156:17,18,22; 157:10,12 Chmflk 45 ^ . 1 ^ . 20; 147:10 checking 46:1, 2,3,10,12; 147:8 a V_AAQ V QA ADAD21-003747 HARTOLDMON0033703 JRYBRN2.TXT 128:13; 132:15; 134:14; 139:11,13 chemical 22:21; 52:5, 7; 68:12,15; 75:1,2,22; 121:15; 159:4 chemically 131:19,21; 132:2 chemicals 86:21,22 chemist 8:2'; 25:11; 35:3; 42:17; 43:18; 149:13 chief 8:2; 16:22; 25:11; 35:3; 42:17; 149:13 Choccolocco 6:14; 7:4,5; 12:14; 18:15; 27:7; 29:22; 34:1; 38:3; 50:23; 51:16; 52:17; 80:14, 17,22; 82:21; 83:2,8; 86:14; 89:16; 90:22; 91:1, 5,8.11; 92:17; 93:1, 6; 106:14,16, 20/ 164:4 choice 102:19 chose 114:9, 12; 130:10 CHURCH 1:3; 40:10; 43:11 circle 153:1 CIRCUIT 1:1.5 City 151:21; 166:2,4 CIVII, 1:4.5 clarified 110:23 clarify 119:19 clarity 73:2 Class 137:17 clean 39:9 cleaning 129:23 cleanup 21:18, 20; 22:1,5,6, 11; 23:23 clear 8.-21; 64:13; 111:1; 112:19 cleared 43:6 clearer 32:6 clearly 123:4 clipped 67:20 closed 11:15; 13:5,8,17; 16:6,9,10; 17:16; 18:19; 63:12; 106:5; 155:8,11,13 closest 142:14 closure 13:2, 19; 14:11; 16:1; 47:3; 115:8 Cobb 94:15 coffee 129:15 collected 140:3 collective 85:1 combination 27:14 come 27:12,13; 40:18; 63:16, 23; 103:14; 133:10 comes 146:11; 159:7 comfortable 5:20 coming 13:11; 44:18 commencing 1:15 commercial 18:19 Commission 16:23; 20:4; 21:4,11; 167:15; 169:23.5 Commissioner 1:15; 4:6,23 communicate 23:22; 30:3 communication 47:16 communications 20:15; 21:7; 32:20,22 community 94:6,15; 95:12 cosq>any 1:6.5; 9:12; 10:17; 12:23; 16:7; 20:9; 21:2,7; 22:23; 52:58,10,12; 55:14; 68:13, 15,17,18; 121:16 145:23 148:22 149:16 155:16 159:14 164:22 165:4; 166:21 ' 167:2,!J complete 16:1 completed 97:13 compliance 4:13; 15:7; 49:14 complicated 30:19 comply 58:2 compounds 55:11 computer 169:8 conceive 14:14,18; 16:16; 36:4; 44:23 conceived 44:3 concentrations 47:6; 55:11; 56:5; 158:1; 153:3 concept 26:1; 130:18 concern 47:8. 21; 161:14 concerned 134:12 147:15 concluded 168:1 conclusion 64:1 conditions 138:13 conducted 151:1,-* confidential 20:6,13,16, 18,22; 21:8; 25:1; 27:23; 28:4,13,23; Page 5 32:14,20 confuse 73:8 confused 73:5; 83:9 conjunction 30:9; 33:22; 60:5; 80:19; 106:22; 133:5; 151:16 connected 42:1; 44:4, 11; 45:7; 68:3; 101:18; 169:13 connection 66:6; 108:12; 114:10; 135:16; 136:3 Conservation 17:7; 80:19; 90:23; 106:23; 108:13; 109:3,5 conservationi st 82:14 consider 12.-10 considerably 77:20 consistent 115:3 consolidated 43:16 consultant 133:22,23; 140:22 consultants n5 . i i 1 o consulting 104:8 contact 10:15; 26:14 contacted 64:23 contained 149:23; 169:5 containers ti4 .4 ft 40. IJOiXU 137:7 containing 137:19 containment 143.-4,5 contaminated 18:15,16; 129:1,2 contamination 20:11,12; . ADAD21-003748 HARTOLDMON0033704 JRYBRN2.TXT 29:19; 39:13; 53:11; 83:2; 0S:2; 129:13, 14; 141:2; 147:16,22; 148:7,19; 151:17; 154:22 continuation 1:10,11; 55:16 Control 87:2 controversy 169:16 conversation 10:15; 60:1; 98 :18 conversations 19:4,8,12,16; 30:22; 31:6; 65:1; 151:10 convoluted 30:20 coordinated 75:10 coordinating 50:7; 97:17 Coosa 89:20; 90:13 copied 74:17 copy 59:10; 70:11,15; 109:13; 128:12 core 80:20; 89:5; 90:16; 143:11 cores 140:19; 142:21,22 corporate 69:2 correct 6:7,8; 9:4; 18:13; 42:10; 47:1; 65:13; 72:22; 73:1; 78:1; 86:1; 87:18; 106:15; 116:19; 121:2; 123:5; 130:9; 149:1; 156:13 couian't 119:5,6,20; 123:13; 161:6 country 49:18; 98:22 COUNTY 1:1.5; 162:1; 163:17; 169:19 Couple 126:19; 153:18; 154:4 course 23:7, 17; 53:4; 68:8 cousins 162:12 cover 5:10 covered 8:7; 155:6 Craddock 103:5,15 Craig 70:20 creek 6:14; 7:3,4,5; 12:14,15; 27:7,8; 29:21,22; 34:1,13,14, 16; 37:5; 38:3; 43:22; 44:7; 50:23; 51:1,15,16; 52:17,18; 56:8; 66:11; 67:4; 76:18; 77:1,8,14,17, 22; 79:2; 80:14,17,22; 82:21; 83:2, 8,13,16,17; 84:5; 86:5, 14; 89:15,16, 22; 90:1,7, 11,12,17,18, 2<!; 91:2,4,5, 8; 92:18; 93:1,4,6; 95:10; 98:16; 99:13; 100:6; 106:14,16,20; 107.-5,6; 120:7,14,15, 17; 122:12, 15; 145:2; 164:4 Crockett 16:20; 17:1; 20:1; 25:2; 30:8; 33:21 crocketfs 29:6 CSR 4:5 culvert 40:18, 20 cup 129:10,14 Page 6 cut 145:10 cute 51:11 CV-96-243 1:5.5 ------------- -------------- D dark 84:20; 124:23 darn 16:13 Darrell 58:13; 59:21; 127:8; 155:20 data 57:12,14, 15; 79:9 database 36:5 date 6:5,9; 31:3; 33:5; 75:12; 133:1 dated 26:14; 48:21; 70:10; 72:23; 82:10; 127:7; 128:2 daughter 163:2 daughter's 163:8 David 74:5,14 day 143:15; 169:20 deal 79:17; 137:13 dealing 50:18 dealt 33:16 Deborah 1:12; 4:5; 169:21.5 debris 118:11 December 136:2 decided 69:23; 141:17 deep 152:2,10, 11; 153:13; 154:6; 159:21; 160:1 Defendants 1:7.5; 2:6.5 Defense 157:15,23; 158:14 define 85:18 defined 51:8; 85:20 degree 10:21; 11:23; 133:4 delay 78:21 demolition . 118:12 Denner 74:5,15 department 17:8; 60:9; 70:19; 72:20; 78 : 6; 80:2G; 108:13 ; 109:4,5; 127:1; 136:17; 156:3 deposition 1:10,11; 4:4, 10,11,20; 5:9; 6:18; 9:16; 26:9; 32:9; 107:21; 109:9,12,14; 111:6; 168:1; 169:2 depositions 4:14 designated 112:22 designed 113:17 detail 48:19; 54:9; 162:3 details 127:17; 152:4 determine 79:7 determined 131:7 determining 35:6 detoxification 130:8,11; 131:4,8,14 detoxified 129:20; 130:21; 131:7 detoxify 132:3 developed 13:14; 35:5 developing 35:18; 36:5, 16; 128:19 development 36:6,7; 71:18 develops 114:23 devoted 114:3 died 165:22 different 33:6; 59:19; 64:1; 73:21; 122:2; 138.6; 152:12 Dillon 1:17 dinner 74:19, 20; 76:1 direct 25:23; ADAD21-003749 HARTOLDMON0033705 JRYBRN2.TXT 38:5; 65:17 directed 47:5 direction 41:7,10,21, 22; 42:5 directly 139:14; 145:8 director 70:19 discharge 37:8,10; 38:5,6,20; 39:15,22; 40:5; 44:12; 45:10; 46:4, 9,10; 47:13; 55:14; 56:10; 99:4,9; 100:1; 144:2; 146:9 discharged 104:18 discharges 56:3 disclose 96:22 discovered 29:18; 145:11; 155:15 discuss 24:23; 98:18; 108:5 discussed 31:9; 99:8; 108:4; 118:9; 156:23; 157:4,7 discussing 157:9 Discussion 14:1; 163:23 diseased 165:13 dishwasher 129:16 dismantling 22:1 disposal 125:5; 135:16; 136:4; 149:15 dispose 86:19, 20; 120:22 disposed 11:10; . 120:20; 129:2,3,8,18 disposing 97:18 dissemination 20:10 ditch 40:8,11, 22; 41:18; ' , ;42:1,6; 43:8, 10 20 144:11,13,20; 146:8 ditches 29:20 division 17:2; 60:11; 72:19 document 53:20; 54:2, 12,16; 60:15; 67:17; 68:1; 84:10; 88:7; 90:4; 100:9, 12; 126:21, 22; 128:2; 132:7,11,13, 19; 134:15; 135:10,14,18, 21,22; 136:7, 11,23; 137:2, 18; 138:3,5, 15; 156:8 documents ' 53:23; 67:16; 73:10; 83:4; 126:20; 134:11; 137:3,5,20 doing 11:1; 23:4; 44:3; 46:16,17; 104:8; 111:19; 115:7; 117:6; 134:22; 139:1; 140:1; 141:20; 142:8; 154:2; 156:5; 157:16; 162:5; 166:11 dollars 114:2 Don 73:2; 74:3,15 DONALD 2:3; 67:14; 161:1 : , ;done 6:13; 8 10 11 10:7; 14:19; 15:19; 16:4, 19; 17:15; 20:16,18; 29:7; 37:16; 57:20; 63:19; 76:15; 77:21; 79:20; 84:7; 86:23: 92:6; 95:1,9,10; 101:7; 110:14,15; 111:15; 112:20; 113:4; 115:4, 16; 117:22; 122:13,14; 138:18,21; 139:18; 148:10; 151:15; 152:2 ; 155:21; 157:14; 165:12 dotted 144:15, 17 down 11:12,15; 13:1,11; 15:18; 16:9; 22:2; 30:17; 37:17; 40:12; 43:11,20; 44:21; 59:12, 13; 77:3,8, 13; 79:2; 85:7,11,12; 98:15; 99:6; 106:6; 109:21; 119:2; 122:12; 129:21; 130:19; 131:9; 140:20; 141:1; 144:18,19; 146:8 downsized 25:20 downstream 55:13 drainage 40:11; 41:2, 7,16 dramatic 16:13,15 draw 40:15; 41:9,22; 42:2; 144:9; 157:12 drawn 41:18; 42:5 dredging Page 7 90:21; 91:1; 94:23; 95:9; 97:12,14; 98:8; 100:5; 106:14,16 drinking 159:5 DSN 85:23 dubbed 28:20 dug 119:21; 122:6,7 duly 5:4; 169:3 dumped 123:15 dumps 156:12 during 9:14; 19:22; 20:14; 23:9; 31:15; 33:15; 34:11; 70:23; 76:7; 103:23; 118:2; 139:19; 140:9; 143:2; 146:5,12 ; 150:2; 151:13; 158:15; 160:17 duty 53:8; 161:23 E earlier 6:3; 18:21; 27:23; 60:12; 63:22; 114:21; 136:10,23; 137:1; 143:6 early 7:8; 65:9; 79:3,4; 80:22; 81:23; 117:1; 138:18; 140:10; 147:4; 149:16; 156:9,13 easier 38:23 east 124:7 eat 132:1 Ed 141:15 eect 4:12; 19:4; 54:12, 21; 56:2; 69:22; 93:4; 114:22; 115:2 eluent ADAD21-003750 HARTOLDMON0033706 JRYBRN2.TXT 146:10 effort 27:9; 37:23; 71:10; 80:3; 111:18; 116:23 eight 3:5; 38:15,17; 58:8; 89:5; 99:11; 124:5 eighteen 3:16; 108:22; 112:1,6,12; 113:1; 116:12; 137:23 either 94:15; 96:9; 129:1; 138:3; 139:21; 148:13; 152:16 Eleven 3:9; 67:7,12 eligible 161:23 eliminate 47:12 elsewhere 27:8 embarking 47:11 Emelle 87.11; 119:4,12,14; 120:22; 121:7; 122:8; 129:4 emerging 15:6; 35:18; 36:17 emissions 8:14; 54:13; 69:21 emphasis 13:15 employee 134:19; 166:22; 167:21; 169:15 esployees 19:14; 75:9; 133:17; 134:9 end 105:19; 120:9; 122:9, 14,23; 144:3, 4; 148:14; 149:7; 150:7, 20; 152:8; 155:1,6 enforcement 49:1 engineer 16:22; 72:18 engineering 22:20 enough 6:20; 51:21; 101:13; 107:14; 143:17 entailed 8:13 entered 32:8 entire 104:20 environment 48:5; 53:6, 14; 54:14,22; 69:12 environmental 7:23; 8:3; 10:8,12; 11:18; 12:1; 14:7; 17:12; 19:23; 42:16; 49:2,4; 52:4; 53:2; 56:17; 58:3; 70:20; 72:21; 78:6; 80:4; 97:5; 103:3; 107:15,18; 133:5; 143:16; 149:13 EPA 47:16,22; 50:22; 51:14; 52:14; 57:16; 58:13; 60:8; 71:22; 78:5; 80:8 equipment 131:17 era 23:12; 35:8; 41:3; 76:8; 140:13; 145:22; 148:1; 150:2 Esq 2:3,7.5, 10.5 estimate 64:11; 101:1 estimation 60:14 et 1:3,6.5 Etowah 169:19 Eugene 165:7, 16 even 15:12; 18:22; 21:9; 33:21; 44:1, 2; 47:7; 80:16; 95:18; 106:7; 119:14; 165:3 everybody 44:11; 98:22 everything 25:20; 28:10; 115:3; 125:22 evidence 4:21; 83:1; 141:1; 158:9 evolution 36:9; 137:3 evolved 32:23 exact 6:5,9 exactly 7:9; 9:5; 37:3; 40:13,21; 42:23; 53:17; 54:12; 111:8; 163:18 examined 5:5 example 129:9 except 4:17; 87:14; 118:4 Excuse 13:22 Executed 40:1; 42:9; 154:18 exhibit 26:4, 8; 27:4; 34:5,7; 38:14,17; 39:2,3,5; 48:14,20; 58:22; 59:1, 4; 61:4; 67:7,9,11; 70:12; 72:2, 5; 73:8; 74:11; 82:2; 83:10; 84:2, 6; 87:20; 88:3,10; 90:10; 99:10; 108:7,14; 112:1,5,12, 23; 116:11, 12; 124:5; 127:3,12,20, 22; 128:5; 132:8,12; 143:20,22; 146:2 exhibits 3:21.5,22.5; 58:7,9; 94:1, 4 Page 8 exist 119:14; 136:1; 139:7; 147:14 existed 67:5 existence 18:8; 64:5 expanded 145:17; 146:5 expansion 145:18 expected 57:10 expecting 78:20 experience 35:22 expert 51:6 expires 169:23.5 explain 12:18; 49:11 explained 15:2,23; 45:22 exposure 53:11 expressed 47:21; 161:14 extensive 140:14 extent 95:6 extra 73:10 F face 141:13 facilities 69:14; 75:7 facility 15:8; 16:10; 17:16; 22:1; 37:9, 11; 38:6; 49:5; 66:16, 17; 97:21; 119:15; 130:14 fact 43:9; 63:4; 76:20; 80:12; 105:16; 107:13; 149:5; 155:14 fair 40:2; 55:18; 110:1 fairly 12:5; 63:15; 81:12; 123:4; 149:5; 158:1 familiar 7:15, 16; 22:14; ADAD21-003751 HARTOLDMON0033707 JRYBRN2.TXT 69:6,17; 132:6,12; 143:17; ' 149:4; 157:3, 13 far 35:13; 43:23; 65:12; 77:3; 85:7; 97:18; 134:12; 147:14 Faust 110:16; 111:18; ' JL _i_ 1 . Faust's 117:5; 119:22 feasibility 130:7 February 70:10; 127:7, 10,11 fed 41:18; 43:22 federal 13:13 feed 40:22 feeds 89:15; 90:11; 91:4 Feel 26:18 feet 76:22,23; 77:4,5,16,22; 85:4,5 fellow 14:21; 16:21; 58:13 felt 14:3,8 few 88:8; 163:21 field 152:9; 154:11 fifteen 3:13; 32:4; 82:3; 83:11; 104:6; 108:7; 136:19 filth 59:9 fifties 167:12 fifty 76:22, 23; 77:16,22; 79:12,17,18; 85:4,5; 87:3, 10; 108:19; 121:5,10; 123:12 fifty-six 34 :17 figure 62:14, 16; 64:7; 99:3; 100:11; 101:11 figures 62:23 filing 4:23 final 115:8 finally 78:8, 10 Financial 2:8.5 find 14:4; 44:8; 49:6; 53:10; 82:23; 103:8; 109:19,23; 110:6,9,19, 20; 125:22; 141:1 findings 33:23; 34:13, 20; 56:18; 94:14; 95:17, 18; 96:2,17, 22; 98:15 fine 107:9; 154:19 first 5:4; 15:11; 38:19; 59:6; 62:15; 67:17; 84:17; 89:23; 90:9, 17; 97:8; 128:16; 148:10; 160:22; 169:3 fish 12:16; 17:6; 18:6,8, 18; 53:12; 57:14; 106:8; 109:2,4 fishing 18:20 Fite 1:17 five 159:4 flow 113:18 flowing 41:20 flows 89:20; 90:12; 144:8, 10 FMC 157:15,23; 158:13; 161:14 folks 66:8 follow 29:17; 135:15 follow-up 126:22 followed 122:16,19; 134:6,11 follows 5:5 foot 79:17 force 4:12 foregoing 169:9 forgotten 100:23 form 4:18; 8:17; 11:7; 19:2; 21:13; 24:8; 29:11; 30:13; 31:17; 32:15; 51:2, 17; 52:19; 53:19; 54:15, 23; 56:19; 57:22; 81:1; 86:17; 90:3; 91:6; 92:3, 11,19; 93:19; 95:20; 99:16; 100:8; 101:21; 105:21; 107:23; 113:9; 114:1, 5,15; 115:20; 117:9,14; 120:2,10; 121:19; 125:2; 142:16; 145:6; 158:6 format 134:1 former 45:6; 49:21; 92:22 formerly 167:14 forms 138:6 forth 1:20 forward 98:13 found 10:10; 29:18; 38: 2; 50:23; 51: 15, 16; 52 :1S; 80:18; 84: 5; 85:15; 86: 4; 92:17; 99: 12; 121:13 i 122:6, 11; 123:9, 10; 125:14 t 126:4; 139 :6; 142:15 1 143:7; 145 :4; 157:23 } 158:11 ,12; 159:15 foundation 115:22; 117:16; Page 9 120:4,12; 125:4 four 98:10; 163:4; 167:20 fourteen 3:12; 34:15; 36:2; 74:12 freuse 33:9; 34:11; 46:6; 71:1,5; 140:9 FRAJHXLZN 2:8 frankly 95:17; 127:15 free 26:18 front 60:18; 93:16 full 4:12 further 14:16; 67:4; 79:2; 85:12; 169:12 G Gadsden 1:22.5; 169:19 Garrett 1:13; 4:5; 9:7; 10:18; 18:22; 169:21.5 Garrity 140:23 gathered 33:13 gave 89:4,6 Gene 128:11 general 22:12; 26:1; 40:15; 42:4; 67:19; 73:22; 74:1; 75:16; 76:1, 5; 107:11; 112:13; 113:15 General's 70:4; 78:7; 80:6 generally 37:7; 47:19; 79:12; 126:16 generation 36:8; 121:23 gentleman 66:18 gentlemen 165:10 George 167:6 Gerald 25:6,7; 165:8; 166:8, 9 H ADAD21-003752 HARTOLDMON0033708 JRYBRN2.TXT getting 6:22,7:2 Gi.ua ib 3 : 9 give 21:9; 27:16; 29:2, 13; 33:4; 58:22; 59:4, 70:11; 89:4, 152:20,21; 162:16; 163:11,20 given 169:ll giving 30:6; 31:10; 45:3, 58:15; 102:6; 110:2; 116:8 glanced 54:5 goal 69:22 Gosh. 77:4; 140:22 got 7:17; 15:13; 41:2 61:2; 66:17 67:15; 73:4 77:15; 78:8 83:4; 84:13 88:6; 93:15 129:14 gotten 164:6 government 75:4,17; 76 :4 grab 84:14,17; 35:17 Graddiclc 70:4 gradient 140:20; 141 .2 greater 159:4 Greensboro 2:12 Greg 66:7 ground 40:3; 114:13; 142:19; 147:8,15; 154:21 grounds 4:19 group 15:17; 46:16; 60:7 72:11; 75:2 5,6,11,17; 76:4; 81:23 groups 78:5 Guardian 166:15,16,18, 19 guess 30:10; 44:15; 62:19, 22; 85:8; 91:3; 99:11; 103:18; 110:5; 111:20; 149:2; 166:19 guessing 91:12 guess timation ;ri . *i n ox j.o guidance 121:22 guideline 79:13 guy 156:16 guys 82:16 --------- ------------------ a half 85:8 hand 169:18 handle 49:20; 51:7; 135:7 handled 87:5; 103:2 handling 50:4 handwriting 42:8; 123:20 hanging 88:6 happen 33:2; 48:7 happening 75:13 hard 78:4; 105:14; 160:10 hate 53:4 hazardous 59:7; 69:20; 129:19: 134:4; 136:9; 137:14 head 72:18; 163:16 heading 17:2 health 60:10; 127:1; 156:3 hear 78:13 heard 18:1; 23:15; 164:11; 166:9; 167:7, 17,19 heart 165:22; 166:3 Heavens 161:17 held 14:1; 163:23 HELMS 2:11 help 38:11; 48:9 Henry 82:15", 17 hereby 163:1 herein 1:20; 169:5 hereto 3:22.5; 34:8; 58:10; 94:4; 127:23 hereunto 169:17 hide 126:11 high 44:6; 31:12; 167:12 highest 108:21 Highway 118:10 HILL 1:2.5; 40:9; 43:10; 77-7.10 history 13:8; 97:9,15,19, 20; 104:16, 19; 105:1,5, 8; 106:1; 107:20; 108:4; 156:14 Hodges 22:15, 16; 24:1,4; 45:18 hog 40:9 hogs 39:11,19, 20; 40:4 honestly 24:10 hope 6 0 ?19 161:7 Hosmer 23 :10 human 14:14, 18; 16:15; 44-23 hundred 34:15; 36:2; 77:4,5 I ------------------------------------------------------- idea 17:17,19; 23:1; 28:1; 29:15; 42:19; 44:3; 50:12; 114:7; 149:12; 159:19; 162:17; 164:17 identification 3:22; 26:6; 38:16; 48:16; 59:3; 61:6; 67:13; 70:14; 72:4; 74:13; Page 10 82:4; 84:4; 88:5; 112:7; 127:5; 128:7; 132:10; 144:1 identified 127:11 identify 82:6; 83:20; 84:8, 11; 126:20; 127:6; 128:9 import 123:16; 125:5 is^ortaz&t 50:16,20; 51:13; 52:13; 101:12 imposed 17:22 Improvement 16:23; 20:4; 21:4,11; 167:15 Inc 1:21.5 Incident 89;10 included 49:7; 81:22; 152:3 including 93:13 inconsistent 108:2; 158:7 incorrect 92:20 indicated 6:3; 8:23: 27:22: 63:22; 66:13; 81:11; 90:14; 92:16; 99:9; 107:21; 109:10; 110:3,6,22; 111:2,3,5; 112:8; 118:16; 122:3; 154:9; 158:22 indicating 21:22; 24:20; 39:18; 40:16; 41:8,12,21; 60:22; 62:17; 76:19; 85:11; 88:7; 112:15; 113:3,16; 116:11.17; 118:20; 128:21; 144:12; 150:13; 152:23; ADAD21-003753 HARTOLDMON0033709 JRYBRN2 .TXT 153:19,22; 154 :13 - 167:10 individual 81:16 Industrial 72:19 information 20:10; 21:9; 28:15; 33:13; 35:19; 36:19; 58:17,20; 79:10; 81:17; 89:7; 96:12; 162:14 informad 94:20,23; 95:2; 157:22; 158:13 Initially 139:15 input 88:23; 89:3; 90:14 inquirer 52:14 inspected 138:16 inspection 59:8; 60:2 inspections 138:1 instituted 21:19; 24:1 instructions 125:22 136:16; 137:9; 138:4 intensive 85:18,19 interested 169:16 internal 133:16 interpretation 121:22 interviews 150:23; 151:3 introduced 100:10 involve 47:7 involved 9:2, 8,15,19; 10:18,20,22; 15:1; 19:19, 23; 31:22; 33:16; 47:2; 49:5,19; 66:17; 80:8, 9,13; 81:5; 100:5; 106:17,18: 111:12 17 ; 122:15,21,23; 134:19,22; 135:1; 141:7; 145:8; 148:9; 160:6,18 involvement 8:19; 10:23; 66:3 isn't 28:17; 56:2,9; 93:18; 106:15; 126:14; 148:7 i38ue 51:7 issued 18:18 issues 15:4; 49:16,18,21 itself 53:21; 54:17; 77:15; 90:5; 135:17 J Jack 10:17,20, 23; 97:6; 105:3 Jacksonville 162:18; 163:19 James 72:17; 162:18; 165:7 January 58:12 JERRY 1:10,12; 2:20; 4:4; 5:3; 32:11; 59:14; 82:10, 12; 84:10; 117:13; 156:16,18 Jesses 23:7; 24:13; 26:12; 30:12 job 8:12; 13:7; 15:3, 15; 18:12; 22:19; 43:18; 46:17; 49:20, 22; 51:7,9 Joe 9:9,12 John 103:5; 167:13 joint 80:2 Jones 96:11; 97:4,8; 98:14; 99:8, 14; 101:5; 103:11.12.16; 104:1,3; 150:23; 151:11 Jurevic 141:15 jury 161:23 K Kaley 103:18, 19 keep 29:23; 39:9; 110:19; 115:23 KELLY 2:10.5; 161:21 kept 63:6 kid 163:2 kidding 160:12 kind 6:21; 7:1,16; 20:11; 21:18; 49:8; 60:19; 66:8; 71:9; 88:18; 104:11; 135:21; 143:1; 150:6; 157:13; 161:13; 166:20 kinds 33:7; 72:14; 137:17 Kneisel 66:7; 70:21; 71:20, 23 knowing 35:13 knowledge 13:7; 36:17; 38:2,4 1 41:16; 42:13; 50:16; bfa:13 ; 63:1; 65:11, 14,23; 67:5; 78:18; 86:12, 18; 96 :10; 99:22; 124:15 138:17 157:19 ; 160:1 knowledgeable 51:5 known 9:21; 12:11; 36:23; 56:15; 96:8; 98:21; 101:19 knows 50:17; Page ll 116:3 KY 146:2 L labeling 136:20; 137:7 lack 115:21; 117:15; 120:3,11; 125:3 landfill 8:6; 11:4,10; 13:5; 16:10; 37:15; 41:14, 17; 42:20; 61:9,15,21; 62:4; 63:9; 65:17,20; 105:18,19; 110:4,15; 113:2; 120:9; 121:17; 122:9,14,23; 123:8; 126:5; 138:8,14,16; 139:20,22; 140:5,6,17, 18; 143:2,18; 144:3,4; 145:5; 146:7, 8,11^ 148:14; 149:7; 150:8, 20; 152:8; 155:1,6 landfills 100:15; 116:22; 117:8; 119:23; 123:6 landowners 95:6 Landwebr 9:6, 9; 10:16; 23:19; 164:9, 17 large 4:7; 133:4 last 5:12; 6:17; 62:12; 63:5,13; 64:2; 66:6, 13,19; 67:1; 78:11; 90:9; 91:14; 110:17,22; 111:6,16; 123:3; ADAD21-003754 HARTOLDMON0033710 JRYBRN2.TXT 143:18; 163:10; 164:11; 166:9; 167:7, 17 late 149:17 later 17:21, 22; 20:4; 28:19; 71:15; 139:8; 150:13 latest 116:22 law 1:16; 124:18 laws 4:13 lawyer 5:13; 30:18; 163:14 lead 12:4 leading 4:18; 77:7 learn 36:10; 150:18 learned 158:18 least 12:5; 50:17; 90:15; 160:17 leave 125:9 leaving 37:8, 1C led 29:20; 66:10; 71:18; 107:6; 111:10 left 9:12; 139:3; 141:14; 164:22; 165:4; 167:2 Legro 48:22 Lai^utCu 2;4.b less 108:15,17 letter 31:5; 48:21; 50:10; 53:16; 67:18; 68:6; 70:5,9, 18,22; 72:23; 74:14; 76:16; 78:8; 82:11; 83:12; 127:7, 10,14 letting 33:12 level 47:9; 86:5; 120:23 levels 79:16; 81:12; 107:1; 108:9,10; 123:11 lied 64:6 LIGHTFOOT 2:8 likely 9:22; 69:10 limit 20:9; 87:3 line 5:18; 41:9,22; 42:3; 124:23; 144:9,15,17 list 54:19; 162:2 listed 21:7; 146:1 listen 102:17 little 30:19; 38:22; 41:9; 48:10; 54:8; 68:4; 83:13, 15; 89:14; 93:15; 112:23; 142:21; 144:15,17; 146:3; 153:6, 23; 159:10; 163:6 live 162:IS lived 94:20 lives 163:19; 164:12; 165:2 locate 160:5 located 9:9; 22:17; 23:10; 43:10; 112:11; 133:19; 150:12; 152:7,14,16, 22; 159:23 ItOyfdii 18 x 16 /18 long 11:20; 63:21; 64:19; 91:21; 160:7; 167:21 long-time 167:21 look 26:7; 27:1,4; 38:10; 44:8; 48:17; 53:1, 15; 55:4,5; 59:5; 70:16, 17; 74:16; 82:13; 109:10,23; 124:3; 128:2, 10; 130:10; 136:6; 138:7 looked 54:8; 63:1; 156:6 looking 53:18; 110:20; 141:20; 142:20; 162:13; 163:13 looks 124:8 lot 25:21; 81:22; 84:13 loud 138:9 Louis 8:23; 9:1; 22:18; 49:16; 72:12; 88:16,20; 89:12; 91:17, 18; 95:19; 1nJ,a0unz1::24n30n ;; 133:21; 167:8 low 106:23 K ------------------- -------- made 4:17; 27:10; 32:13; 33:23; 36:23; 37:23; 47:16; 56:18; 60:2, 14; 62:20; 64:16,20; 67:3; 70:6; 78:11; 98:15; 102:13; 109:3,5; 149.-12 Mahoney 68:9, 11 TSfiTi 64:6 managed 9:3 management 70:20; 72:21; 78:6; 120:1; 134 5 * 1 . O- manager 23:8; 24:14,17; 45:7; 63:8; 74:6; 139:17; 141;Q/11 manifests 63:6 manner 132:4 manufacture 105:8; 130:4 yianuamv tUTSTS 75:3 many 5:13; 77:5; 93:11, 12; 97:20; 114:2; Page 12 150:10; 160:5 map 38:9; 84:20; 85:21, 22; 124:3 March 75:15, 23; 76:2; 80:15,22 mark 26:3; 38:13,19; 39:20,22; 40:14; 48:12; 61:1; 67:7; 72:1; 74:10: 82:1; 88:2; 112:12; 115:11; 118:17,19; 1370* ici.on marked 3:2.5, 21.5; 26:5; 28:13; 38:15; 39:1,4; 48:15; 59:2; 61:3,5; 67:12,17; 70:13; 72:3; 74:12; 82:3; 83:13; 84:3; 88:4; 110:10; 111:23; 112:6,22; 124:7,23; 127:4; 123:4, 6; 132:9; 143:19,23 marking 112:3 marriage 169 113 MASS 1:2.5; 40:9; 43:10; 77:7,10 Martin 18:17, 19 material 111:12; 119:4 materials 11:4; 93:14 matter 2 ft: 14 r 107:13; 115:7; 169:16 Mayausky 96:11; 97:6; 101;3 104:15; 105:3,16; 107:17 Mayausky's awnwo ^i ADAD21-003755 HARTOLDMONOQ33711 JRYBRN2.TXT mean 10:14; 11:14; 19:20; 21:1; 22:10; 24:19; 25:13; 29:21; 33:4; 36:16; 39:7; 41:3,12; 42:2; 43:3; 44:2,21; 57:8; 59:6; 62:1; 67:2,5; 71:8; 73:17; 79:4; 89:4; 91:3; 110:13; 116:2,13; 124:19; 126:8; 131:18; 133:15; 134:20; 135:6; 136:15; 137:3; 140:2; 149:11; 159:12; 164:15 means 95:9; j-uz 4; xo7 : /, 8 meant 28:2; 41:6 meet 23:2; 47:10; 82:13 meeting 22:16; 33:20; 75:11, 15,22; 76:2, 3,7,10; 81:20; 34:18 meetings 76:8, 16; 94:12; 95:13 melted 129:21; 131:3 member 132:23 members 94:15 memo 26:11 memorandum ** j ; j. memory 50:8 mentioned 6:17; 9:6; 16:18; 18:21; 23:18; 27:11; 36:20; 37:13; 61:17; 63:13, 18; 66:2; 86:8; 143:6; 147 : 7 Merrill 1:17 met 23:4; 64:1; 75:8, 17; 82:8,14 metal 129:23; 131:3,9 method 131:22 methodology 35:6 methods 136:8 MICHAEL 2:10.5 mid 12:1 might 10:10; 18:15; 32:13; 38:11,22; 49:19; 50:19; 87:8; 119:21; 120:8; 135:1; 139:7; 146:18; 147:14; 148:12; 150:16; 161:9,22,23 mile 85:8,9 miles 108:16 Miller 25:5,6, 7,3,18; 26:12; 30:11; 31:4; 140:23; 165:8; 166:8 Miller's 25:15 million 17:5; 34:16,18; 36:3; 61:11; 64:7; 79:13, 18; 87:4,11; 100:13; 105:17; 108:16,23; 121:5,10; 123:12 millions 114:2 mind 14:14,18; 16:16; 44:23; 73:9; 111:1; 161:18,20; 1 .;xo fcj mine 60:16; 141:23; 142:2 minute 13:23; 27:12; 109:18; 149:20 minutes 88:9; 163:21 mischaracteriSea 32:17; Page 13 99:18; 113:11 missing 89:14 MISSXOHASY 1:2.5; 40:10; 43:11 misspeak 123:5 misspoke 135:13 mistake 83:23 misunderstood 62:12; 119:1, 8 mixed 83:5 mixtures 55:12 monitor 155:5, 12 monitoring 151:22; 152:6,11; 154:8,10,12, 16,20; 158:3, 11,13; 159:1, 21; 160:2 MONSANTO 1:6.5; 6:4; 7:23; 10:8; 11:5; 12:22; 17:13; 19:14; 21:19; 22:21; 27:5; 30:10; 33:21,22,23; 35:22; 36:22; 39:12; 49:12; 52:5,7,9; 68:12; 69:5; 71:4; 72:13; 74:7; 75:5, 18; 85:16; 89:12; 94:19; 101:18; . 102:23; 104:9; 107:16; 114:12,21; 115:5; 121:15; 124:21; 131:11; 151:16,19; 158:16; 159:2; 164:20; 166:22 Monsanto's 74:9 Montgomery 75:11 MOORS 2:11; 72:17 most 14:13; 21:6; 44:22 mouth 112:18 move 114:23,- 121:7; 122:8 moved 98:12; 120:18 movement 111:11; 113:7,15; 141:21; 142:9,12 movements 25:14 Mr 35:23; 132:14 MTS 133:22i 135:20 much 32:1; 51:6; 61:7; 65:14,22,23; 10 0:20; 101:1; 105:10; 151:2 mud 36:3 MOLLISS 2:11 multi-page 84.9 MW 154:19 myself 57:6 N name 23:15; 58:14; 81:19; 155:20; 10; 166:13 named 58:13; 66:18; 81:16; 156:16,21 wfiiym Oft .11 . 151:7 near 34:16; 40:8,9; 43:10,11; 85:10; 115:1; 158:4; 159:2 necessarily 6:19; 25:22; 67:22 necessary 4-16 need 6:23; 14:17; 45:9; 94:10; 108:5; 117 -. 12 | needed 14:18; ADAD21-003756 HARTOLDMON0033712 JRYBRM2.TXT 105:20 negatively 163:16 neighbors 148:12,16 never 42:22; 44:1,2; 45:8; 57:2; 73:9; 82:8 new 5:11; 13:10,13; 35:7; 47:10 news 36:20 newspaper 95:11; 96:15, 1.8 next 66:3; 1C1.Q nine 3:6; 5:21; 48:15, 21; 58:8 nineteen 3:17; 127:4,12,21; 138:1; 161:22; 162:7; 163:7 nobody 8:22; 24:6; 45:20; 88:17 non-sequential 67:15 none 45:5; 124:15; 142:15 nor 35:15; 169:15 normal 134:20; 135 :9 normally 125:16; 135:22; 136:15 north 2:9,12; 39:15; 144:8, 10; 146:23; 147:21; 148:13; 152:7.9,18: 154:10,14 northern 148:17 notarial 169-18 Notary 4:6; 169:23 nothing 10:12; 28:11; 29:14; 34:2; 36:5; 114:18; 115:18; 169:4 notice 4:22 November 82:10; 132:15; 134:14; 135:12 number 1:4.5; 26:4; 34:5; 35:14,16; 38:14; 48:14; 53:1; 61:4; 67:11; 70:12; 72:2; 74:11; 82:2; 84:2; 88:3; 109:20; 112:5; 127:3, 20; 128:5; 132:8; 143:22 numbers 34:21, 23; 36:8,20, oi. cq.n. 59:15; 94:1 0 o'clock 5:15 21 Object 8:17; 11:7; 19:2; 21:13; 24:8; 29:11; 30:13; 31:17; 32:15; 51:2,17; 52:19; 53:19; 54:15,23; 56:19; 57:22; 81:1; 86:17; 90:3; 91:6; 92:3,11,19; 93:19; 95:20; 99:16; 100:8: 101:21; 102:9; 105:21; 107:23; 113:9; 114:1. 5,15; 115:20; 117:9,14; 120:2,10; 121:19; 125:2; 158:6 objection 58:4; 102:4, 15,18; 158:17 objections A .1 C 1XWQ 1 117:13 obligation 161; 3 observation 117:20 observers 80:9 obtained 12:13 obviously 41:3; 144:5 occasion 100:3 occasionally 94:10 occurred 12:6; 66:15; 142:9 October 48:21; 57:19 off-site 151:18 offer 34:3; 58:6; 93:23; 127:19 offered 3:2.5, 22; 4:21; 34:6; 58:8; 94:3; 127:21 office 78:7; 80:6 officer 7:23; 10:8; 11:19; 14:7; 17:13; 19:23 offices 1:17 okay 8:20; 9:11,18; 11:13; 13:9; 23:13; 24:13; 26:21; 31:9; 33:18; 36:18; 42:4; 45:5; 46:16; 54:8, 10; 55:8,18, 22,23; 59:20; 63:13; 68:2; 71:3, 3.4; 72:11; 74:18; 77:13; 78:12, 14; 80:18; 82:8; 88:14; 93:8; 97:3; 101:15; 108:6; 119:19; 123:2.18; 127:13; 128:16,20; 132:2; 134:3; 135:5; 138:11; Page 14 139:18; 141:9; 14S:22; 153:6; 154:5; 162:11; 165:16; 166:22 old 156:2; 164:16,17; 165:18; 167:4,11 on-site 129:6, 8; 136:8 once 75:11 one 19:17,18; 39:16,22; 40:6; 45:23; 46:8,9: 49:11; 53:15; 59:17; 62:20; 63:18; 69:15; 71:3,8; 75:9; 88:10; 89:9: 99:20; 119:5; 120:18; 128:8; 142:3, 10; 152:22; 153:21: 156:12; 158:23; 160:10 one-page 83:12 ones 86:9.11; 118:15; 153:8; 163:6 ongoing 15:8; 49:15,23; 133:14: 137:4 only 21:23; 111:11; 155:18; 160:1 open 152:9 openly 30:3; 33:16 operated 11:5 operating 65:20; 135:23; 136:16; 137:8; 138:4 operation 12:23; 63:9, 12; 68:21; 100:6; 115:4; 118:12; 128:23; 129:10; 133:15; ADAD21 -003757 HARTOLDMON0033713 JRYBRN2.TXT 150:11 operational 69:14 operations 15:8; 49:15, 21,23; 97:19, 20; 150:2; 15 5: 2,4 ; 166:7 operator 135:2 operators 135:3,4 opportunity 26:23; 55:19 opposed 30:5.; 133:20 order 108:22; 126;16 ordered 128:14 organisms 131:23 organophospha- te 113:14 organophospha- tea 111:13; 114:11; 116:5; 123:23; 124:1 orientation 153:16 other 3:21.5; 9:7; 16:7; 20:11; 25:14; 36:21; 45:5, 1G; 57:15; 64:12; 67:21; 93:9; 95:8; 99:21; 101:6104:17; 105:1; 106:1; 109:11; 110:7,12; 116:4; 120:15; 141:7; 142:16; 150:6 others 24:1; 60:20 otherwise 78:14 ought 54:1 out 6:1; 3_2 -U i * . 14:4; 16:6; 29:9; 35:4; 38:6; 40:3; 42:7,14,16; 43:6,18; 44:13,18; 53:9,10; 64:14; 78:23; 93:16; 94:17; 97:5; 98:3; 99:3,23; 102:16; 103:8; 105:11; 107:19; 110:6; 116:10; 117:6; 118:3, 16,22; 120:6, 8; 123:10; 128:22; 129:12; 133:10,11,20; 138:9; 143:16; 149:3; 153:7; 160:2 outside 126:5 over 7:6; 9:16; 24:18; 29:16,23; 37:20; 40:19; 43:18; 46:2, 22; 47:17; 49:18; 61:22; 97:4; 98:8; 101:16; 110:4; 113:4, 20,22; 115:9, 16; 119:1; 121:4; 123:11; 138:7; 140:16,18; 147:21; 148:21; 152:8; 154:11; 160:11; 161:22; 162:7; 163:7 overall 147:6 ovsr^rowa 42:22; 43:5,6 own 42:8; 119:15; 121:16; 1CC.V5 owned 66:17; 124:21 P p.m 168:2 page 2:14,20; 55:4; 59:5,9, 13,15; 60:22; 67.18; 83:9; 91:14; 109:11,20; 136:6,18; 137:12,23; ; m1 Cil .1 Papageorge 18:22; 45:6, 12; 50:6; 52:1,2; 56:15; 57:16; 91:19,21; 103:2,23; 104:2,5 Papageorge'a paper 93:13, 14; 156:6; 158:19,23; 161:16 paragraph 27:19; 53:15; 55:5,17,20; 90:10,16; 91:14 parathion 60:20; 61:8; 118:11,12; 119:4; 123:19; 126:4; 128:23; 129:10,17; 130:3; 131:17; 132:1; 150:16,19 Pardon 126:1 part 7:20; 8:19; 11:17; 23:5; 51:8: 55:17; 58:19; 73:12; 79:12; 84:17; 94:16; 107:5; 110:8; 111:17; 117:5; 120:15; 124:22; 133:14; 134:3,8,11; Page 15 1a -3i 6:8,. 10,15, 140:11; 146:12; 147:6; 148:1, 4; 155:21; 165:1 participate 6:19 participated 12:5; 134:17; 165:9; 166:23 particular 16:4; 27:8, 10; 28:21; 29:9; 30:2; 44:5; 47:18? 49:5; 50:3, 20; 51:14; 52:14; 54:12; 58:16; 61:16; 63:10; 69:4: 74:20; 79:19; 96:6; 99:8; 100:23; 103:3,9; 109;6; 114:3; 141:18 parties 4:3; 169:14 parts 13:16; 17:5; 34:15. 17; 36:2; 79:18; 87:3, 10; 108:15, 23; 121:5,10; 123:12; 130:1; 159:4 past 12:2; 77:13,15; 114:23 Paul 22:14; 24:4 PCB 8:10; 11:3,9; 13:6; 20:10; 21:20; 23:23; 28:17; 37:14; 39:13; 45:7; 49:15, 18,20; 55:11; 82:20; 83:1; 89:10; 97:10; 98:2; 108:11; 111:5; 113:6; 141:2; 147:15,22; 148:7,18; 1 ADAD21-003758 HARTOLDMON0033714 JRYBRN2.TXT 151 -.17 159 :2; 165 : 11 PCBs 7: 2; 8 :5, 15; 17 5 ; 18: 5,8 ; 24 : 5 ; 28: 20; 37: 4; 38: 1; 47:7 4 22; 53 : 13 ; 54: 21; 58: 17; 60: 19; 61: 12, 20; 67 4 ; 79: 16; 80: 20; 81: 12; 85: 14; 86: 4; 87:4 t 92: 17; 93 : 12; 96: 23; 98 : 1, 19, 22; 99: 5, 12, 23; 100 -.14 ,16; 103 :4; 104 :9, 17, 22; 105 :4, 8.17; 106: 11, 18, 21; 107 : 2, 3,7 ; 110:7 t 12; 113:13 f 20; 115:18 1 116 :9; 119 : 22 7 120 : 23 t 121 :9; 123 9, 14, 18; 124 -.10 ,11, 13; 140 : 12 / ^ A , 141 : 19 7 142 : 13 ,15; 143 :7, 8,9; 145 :5; 147:10; 148:23; 149:6; 150:3; 152:3; 157:4, 7; 158:1 Psarlv ico.io PECK 2:7.5; 7:7; 8:17; 11:7; 19:2; 21:13; 24:8; 26:18; 29:11; 30:13; 31:1, 17; 32:15; 35:11; 39:1; 46:13; 47:18; 51:2,17 52:19; 53:19; 54:5,15,23; 55:16; 56:19; 57:22; 58:4; 67:14; 73:2, 9,12; 77:11; 81:1; 83:4, 10; 84:9; 85:22; 86:17; 90:3; 91:6; 92:3,11,19; 93:19; 94:7; 95:20; 96:13; 99:16; 100:8; 101.-21; 102:9; 105:21; 107:23; 109:15; 113:9; 114:1, 5,15; 115:20; 116:2,13; 117:9,12,22; 119:9; 120:2, 10; 121:19; 122:18; 125:2; 141:22; 142:6; 149:20; 153:10; 158:6,17; 160:20; 161:5,20; 162:8; 164:7 pen 38:22 pencil 38:20 people 9:1,7, 17,20; 12:14; 13:4,21; 14:12; 15:3; 18:20; 19:18, 19; 20:2; 23:17,22; 33:17; 45:5, 18; 46:22; 49:17; 64:22; 71:22; 72:13; 94:20; 95:19; 101:6,15; 141:8; 162:10 people's 13:6 per 17:5; 34:15,17; 36:2; 79:13, 18; 87:3,10; 108:15,23; 121: 5,10; 123:12; 159:4 percent 121:8 performed 146:19 perhaps 45:3; 145:21; 150:15 period 20:14; 23:9; 27:9, 10; 33:15; 42:15; 67:10; 69:4; 87:15; 103:9,23; 129:4; 139:19; 143:3; 146:13 periodically 75:3 permission 78:2 permitted 123:7; 124:21 person 9:5; 17:12; 25:12; 42:16; 48:4; 49:4; 50:17, 21; 52:4; 59:22; 71:6, 8; 97:5; 103:1; 107:15,18; 143:16 personal 10:23; 138:17 personally 9:19 pertained 97:22 phone 78:11 phosphate 47:5,9; 112:10; 113:7, 8 phosphates 47:12; 123:21; 150:9 phosphorus 13:16 picked 98:12; 120:18 piece 147:20 pieces 130:19 pike 13:11 pipe 130:19 pipelines 128:22 place 22:7; 23:3; 25:15; 40:4; 66:4; 85:10; 87:2; 103:17; 109:23; 115:2; 122:1, Page 16 7; 137:21; 138:2; 140:16; 146:22 placed 119:4 places 152:12 Plaintiffs 1:4,16; 2:2 Plaintiffs' 3:2.5; 26:4, 8; 27:4; 34:5; 38:14, 17; 39:3; 48:14; 58:7, 22; 59:1,4; 61:4; 67:7, 11; 70:12; 72:2,5; 74;ll7 * 82:2; 83:10; 84.-2; 88:3; 90:10; 94 ; 1.; 99 :1 n ; 108-7; 111:23; 112:5,23; 116:11; 124:5; 127:3, 12,20; 128:5: 132:8,11; 143:20,22; 146:2 plan 71:15,16, 19; 79:9; 86:20 ' plant 8:5,15; 9:10; 11:11; 13:4; 16:9; 17:15; 21:20; 22:8; 23:6,7, 11; 24:14,16, 17; 25:11; 27:7; 34:17; 37:17; 44:13, 21; 45:6; 46:4; 47:22, 23; 49:13,15, 22; 50:1; 52:4; 54:13, 22; 55:15; 56:3,11; 58:18; 60:2; 62:6,7.8; 64:16; 70:5, 7; 74:6,8,9; 86:6; 88:17, 18; 89:10; 92:18; 93:7, 8; 97:7,10, S ADAD21-003759 HARTOLDMON0033715 JRYBRN2.TXT 22; 98:3; 99:1,6,23; 104 -.15,18,20; 105: 1,5 ; 106:5; 107:20; 124:8; 134:13; 135:3,17; 139.17; 141:9,11; 143:14; 146:10,12; 148:17; 149:4,8; 150:1,9 plants 13:16 please 12:19, 21; 40:14; 84:11; 127:2 pledge 69:5, 16; 70:1; 114:21 pledged 70:1 point 12:9; 14:15; 16:2, 16; 17:3,10, 20; 19:1; 20:20; 22:3; 34:10; 35:14; 36:13; 37:23; 38:6,20; 39:16,22; 40:6; 44:12, 16; 45:11,12; 46:9,10; 47:8; 50:7, 20; 51 - 1A. 57:12; 58:16; 60:15; 61:16, 23; 63:11; 64:4; 65:1,6; 66:1; 67:9; 68:19; 69^1; 70:23; 71:21; 76:21; 78:18; 79:13,19; 87:1; Qfl19. 99:4,9; 101:3,5; 104:7,12; 105:2; 1Q3:20 109:6,8; 116:10; 119:22; 131:12; 134:16; 140:22 141:18 142:20 144:2; 146:9; 147:16 149:18 156:11 157:22 158:14 164:22 165:9 pointed 41:10 policy 20:8; o4^q.. ii.'ft f mA J . r 30:2,3 31:15,21; 134:4,6,12 pollution 4.0 ; jlj t n4 nf .. tVz /. 28:16,17 Porch 1 17 portion 90:15; 122:10 137:8 position 10.-6; 12:16; 14:7; 15:6,20; 20:2; 22:4; 31:16; 32:10; 34:12; 35:3; 57:6; 99:13; 101:16 possible 58:19; 81:18, QQ . Qw . t 115:1; 148:18 possibly 93:9 potential 36:11; 59:7; 67:3; 98:2 pounds 61:10, 11; 100:13, 14; 105:17 power 145:23; 148:22 149:16 155:16 practical 86:2 practically 32:21 practice 32:21; 33:1; 125:21 * 126:9,10,14 practices 115:1 preceded 25:12; 135:18 predecessor 135:21 prefer 162:4 preference 131:13 preferential 131:15 preferred 131:22; 132:3 prepare 133:3 prepared 88:19,21; 89:11; 132:14; 134:13; 135:10,14 preparedness 87:22; 88:12; 89:9; 92:9 preparing 132:18 presence 148:23; 169:6 present 76:7 president 68:12,20; 69:2 press 92:1,2 pretty 14:20; 16:13; 65:11- 86:11 ~' previous 92:15; 100:9; 109:9; 137:18; 149:14 * previously 6:13; 8:9; 16:18; 37:13; 38:18; 52:9; 61:17) 75:19; 87:12; 95:3, 5,15; 96:1; 99:10; 112:2, 8,22; 118:16, 21; 122:4; 123:15; 147:7; 154:9 primarily 113:1; 118:9: 135:3 prior 4:21; 8:11; 11:11; 23:12; 32:17; 99:18; 113:11; 138:14; 139:19; 158:8; 166:3 probably 12:3; Page 17 64:21; 86:7; 89:18; 100:22; 103:5; 117:2; 138:20; 164:19; 167:12,20 problem 12:6; 14:8,10,13; 16:6; 45:8; 66:7; 79:1; 97:10,16; 106:4,13; 110:11; ' 111:5; 113:6, 7; 114:3; 139:7; 147:13; 161:11* problems 98:1; 103:3; 156:23 procedure 28:5,6; 29:1; 133:16; * 134:21 procedures 134:2,9; 135:9; 137:6 proceedings 32:9 process 36:9; 130:8,12; 131:5,14.15. 16; 132:3 produced 28:19; 98:23; 150:9; 160:23 product 28:18 production 62:23; S3:14 Products 12:23; 49:13; 52:10 Professional 1:14; 169:22.5 program 21:18, 20; 22:6,11; 23:23; 47:11; 66:11; 90:22; 140:14; 147:6 programs 111:15 prohibited 114:13 project 44:5 properly 58:2 property ADAD21-003760 HARTOLDMON0033716 JRYBRN2.TXT 86:15; 87:16; 147:20; 152:17,18; 155:17,19; 156:10; 158:4,5; 159:3 proposed 78:3, 13; 84:23 proposing 90:23 protect 53:5 ciuuewbJiCu 49:2; 53:3; 56:17; 58:3; 80:4 protocol 72:16; 77:6; 78:1; 79:7, 22; 84:16,22; 87:13; 98:8; 106:19 provided 57:15; 141:4, 6 public 4:6; 21:11; 30:1; 33:12,20; 17:1; 60:9; 96:9; 127:1; 166:5; 169:23 public's 27:18; 29:4; 30:8; 31:12 publications 27:17; 29:3; 30:6; 31:10 pull 71:10 pulled 65:15; 120:6,8; 128:22 purchased 39:13; 147:20 purpose 44:20; 64:10; 128:15 purposes 86:2; 125:6; 162:8 pursuant 1:19 pushing 164:19; 167:5 put 28:22; 39:19; 42:6; 57:6; 59:18;. 69:3; 71:15, 17; 72:7,9, 15; 79:6,9; 83:22; 84:1; 87:14,22; 88:15; 91:16, 18; 112:18; 115:2; 113:5, 9,12,15,20; 123:7,13,18; 129:16; 130:18; 131:4; 138:3, 15; 145:12, 17,20; 146:22; 152:12; 153:6,7,11, 23; 154:16 putting 33:10; 133:23 Q quantity 151:6 quarter 85:8 question 8:18; 1*1* '.fwt. IQ.V/ 21:14; 24:9; 29:12; 30:14, 16; 31:18; 32:16; 35:12; 41:15; 50:5; 51:3,18,23; 52:20,22; 53:20; 54:16; 55:1; 56:1, 20; 57:19,23: 76:14; 81:2; 85:14; 86:3; 88:7; 90:4,8; 91:7; 92:4, 12,20; 93:20; 95:21; 99:17; 101:22; 102:8,10,17; 104:13; 105:22; 107:11; 108:1; 110:17; 113:10; 114:6.16; 115:2i; 117:10,15; 120:3,11; 121:20; 125:3; 128:8, 16; 142:10; 157:7; 158:7; 159:8 questioned 33:18 questionnaire 57:11 iJuvStiC&S 4:17,18; 55:7 quickly 6:1 Quintard 1:18 quit 44:15,17 ------- = = & railroad 144:19,22 ; 146:23; 147:1,21; 152:17,19; 153:17; 154:11,14 raised 39:12, 14; 107:11 ran 166:21 range 89:4 rather 61:19; 101:5; 112:10; 162:13 read 26:18,21; 31:5; 35:1; 48:18; 53:16: 54:1,7; 55:6, 20; 88:1,13; 91:14; 119:1; 127:18; 138:8: 161:15 reading 4:10; 92:7 readings 7:1; 15:13; 44:6 readv 5:21.22 real 31:14; 44:6 really 22:9, 13; 137:2; 144:21 reason 10:1,9; 15:21; 66:16; 96:6; 99:5, 20; 105:12, 15,23; 106:3; 110:7; 114:9; 116:4; 129:11 recall 5:8; 6:10; 58:15; 66:19; 67:8, 9; 94:12; 96:19; 104:21; 136:10; 139:20; Page 18 141:12,17; 159:12 receive 56:10; 81:15 received 36:22; 81:8 receiving 55:12; 56:4, 6,7,9 recollect 10:20; 24:3; 96:20; 147:18; 157:3 recollection 9:13; 17:1; 25:3; 48:9; 59:23; 84:14, 19; 108:21: 110:21 recoamenda tions 29:6 record 14:1; 163:23 records 63.-14, 21; 138:1 recurring 106:4 recvcled 131:9 reduce 69:20 reduced 169:6 reference 60:12; 61:15 referred 85:2 referring 31:4,6; 85:23; 118:6; 120:5; 156:20 refers 29:5 refresh 59:22; 110:21 refreshing 48:9 Regional 1:21.5 Registered 1:14; 169:22.5 regular 63:8; 138:21 regulated 124:20 regulations 13:10,13,14; 15:7; 53:8; 75:14; 87:6; 119:7; 121:14; 122:16,20; ADAD21-003761 HARTOLDMON0033717 JKYBRN2 . TXT 125:20; 126:13; 137:21 regulator 27:13; 28:9; 156:21 regulators 30:4,23; 31:7; 32:13; 33:17; 50:19; 125:12,14 regulatory 14:11,17;. 21:10; 28:12; 121:21 related 49:21; 73:H; 162:1, / relating 4:14 relations 75:4,17; 76:4 release 92.-2 54:21; 69:21 relocation 118:10 remain 134:10 remediate 111:4,16 remediation 41:5; 43:7; 79:3; 110:14; 111:IB; 116:23; 117:21; 119:23; 124:9; 148:2, 4 remember 6:5; 19:4,10,13; 21:23; 22:16; 24:12; 26:10, 16; 34:20; 47:23; 48:2, 20; 49:3; 58:11,14,21; 59:23; 60:6; 64:20; 66:5, 9,10; 68:5; 70:22; 74:2, 3; 75:21; 76:6; 81:18, 20; 82:17; 88:11; 89:6; 92:7,8 ; 94:18; 96:21; 97:1; 98:4; 100:3; 104:23; 108:6,8; 110:11; 117:19; 123:4; 127:9, 14,15,17; 132:16; 133:12; 136:20; 137:10,18; 145:20; 147:12; 152:4; 154:7; 156:16,21; 157:4,9,16; 160:5,16 remembering 48:8 removal 71:16, 19; 73:18; 79:9; 121:23; 136:3 remove 87:9 removed 79:8; 107:4 reorganization 25:22 repeat 18:1; 90:8 replaced 138:5 replacement 25:23 report 59:8; 64:16,20; 96:17; 125:13,22; 126:6,9; 139:6 reported 9:17, 20; 139:10, 13; 148:22 reporter 1:13, 14; 159:13; 169:22,22.5 Reporter's 2:16 Reporting 1:21.5 reports 20:1, 5,7; 32:12 representative 75:10; 150:1 representativ- es 75:7 request 54:18; 58:20 requests 54:19; 58:2 required 16:12; 17:7; 52:2; 125:17, 19 requirements 138:2 requires 125:21 residue 11:9; 63:2,16; 120:5,13 resolution 78:10 resort 78:11 respective 4:3 responded 50:9,12; 57:18 responding 50:16,21 response 50:5; 110:17 responsibilities 8:3 responsibility 11:18; 14:3; 50:3; 65:18, 21; 139:12 responsible 14:13; 16:15; 44:22; 48:5; 50:18; 97:17; 139:1 result 36:23 results 6:21,- 7:17; 9:21; 12:13; 14:4, 23; 81:9; 84:7; 103:10, 11,20; 164:2, 6 retired 91:21; 139:11; 162:19; 164:21; 167:7,9,18 reverse 125:8 revision 135:12 rhyme 106:3 Richard 68:8 rid 86:13 ricrht-oi-way 126:5 River 89:20; 90:13 road 40:17,18 Robert 81:16, Page 19 21; 82:8; 97:4,11,12; 150:23 roofing 93:14 route 144:21 routine 28:5, 6; 29:1; 32:21; 138:19,20 routinely 137:20; 138:16; 140:1,8 RPR 4:5 rules 4:13; 53:7 running 166:12 runoff 140:3; 143 :2 runs 40:8,11; 144 : 6,17 S Salers 1:12,4:5; 169:21.5 same 4:12; 16:21; 29:17; 39:2; 58:4; 61:13; 69:8; 102:15; 158:17 sasq>le 84:23; 108:9 samples 46:19, 21,23; 47:1, 4; 80:10,11, 21; 89:5; 90:17; 108:12; 139:22,23; 143:11 sampling 36:23; 79:6, 22; 80:1; 81:8,15,17; 82:20,23; 84:15,16,18; 85:2,3,5,17, 19,20; 87:13 saw 96:12 saying 7:11; 14:3,6; 28:21; 54:20; 57:9; 121:14, 21 says 27:16; 29:2; 53:2, ADAD21-003762 HARTOLDMON0033718 JRYBRN2.TXT 12; 61:10; 82:13; 89:9, 15; 90:11; 91:3; 132:17; 137:13; 138:8 SCeUl 152:5 scanned 48:18 scans 152:2 scene 75:13 school 162:21 Scott 35:1,5, 14; 36:14; 45:17 scrap 129:21; 131:9 seal 169:18 section 7:6; 22:20; 113:14; 115:16; 124:7 sector 113:2; 115:10 security 166:16* sediment 7:2; 12:15; 34:14; 37:5; 44:7; 46:3,12,19, 21; 71:16,18; 73:17; 79:17; 81:13; 107:5; 108:10,11; 122:12 see 10:3; 11:16,17; 14:2; 25:20; 40:3; 41:14; 42:8,23; 46:15; 54:18; 60:20; 99:15; 105:13,15; 110:20; 120:20; 130:16; 133:22; 141:13; 153:15 seeing 26:ll, 16; 48:20; 49:3; 67:9; 68:5; 70:22; 117:19 seek 103:8; 107:19 seem 14:20 seems 157:2; 159:13; 164:13 Seen 57:2; 104:5 send 153:23 sending 127:9, 14 sent 25:1; 28:8; 71:20, 22; 72:7,17; 76:16; 126:22,23; 128:12 sentence 89:23: 90:9; 91:3 serve 11:20 served 143:15 service 1:21.5; 90:23; 106:23; 129:12; 130:3 set 1:19; 64:10; 71:6, 8; 87:6; 125:20; 126:17; 136:13; 162:4; 169:17 setting 69:13 seven 3:4; 26:5,8; 27:4; 34:6; 55:17 Seventeen 3:15; 88:4, 11; 90:11; 94:2 seventy 164:19 several 25:13; 64:17; 71:22; 77:4; 108:16; 111:15; 152:10; 159:1 shakes 163:16 shall 4:16 Short 87:15 Shorthand 1:13; 169.22 shouldn't 57:8,9,21 Show 67:6; 72:5; 82:5; 87:19; 132:11; 144:9; 152:15; 159:3 showed 100:11; 106:23; 156:1 shown 85:21 shows 60:8 shut 11:11,14; 13:1; 37:17; 44:21; 99:6; 113:17 shutting 44:20 sicced 66:21, 22; 67:2 Side 113:21; 148:16,17 Siegelman 74:3,16; 75:16 signal 102:6 signature 4:10; 127:16 significance 34:23; 35:13, 16; 36:1,12, 15 simple 30:21; 31:14,20; 44:15; 53:5 simply 58:21; 62:18; 75:2; 122:1; 130:18; 133:16 since 5:21; 14:6; 41:5; 64:1; 65:8; 160:21,23 single-page 67:18 Sir 15:21; 16:14,17; 28:3; 40:14; 49:9; 65:4; 124:12; 153:18; 158:21 Sit 15:18 Site 11:5,10; 44:13; 46:8; 58:18; 59:7; 60:3; 117:21; 151:19 sites 159:2 sitting 42:18 situation 12:20; 27:18; 29:4,9; 30:7; 31:11; 66:4, 10,15,23; 71:11 Six 162:12; 163:4 sixteen 3:14; Page 20 34:17; 84:3,6 Sixty 167:5 Sixty-ish 165:19 slag 150:10 small 146:4; 150:15,19 SMITH 2:4,11 snagging 91:i Snow 6:14; 7:3; 12:14; 27:7; 29:21; 34:1,13,14, 16; 37:5; 43:22; 44:7; 50:23; 51:15; 52:17; S6:8; 66:11; 67:4; 76:17,23; 77:8,14,17, 21; 83:16,17; 84:5; 86:5, 14; 90:1,6, 18; 93:4; 95:10; 98:16; 99:12; 100:6; 107:5,6; 120:6,14,17; 122:12,15; 145:1 soil 76:22; 90:23; 106:22; 108:9,23; 114:14; 123:12; 139:23 sole 99:11 solid 60:7,11; 120:1; 124:20; 156:5,12 somebody 25:19; 30:10; 35:23; 55:3; 88:16,19; : , ;89:4,11; 102 1 12 133:20; 149:3,8; 159:14; 161:8; 165:4 somebody's 64:11; 86:15 someplace 45:10 something 12:11; 13:18; ADAD21-003763 HARTOLDMON0033719 JRYBRN2.TXT 28:4,7,8; 35:21; 40:15, 16; 43:14; 67:6; 69:3; 73:20; 77:18; 83:21; 96:5; 116:7; 118:20; 121:8; 125:11; 134:5; 136:1; 143:13,21; 164:5,14; 166:17,18; 167:3 sometime 6:6; 8:1; 33:8; 58:11; 65:8; 66:4; 80:15 sometimes 76:8,9 somewhere 5:18; 39:17; 40:12,21; 109:18; 146:5; 149:17; 156:9 son-in-law 163:2 sorry 26:22; 68:2; 82:16 sort 9:3; 12:4; 66:21; 71:6; 93:15; 135:12; 145:6 source 27:15, 21; 38:1; 44:8,10; 98:19; 99:11, 23 sources 93:9 south 39:15; 62:4,7; 115:15; 140:6; 152:17 southern 37:15; 41:13, 17; 42:20; 61:21; 62:2; 105:18; 110:4,15; 140:4 speaks 53:21; 54:17; 90:5 specialist 133:6 specialty 72:13 specific 6:23; 23:3; 24:3; iJ : 5; 34:21; 54:19; 76:9; 86:23; 95:22; 125:20; 138:19,20; 152 :4 specifically 22:10; 35:23; 46:20; 48:2; 73:17; 80:15; 87:5; 88:20; 96:21; 97:1, 3,23; 98:4; 104:21; 105:6; 117:4; 120:13; 133:12; 135:20; 136:12; 137:11; 157:9; 160:7 specifics 58:21 specified 87:3 speculation 21:15; 29:14.- 51:4,19; ' 52:21; 55:2; 56:21; 58:1; 92:5,13; 101:23 spell 39:20; 42:7 spent 78:1,21 spills 18:16 split 80:10.11 spoke 76:2 St 88:19 St. 8:23; 9:1; 22:18; 49:16; 72:12; 88:16; 89:12; 91:17, 18; 95:19; 101:20; 102:23; 133:21; 167:8 stab 152:20 Staff 132:17; 133:1,4,7,9, 19 stamp 33:10 stamped 32:12; 55:4 stamping 28:3; 32:19 stand 102:14 stand-alone 68:1 standard 17:4, 9,19; 18:2; 47:10; 159:5 standards 17:17; 18:1, 4,7; 69:13; 126:17 standpoint 13:6; 28:12; 33:10; 75:14 Stanley 4822 Star 159:7 started 6:4; 45:21; 47:11; 63:10; 107:9; 110:3; 111:9; 140:13 starting 7:13 state 1:1; 5:1; 13:3; 60:8; 75:8,9, 13,14; 82:14; 84:18 stated 94:14 statement 10:4; 27:15; 79:15; 87:22; 88:12; 89:10; 92:9; 94:21; 102:13; 112:17; 118:21; 123:2; 125:7 statements 27:16; 29:3; 30:6; 31:10 States 49:1; 53:2 stay 43:1,3,5; 75:12 stenography 169:7 steps 15:11 Steve 163:9 STEWART 2:3, 3.5,4,21.5; 5:7; 7:9; 12:18; 13:22; 15:2; 26:3; 32:8; 34:3; .36:4; 38:13; 39:6; 46:14; 47:20; 48:12; 54:3; 55:21; 56:23; 58:6, 23; 61:1; Page 21 72:1; 73:6, 13; 74:10; 77:23; 79:6; 82:1; 83:6, 18; 88:2; 93:22; 94:9; 98:21; 102:2, 21; 109:13, 16; 111:22; 112:3; 115:23; 117:23; 119:11; 122:19; 127:2,19; 128:3; 142:1; 160:12; 161:2,7; 163:20; 164:1,8; 167:22 sticking 93:17 Still 24:22; 68:16,18? 85:11; 88:6; 129:6,12; 164:9,20; 167:17 STIPULATED 4:2,9,15,22 stipulations 1:19; 2:15 stopped. 44:18 storm 140:3,7; 143:5; 144:5 story 93:17 straighten 102:16 stream 7:6; 29:19,20,21; 108:16 streams 56:4, 6; 142:22 Street 1:22; 2:9 strictly 28:10; 50:8 Struck 27:3 struggling 160:4 studies 23:5; 71:17; 79:20; 111:9; 142:8 Study 19:19; 91:9 Stuff 67:21; 73:16; 77:9; 88:18; 122:11 1 ADAD21-003764 HARTOLDMON0033720 JRYBRN2.TXT subject 31:9; 47:18; 106:2 submit 20:1,5, 7 submitted 58:20 substance 19:11; 101:14 substances 87:1; 123:9 substantial 11:3; 145:4; 1^9-6; 158:2, 10 succeeded 103:1 suggested 30:9 suitably 131:6 Suite 1.-18 sulfur 112:10; 123:22; 124:1 Sunday 158:19 Superintendent 166:5 supposed 60:17; 102:3 surface 41:20; 42:19; 129:13,14,17, 23; 143:1; 145:5; 146:7 surgeon 99:3 surprised 43;9 surprising 49:6 survey 58:19; 63:19; 83:13, 15 Sweet 94:16 switchyard 145:10,12; 146:1,3,4 sworn 5:4; 31:23; 169:3 system 63:17 systems 166:16,19 T Taffee 59:14; 61:14; 62:20; 63:7; 64:6. 12; 139:5 Taffee's 62:18 talked 19:18; 24:15; 60:13; 64:23; 66:6; 90:16; 97:19; 98:14; 130:6; 146:18; 147:12; 148:11; 164:1 talks 137:23 tarry 145:6 TAYLOR 2:3.5: 32:8 teachers 162:21 team 71:9,12 technical 28:11 technology 35:7,19; 36:6,7; 114:23; 115:8; 128:19; 129:22 tells 137:14 tan 3:7; 59:2, 4; 61:2,10, 11; 64:6; 94:2; 100:13; 105:17; 108:15; 161:19 Ten-A 3:8; 61:5 tenets 69:15 terrain 40:2 test 6:21; 7:17; 12:12; 14:4,23; 84:7; 86:10; 103:10,11; 128:14,15,17; 129:22; 140:12; 141:18; 146:16,20; 164:2 tested 106:6; 131:6; 140:8, 19; 142:15 testified 5:5; 93:3 testimony 32:18; 92:15, 22; 99:19; 108:3; 111:6; 113:12; 158:8; 169:5, 11 testing 6:12; 7:3,4,5; 8:4, 10,14; 9:2, 15; 10:7,11; 13:2; 16:8; 80:14; 84:7; 101:4,6,19; 106:19; 139:18; 140:1,21; 142:16; 148:21; 151:15; 165:11; 166:21; 167:1 tests 17:15; 109:3,4; 139:22; 141:4; 146:17 Thanks 109:15; 142:6 there's 85:14 thereto 4:21 thing 16:4; 21:23; 25:23; 49:8; 54:7; 60:19; 68:4; 71:5; 72:7; 78:10; 84:17, 20; 89:14 things 5:10, 11; 27:23; 33:7; 53:13; 60:13; 73:5; 83:9; 122:2; 126:16; 137:17,19; 139:23; 143:18 thinks 102:12 thirteen 3:11; 64:21; 72:3, 6; 136:6; 137:12 thirty 34:15; 36:2 thirty-two 109:12,17 Thompson 81:17,21; 82:9 though 37:18 thousand 61:10; 100:13 three 17:14; 27:19; 39:3; 52:16; 78:2, 5,15,22; 80:11; 98:9; 121:8; 167:20 Page 22 three-quarters 59:13 three-way 80:3 throughout 33:3 tidbit 106:1 Toby 25:16; 165:13,14 today 42:18; 96:1; 100:10; 125:7; 167:16 together 59:18,19; 69:3; 71:10, 15,17; 72:8, 9,15; 79:7, 10; 87:23; 88:15; 91:17, 18; 134:1; 138:3,15 Tom 164:3 took 8:14; 12:4,16; 13:7; 14:6; 15:12,19; 18:12; 22:4; 24:18; 25:15; 29:16,23; 31:16; 32:10; 34:12; 35:3; 43:18; 46:21, 22,23; 47:4, 17; 66:4; 69:17; 97:4; 103:17; 108:11; 139:11; 142:4; 155:23 top 26:14; 59:9; 89:2; 92:10; 145:5 Torbit 82:15, 17 tore 16:9 torn 22:2 TOSCA 114:17, 18 total 114:22 totally 29:13; 35:7; 42:21; 43:5; 113:17; 160:8 toward 41:13; 47:5; 69:21; 114:22 Town 94:16 toxic 69:20; 86:22; 87:1; 1 ADAD21-003765 HARTOLDMON0033721 JRYBRN2.TXT 150:6 track 38:1; 146: 2 3 ; 147:1 tracked 38:4 tracks 147:21 trade 75:2 train 135:6 trained 134.-20 training 133:4,7,9,13. 14,16,18; 134:1,8,17; 135:3 transcribed 169:8 transcript 169:10 transcription 169:9 transfer 161:21 transferred 149:15 travel 84:13 treating 130:14 treatment 23:4,6; 130:14; 137:13,15; lt>6:6 trial 4:20 ti3r ibu tiry 77:7,10,16; 107:6; 120:6, 14,16 trick 39:8 tried 119:2 trouble 48:8; 93:16 true 125:8; 159:9; 169:9 truth 31:23; 32:1; 169:4 try 5:14; 71:10; 78:9; 125:19; 135:6 trying 35:11; 39:8; 41:14; 51:11,12; 53:10; 78:2, 15,22; IQS;14; 109:19,23; 110:5,8,9; 111:4; 160:4, 13,15; 163:9 Tucker 18:21; 35:1,5,15; 36:14 Tull 66:18; 85:10; 93:7,8 twelve 3:10; 5:15; 64:21; 70:13; 161:19 twenty 3:18; 65:3,6,7; 108:22; 128:6 twenty-five 19:21 Twenty-one 3:19; 132:9, 12 twenty-two 3:20; 89:5; 143:20,23: 146:2 twice 75:12 two 17:14; 34:23; 52:16; 76:15; 109:11,16; 116:22; 117:8,19; 118:5,6,13; 122:1; 126:16; 162:10; 163:6 type 145:19 typical 20:15; 21:6 typically 142:23 U ultimate 69:22 ultimately 43:22; 68:21; 70:6; 89:20; 90:12; 145:1 uncle 162.-23 under 40:18; 46:23; 69:23; 91:9; 114:17; 119:7 underground 111:11; 113:8; 141:21; 142:10,12 understand 8:12; 10:3,5; 14:2,22; 15:9; 16:5; 17:4,21; 20:17,21; 30:16,18; 38:9; 45:4; 51:21; 90:6; 99:15; 102:21; 105:13; 112:16; 113:20; 114:8; 121:4; 122:5; 131:11; 150:7; 152:15; 160:9 unders tanding 8:20,22; 14:5; 32:11; 38:11; 39:17; 61:19,20; 64:13; 66:23; 90:2; 104:11; 113:23; 115:19; 116:16,20; 145:9; 146:6; 148:6,8; 159:6 understood 16:11; 39:11; 44:10; 45:2; 52:3; 111:7; 119:3; 138:13 unintelligible 30:15 unit 124:20 United 49:1; 53:2; 157:14, 22; 158:14 units 120:1 unless 78:13 until 43:6; 148:22; 155:14 up 8:21; 17:2; 26:14; 29:5; 39:19,21; 40:17; 41:13; 42:23; 43:23; 45:19; 64:10; 71:7,8; 75:12; 83:5; 92:10; 98:12; 102:14; 106:2; 114:20; 119:21; 120:18; 122:6,7; Page 23 125:11; 136:13; 140:11; 145:1,7; 153:19; 155:7,20,23; 166:1 update 137:5 updated 137:5, 20 upgrade 40:5 uphill 40:5 upstream 55:13; 67:4 V vaguely 58:14; 157:2 Valley 94:16 versus 1:5 vessels 128:22 viewed 146:9 W Wait 109:17; 149:20 waived 4:11,23 walked 42:22; 155:23 walking 43:23 Walnut 1:22 wanted 5:10; 8:21; 55:3; 128:9; 130:16; 164:8 waste 11:3,4; 23:4,5; 37:8, 10,14; 59:7; 60:7,11; 63:7,16; 105:10; 118:11; 120:1; 121:23; 123:16; 124:20; 125:5; 129:2. 19; 130:13, 15; 131:16; 132:1; 134:5, 22; 135:7,16; 136:4,9; 137:15; 150:1,6,16, 19; 151:7; 155:5; 156:5, ADAD21-003766 HARTOLDMON0033722 JRYBRN2.txt 12; 166:6 wastes 104:17; 137:14 water 13:13; 16:23; 17:2; 20:3; 21:3, 11; 37:8,10; 41:20; 42:19; 46:1,3,11,18; 47:1,5; 53:12; 55:12; 56:9; 72:19; 113:17; . 114:14; ' 130:15; 131:16; 139:21; 140:3,8; 142:19,22; 143:5; 144:5; 146:7; 147:8, , , ;15; 151:18, 20 21 22 154:21; 159:5; 166:6; 167:14 waters 55:12; 56:7 Watson 167:6, 11 way 11:16,20; 20:19,23; 21:2; 43:1,4; 59:13; 61:7, 15; 63:18; 68:3,23; 77:8; 99:21; 144:19; 156:15 ways 33:6; 80:11 wells 146:22; 152:2,5,7,10, 11,16; 153:11,14; 154:6,8,10, 12,17; 158:3, 11,13; 159:2, 22; 160:2 west 62:6,7; 105:19; 120:9; 122:9, 13,23; 144-3, 4; 148:13,14; 149:7; 150:7, 20; 152:8; 155:1,6; 165:5 western 62:2, 3; 113:1,21; 115:10,14,16; 123:8; 143:17; 144:3,4; 148:16 whatever 8:6, 16; 86:5; 130:19; 131:17 whatsoever 115:18 Wheeler 23:14; 45:17 whenever 63:19; 103:13 WHEREOF 169:17 wherever 49:19; 85: 15 whether 8:5 t 15; 10: 16; 12:15; 36:20; 57:14; 94:19; 24: ll; 41: l; 76: 12; 117 :3; 142:11; 145:20; 157:21; 159:15 WHITE 2: 8 CO H whoever 89: 141:6 whole 14 :8; 54:1,7; 55:20; 68: 20; 97:22; 169 : 10 wide 152 -.1, 5 wildlifei 17 : 6 will 27: 3; 30:17; 59: 5; 61:19; 67: 6; 70:11.. 82: 13; 93:22; 110:19; 136:6; 153 :2. . 7; 159: 8,10; 162:6; 163 : 20 Williford 167:13 wind 145:1 withdraw 61:19: 76:14; 104:12 within 115:4 without 110:2; 159:8 witness 2:20; 4:11; 40:1; 42:9; 51:4, 20; 55:19; 56:22; 58:1; 73:4; 83:7; 86:1; 92:13; 116:1,3; 120:4; 153:13; 154:18; 160:22; 163:16; 169:1,11,17 witnasses 169:7 word 39:21 words 112:18 work 10:13; 12:1; 16:19; 47:3; 52:7; 68:15; 72:14; 73:15; 76:15; 90:21; 91:19; 104:8; 110:3, 13,14; 117:5; 130:17; 131:1,8,18, 20; 145:19; 157:13; 162:16,17,20; 163:12 worked 11:22; 23:3; 29:8; 42:14; 52:9; 68:18; 78:4; 131:2; 158:15 working 6:6; 7:20; 12:22; 13 :12,15; 14:12; 20:3; 24:4; 30:11; 45:21; 49:13, 17; 52:5; 68:16; 69:21; 79:11; 96:5; 107:15; 114:21; 118:2; 132:23; 133:13; 164:20; 165:21; 166:2; 167:17 works 163:18; 165:20; 166:5 Wright 165:8, 16 writing 169:6 Page 24 written 135:22; 136:15 wrote 28:10; 89:18; 109:20 X XS 112:23 y y'all 18:14; 23:21; 28: 22; 29:8,17; 30:5,22; 39:11; 44: 16; 46:10; 47: 16; 50:22; 52: 15? 63:6,14; 66:16, 21; 69:16, 23; 70:5; 72:7 # 73:15; 76: 3, 21; 77 :9,19, 21; 79 : 2,20; 80:18; 82: 19, 23; 84 :22; 85:3,4 ; 86 ;9, 10,20; 87: 7, 9,22; 91:19; 92:1,10; 94:5,13; 95:16; 96: 22; 98:15, 18; 103:19 1 106:4, 17; 107:4; 108:11 t 119:5, 15,17; 122:6; 123 :6; 124:9; 130 : 6 ; 134:7; 135:15 i 136:2; 137 :7'140:11 I 141:1, 17; 142:7; 145 :4; 146:16 t 147:19 t 148:10 ,15; 152:7, 12; 155:11 i 156:10 ,11; 157:14 ,21, 23; 158:13 / 159:15 i 160:2, ll; ADAD21 -003767 HARTOLDMON0033723 JRYBRK2.TXT 163:20 y'all's 29:22; 31:15; 92:18; 126:14; 134:4 yard 93:16 year 75:12; 137:5,6 years 17:14; "19:21; 52:3.6; 64:18; 65:6, 7; 78:2,15, 22; 93:11; 98:10; 104:6; 150:10; 167:20 yourself 28:9; 55:6; 91:15; 138:10 Z zero 69:22; 114:22; 115:1 / 1:8 169:21 Page 25 ADAD21-003768 HARTOLDMONOQ33724 L3oss:hw AWeiATOM. AUAOAUA March 31, 19 70 UI3JVCT keco::-' ;rwo.\Tic,:is or task ra.zac os PLANT DUMP Cl, TO J. L. Corder ' Menders: H. 3. Mu Hally, Chairman Hal 3raieiton J. L. Ether edge T. W. Laurence J. H. Foveli E. C. Height I. ?unni.-..i A serious problen exists at the present tiae with Che Monsanto dump. The two main areas of concern are: (1) water leakage frea the F.C.3. dump, and (2) lack of security throughout the dump area. These two areas create Hazards la the areas of water pollution and in liability problems. September 12, 1S71, all open dumps in die State of A la bates will be eon* verted to land-fill operations. This law applies to municipalities, but it also applies to any privetc dump operation which might pose a water pollution problem or health hazard. In light of the attention P.C.3. has received, it is highly probable that the Monsanto (?.C.3.) ducip area could ixi classified as a serious water pollution source. For this reason it is imperative that this operation be converted to a land fill type so as to minimize the chances for vqerr pollution as well as " for'the aesthetic value to the-plant, aince- the-proposed Highway 202 expansion will be very close to the dump area. n. xEctroffiaaiTioss For purposes of simplicity these recommendations are being split into two categories: (1) immediate changes in operations, and (2) long range changes. A. Idtt? Acciona . 1. Ellr.ln.-tcc P.C.F, Drslnacc fron Present Dunn Site To nccomplish this it Is rccowmirrided that extensive changes br made in chc present dump 'area. The old drums lying on eh* bank* of the dump should be moved to the bottom of the hole. .Sufficient dirt should be hauled in to provide at leant 2 ft. of cover over nju Q13822 J ADAD21-003769 HARTOLDMON0033725 -2- ehese drums and is should be compacted In such a vay Chae it will provide a good footing for establishing individual crlls uithln the larger bole which ecn be operated as a land-fill. It is recotmnended that this dirt be obtained from the vicinity o the present dump and be excavated in r manner to provide a trench fir future land-fill operacion. 2. Provide Security around Dnmrint Site A fence with the proper markings should be provided around the area presently being ueed. The attached drawing show* the area which should be fenced. 3. Repair Incinerator n The teepee incinerator located at the dump thou Id be repaired and put into operation. The regular operation of this unit will decrease the volume of material which must be placed into the land-fill. State of Alabama law also states Chat open burning of wastes he halted hy September 12, 1971. This unit should be repaired to ehat ft is operable and operated as per the recom mendations of the manufacturer. . ' A. Provide Periodic Cover of the Waste The waste material In the dump should be covered on a regular schedule. A minimum of once per week is recommended. Tlie waste material should be covered in accordance with good operating procedures. The periodic covering of waste and dividing the remainder of the hole into cells will allow drainage of the dump site and eliminate the large lakes which arc presently a problem. Economics will probably necessitate contracting the Job of covering c SjiCrcl*!, but this job-shouldA bkeee M 4*d S-cf Monsanto representative. 3. Develop a Duoo Management Svatem The entire damp and solid waste disposal system should be made a responsibility for one person and this person should have Che re sources with which to control the operation. There should be an operating manual procedure developed for the dump operation. This nanus 1 should Include such topics as the proper methods for pre paring waste material, a definite schedule for enllectlng che wastes, as well as the development of sn Inventory system for the waste and Che development of a plot plan so that accurate records can be kept on what and where these wastes are burled. The above mentioned things are suggested only as a guideline for the develop* went of ehe system and many details have been omitted which should he in* eluded In the operating Instructions. OEM Q13323 ADAD21-003770 HARTOLDMON0033726 -3- Lonc Rnnpc Operations Preparing for a land-fill operation should begin nov when obtaining the dire for cliaiinycliig the immediate problem with the dump site. This dirt should be raved from the mountain around the dump slLr and it should be moved in such a manner chnc preparation of a trench la begun. 1. I-nd-~ill Oneration . A land-fill operation is an orderly manner for disposing of reltd waste material in such a way that it does not create a threat to health, a public nuisance or pose any wacrr pollution problems. Safeturrds should siro be taken to make certain that underground water is not contaminated, the material should be covered on c regular basis to a minimum of 1!" and material should not be placed closer than 24" below ground level. The land-fill should be seeded with grass and trees after filling so that erosion will not uncover the material which has been burled. The Tesk Farce recommendations for future land-fill operations are as follows: a) Dig a trench (along the contour of the mounts in) of sufficient size to handle the plant's solid waste for a period of one year minimum (eat. 14,000 yds. per year baaed on 1970 dram usage). Thi* trench should be sloped such that it is dtained st one end. Width should be such that equipment will have sufficient space to maneuver in it (i.e., 8-IQ' widt). The depth should be from 8-10* so that sc least 6' can be used after periodic covering and allowing for 2' of top cover. b) Covering of material should be accomplished a minimum of once . per week. c) Waste should be segregated and the paper, wood, fiber yaks, etc. homed. Only still boctoms end ncn-bvmable material should be buried. , d) Decontaminated drums and scaled drums of sample boctles from the Psrathion process, aa veil as drcontamincCrd equipment, could also be buried with the ocher plant wastes, thus eliminating the seed for a separate toxic dump. p) Run-off water from the trenches should be sampled s minimum of once per week (more often in rainy weather) to make certain that no material is being lost from the fill. f) The person responsible for the land-fill operation should in spect this area regularly to make certain That the area is being well kept. DSW 013824 ADAD21-003771 HARTOLDMON0033727 g) After die trench has been filled with waste it should be covered, compacted and planted with grass and trees to prevenc erosion as well as Improve the appearance oi the area. h) establish system of test wells for monitoring of ground water for contamination. 2. Seeur 1 tv The original fence should be extended Co encompass sufficient new area ac any time which It is required. In ocher words, the active part of the dump should always be inside a fenced and secure area. tiarkers should be provided on used up trenches so that this location can be easily determined. 3. Alternate Methods of IMsoosal Alternate methods of disposing of ctill bottoms end other plant wastes should be evaluated, aince the method of burying in a drum ia quite expensive as well as space consuming in the Land fill. (In 1970, approximately $38,000 was apenc for drums.) The task force.recsssscads that ocher methods certainly be looked ac for the future (i-*., bulk, hauling, pumping, improved yield, new product development) . lit. COSTS These costa are based on estimates of Che 1970 waste volume. A. Immediate Costs ` ' 1. Cose of converting the present dump Into a seml-land-fill operation .......... $31,000. - - - ............. - .......................... -.................. 2. Coat of operating this land-fill until hole ia depleted - $10,000/yr. 3. Cost of fence for securing present site and for sufficient srea for five (5) years in future, $35,000. A. Clean-up area - $2,000. . B. Lanr Bantr Carrs (Based on 1970 Volume) 1. Opcr.ting costs per year (excluding drum cost) - $10,000. :md At l . QSW 013325 M. a. HuUally Tsrk Ferre Oitirtvc ADAD21-003772 HARTOLDMON0033728 c 0 C JJ 0u --< < XI a >> U -I 9a XuI J3 9 ow u o 0 cu a 0"* a -h tj XS a bo *a xai Cu a x9i ba 99 xi X -- Cn M9 3 WXZ ox b 03 -C o- -- 0 04 -H XI 9 I^ a >* X co n i u s. 52 OSW 015369 ADAD21 -003773 HARTOLDMON0033729 "'!ap*SE ADAD21-003774 HARTOLDMON0033730 nr . v'Oc S roauwj tc l* Director . Alabama Department of E nvironmen ta1 Ma r.agerne n t 1751 Federal Drive Montgomery, Alabama 36130 . 'x / Re: Monsanto Chemical Co., / Anniston, Alabama Dear Mr. Broadwater: On Monday, February 25, 1935, members General's staff met with representatives o Company concerning the finding by this off Cre<->; sediments. Tne level? four'.', in sc-e excess of 100ppm an.: were as hi.;n as 1 -: p t a pr.ro.xima telv 1-1 1 2 miles fro:- tne pl?..no ^ L.ic r.'-uuuicy Monsanto Chemical ce of ?C3s in Snow glad to transmit any of it whicn you mitht contact us cn what information vou want. We expect to meet with the company again, shortly and you or your representatives are invited to -attend. We will inform you of the time of our next meeting and cf further developments in this matter. Since c.nis matter involves potential litigation, we would appreciate your- office refer ring inquiries from Monsanto to this office and that your office do nothing which might jeopardise t.nis potential litigation. c c: David Ludder Charles Horn Dan Coooer r>Ori<*t" ivx o f: A9 ADAD21 -003775 HARTOLDMON0033731 I Figure 6. Site Location Map for the West-End landfill. 35 ADAD21-003776" HARTOLDMON0033732 II ;*p?n \L .. jj.iA : pre^h ; . ./ y, , /ifr-r> $u*4z) ^ Sh&^> (-AU-ia. f*C&S - fli^s-vu, fA-A,h . m-4 4 rf~L- 7" a/' y^L; ( 7/^1 . ^ -- -------- ~2? 1 (j-iMu~^ ere A4-/ ( /^-- A~6-0 'j ' ' Q.yJ^. CbJ. _ , r^ c ^Lca La hi-- {a/Lc) - CX--iK cCa-Az*. (P^~ {-(_, ~st-A\ ^Sf-XsA pv\JLsA~ ^tjn-- 0^ {M* //u. A'aJA -4-Usi.t*6/j c/jA _ 7^1>v. Ap PPi4U*P AA~cAi--_ -- &-''' A ^ L/XX-&A. ^ C.A{ ^{~^X /^f --'--X+At /f~^?7^f {($^\ f~^~ hs-e*s-t$. ; V-J> . ftr4o HA Jijt'u jA H-c 1^ { u>AoL~ /<> ~z. fp jL^-t^A-i aA^ ^jdgSSSSZSP^Ao-'~<P^zAp&a!, '^-ugjb ) t0SS5^ A XJ Ck /Vu- ^ ^ ^ A-tA y^\^--u> ^ ' JT-' {A/ /n^ 5 /Zc>- r/ <cc^j J pc^- A M J .-X(,Xs ; CkW tX-^J s^X / ^ c[a ZZ Sr-O M< . ,. / ,, ~Hcj i^J- _y4-AtAr^^, A>-eZA\A hS /iS-^t+xAt - UsZsit JLAaJs^ iA-QU-' >^C* J--X-/ 6tl~t / --/ /Ah-^S- ^ AhA?(Jl j LO^ P- . tz) J/ >^Cx_ A'uL^f six^eJA' Uhetnt - <u4**zt vz ^/ tl&nS frz-<zA> pp%^ ' 0000152 y //OOd<INO----------;----------rr- . OtX^cAi /{AAA/ /'/' 64-^ r^~ aAxs ^ AeJ Q^cl AM^Urr/ 'c'zy' CaX~{ r^'y rA^u ^ nlj- ^ C<^AAaA {{jl^. i/j^UL{ cAcjA' / Z-r ^7 HA c*ju>At Cu^. m,-/ /- , ,y ^/-'1 upt ,; y^-cC/. w.<_^c-tx.yv^ i <ij ;J, 6C/M i 4- j ,r ,/. 44-1 S e*'.('-', ; A yTc-c^, .;/ z/ z.'. t-i 4 Q^yjy-L~s-<JL AAA /' 0':Ha{)^ * ^ -KJ_t~. ^ i' i`y/-r--'___ yZ '^h 1 iLo : /^.y c - r. ;_ O ADAD21 -003777 HARTOLDMON0033733 lb jtPmj\Jr**")*??--' pi^^cus/pL*. -jjA$k,^^ c-T-i^-h A^*~ n^.Jlrzfd.--cy>------------tisA-A ("v-l-u f*\i-ot \ C-^oCKi< lock.a Cl/; //i2s<^<<^~- Ajs-^s-A*/ f/~*- d* sP> /sr'L C^tL 'M~l A^Jf--jf jrnsxC-^n-, lyk j\-^~ctXC<s/--^ y4-- CP-- J- ff~ sAP^i- fi-cA b*d~ j\Jl^yCuffis- SK. hs/P''' / u 'Ir'-Jul frA 1^. uj- &LP fXs-^J- V pT<T ~f7-*J^*X "J /*!, r&y* 0k /k frjJ A ^ Z/$ A ^ f/h tSi^fl SJT <3--PC // LXj^vXjlA. f~bz-C~ 'PCas\ LV-&\/k -^J^aaPJ CtA-iACLs* iPtx/ `US' pc fil. /r-e AA&Xl c<M fif uyb-tr^ umAP ^j/tUjX/U pCi~ Lj_lXX lv-sla^C' . V si A ., t f /? f Js Cy-aAr sis^A P'fX -V un/i-L -- . PC-tir j 5 hsb ^j/P j h&-y j PCa. cTrTi- t5 Jfhbz-o^pj_J. y-- os^^-ct^ ^yyP-cJ. a_J pC/t f-U^c UsiZX "ft &-L jyiu^'U-Z^ tfC/5 &s-~ tS^a'AA/s '. C\ ^aSssxsJLl. (jr^~ L. jjUx^zhJ, nr--r ,v, 0000152 I "' ~f. . 1 A AAr fy^^rjuj fX// yo--vx- #-<.aaJ Lcfij/ '7fi / / -t^u-u-r r-yi*U*CLfL^xA IA A ipA-A PCaP 4o*_ ly?^U- LM_ JL^vLXj.A Jl/aJ^ -h . U ^ ^i?o-Ji (yA/Xfi , pC-aP tu-J. At/ // jfrdi-zJ fi&t~lj j^ftuJ $ jr^/ffiz>--, X^~f 1 u>&<s-/J /L-aJ /-A sCsiAgsu^-- UAfi^X/ bat^s ~tu dr^. A- b yVL^. <e-t^_ j-/j siezJjuA t^Xs^,yC" uj-^ O-'IjJP- A ^yV'-JUpi r A-ffA. /A t- A awfif iAJ/Pb !&&) 002 Ty- '*- i >J,................i U, Kl/) ^ O j S i / V' 0 ,/v ^.?yp si Pi, /PcrO \ COR y1" 7 . 7- . ^c-, AzJ- X 1 At /l^-'XXt LxA xP LJJU 6-Aj /WE*Si l, / / Jr- ,.t{ no G4 C 13 0/S J-f X. O.c , lM , /fit <* 4. A & i-y AzxJ j. 1 ^- <s- i sx^ywlys}- {h-A.1 C/jP /A /u^<u< d' 7 D'n Cr, PcS J ^ / *. ADAD21-003778 HARTOLDMON0033734 jn. Jvc-t'-' fk QlS U ~ J ` - J i r~ r V (7 "+ A. a Jt^~ _ -?LcC-l / 'a Jt1 4-i i **-' <> > * - ' '--***--"-- v -- - /. Hj- yCX^ S*t*n iyi .a /. / Ctf-An ^ AU/^-' Uj Pl\ J$T d--X JLu-Hy-- ^7" o ypL, / C /- / *A --4-iA'i' ^ /"/" yl-<P-T~*y-CA /'y\\SL^~ /l^v &y 7^-' /A/ yv^/^i ''-j' ) Cc ' / it. /-? d^\ i~ 7>lijt ^Iy'sk^cP. to# i) pjx^j L/,juM$or. (XX-tJs Q<2-m ^ -------f-----f-----------*-------------- H'-'JbzU. tAeif/i fAtfw* WtAY. ?~c&$ b*lotJ U^J. pc.vf * I $kpw* r<*' ^^ <4*^ ts>re^ - r^$;{su^'k - &<c.' OV^- <l.`^ 'tv'xJ'W". GOR 3. i*'S Q 4 C i,- 0-^3 ADAD21-003779 HARTOLDMON0033735 fiG-flSafilO t vSC*'- G. y. filler - Anniston, Alai. Hay 7, 1970 Axcciaa iOLunriQN AWIC CONTACT u. u- jessss i. C. Laadvehr S. L. Williams ?. 3. Hodges - G.0. W. 3. Fapagecrge - G.O. F. J. Ho 1 rapfel - C.G. J. R. Savage -G.O. S. V. John - C.C. J. H. Grove - Deca cur E. G. Wright plaintiffs exhibit 'Py?mi>>=L On May 6, Messers. J. C. Lundwehr, E. G. Wrighc and I visited Mr. J. L. Crockett, Technical Direcror or che Alabama Ucer Improvement Commission, in Montgomery. The purpose oc che concacc vas twofold; fine, co familiarize Mr. Crockcct with Che sicuacion regarding Aroclor waaces and cheir reported pollueian pocencial and, secondly, Co build confidence chzc Monsanto intends to cooperate with governmental agencies Co define che effects of Aroclor on che environment. Hr. Crockecc and che AVTC staff were totally unaware of- che published information concerning Aroclors. Copies of che most pertinent articles describing che sicuacion along wich Mr. Minckler's statements were provided for his use. Additional information supplied covered che following facts: 1) Monsanto la currently investigating independently and in cooperation with governmental agenti the pocencial ecological effects of Aroclors. 2) Investigation and research programs are underway at Anniston to identify, quantify and develop techniques which would control product losses to the environment, 3) Any Aroclors reaching the watershed from the Anniston plant were entering Snow Creek, 1) The produc tion process was described In general detail co point out chat water was noc esa.encial co production of Aroclors, and waste water was produced only by auxiliary equipment such as steam jets, etc. Mr. Crockett was moat appreciative of Monsanto's approach co the problem and che fact chac Monsanto came co him. He alluded chat our action would produce a situation chac was beneficial co che protection of both the Konsanco and AWIC posittiona. `is recce endatlons were as follows: ..1, _ Supply..the AVXC wl_ch a general process description detailing pocencial Loss sources. ............................... ................. ~ ~....... ~ 2. Continue co develop information and as major items develop intorm -the-- AKTC_ ' Giva no statements or publications which would bring che sicuacion co the public's attention. ' X sppro-scMcM by nsrvs cisibc? AWXC qtt Monsanto ts free co scace ch_ t che situation Is under stud/ by Che staff of AWIC at Che direction of che Technical Director, Mr. Crockett. If in the future, information is developed Indicating chac Aroclors a. e detrimental to watersheds, Monsanto will be required co secure = permtt from AWIC co aLLow certain maximum quantities of chlorinated biph-nyl to enter Sroo Grech. QSW Q 1^0*98 ADAD21-003780 HARTOLDMON0033736 C. L. Jcaaee -2- May 7, 1970 In aumnwry, Mr. Crockett vaa noticeably unexcited *e our discloaure and all hia remarks were direcLad toward a careful awal.uaLion followed by action* a* required by data. The full cooperation of the AWIC to reach the above objective on a confidential bati* can be anticipated. It mutt be Tract-be-red, however, that all *WIC actiona are' aubject to atatc . political preaaurc and federal control. /ba HONS 09953V ADAD21-003781 HARTOLDMONOQ33737 3- 9 4 3 -3 6 8 0 OZMZT MSO ADAD21-003782 HARTOLDMON0033738 , 4 l c / v ----------------C / * V . I ^77? ? UNITED STATSg ENVIRONMENTAL PROTECTION AGEM<~v N - wr'J- * ` . ...... WASHINGTON. O.C. 2C4T --- -------- '- OCT 17 1.97C " orrtct or avasctMcrr Hon**uca.-Industrial Chaaicalt Cocpaay SQQ K. Llsdbesrgh Sovilsritd . . Sc. Laois, Missouri 63166 Centleaea: QCT 221^3 Secant govetnaantal sacplisg data indicate the presesee of Polychlorinated Siphenyls (?C3a) end coaparable eheslcxl substances is the eir, is. water bodies, end in fish is several ereee of the country. Is order to determine the nature esd extent of the possible adverse effects resulting froa the presence of ?C3 compounds is the environsear, the Isvfronseatal Protection Agency (E?A), in cooperation with other federal and State agencies, is atzeap dag to. deteraiae the sources end sconces of ?C3s entering _ the esvironaent. It is iaporcaac that this effort be carried out without delay. .. - It is our understanding Chat your esspany handles PC3 ceapcuads a? aiaturee or coaparable cheaicsl substances in its operations. I aa therefore requesting, pursuaat to the authority provided by Section 308 of the Federal Water Pollution Control Act. aa aseaded, 33 TT.S.C. 1313, and Section 114 of the Clean Air Act, as aeended, 42 IT.S.C. 1857c-9, that your ccapany furnish cPA with inforaacion pertaining to your use and handling of PC3s and coaparable chenicai eubscances. In addition to a general description, which ahould include inforaacion as to sources, quantities, uses, and ulciaace disposition, you should respond in detail to the enclosed questions. If any question is not applicable to your conpany or operations, p-lease so indicate by " "reaponding "not applicable."-. ` ` ...................... - - - The inforaacloa requested herein ause be provided notwithstanding its passible characterisation as confidential inforaacion or trade * secrets. tShould you so request, however, any inforaacion (other than * effluent or eafasion data) which the Adninistrator of this Agency ' deteraines .to conatltuta nethods or processes entitled to protection .x aa trade secrets will be oaincained as-coni idee till, pursuant to procedures specif^&d la, ~G CT% ?s.rh X* xOn OOdZ^Q 213 ADAD21-003783 HARTOLDMON0033739 2 -- Within 14 davs of receipt of-this' letter. your con?any a; "provide 212 lasOfSidea eanearaiag your currant status and activities and covosi-j rS*'cwlvB.aoac!i period tmediately preceding receipt of ,,xi2r*iactos.. - - .. . . Within 30 days folladng receipt of this letter, your cocpany susc provide ell inforaecion for ail of - the prior years indicaced. " The infamadou, required herein should he sent directly to the address indicated helov. If you have any questions you nay cell the person indicated below or Hr. Slake A. Biles of our office niiC2az:.-755-*71I. We appreciate your prenpt cooperation in this natter. Sincerely yflurs. Enclosure Segional Contact: <. Hr. Sari J- Stepurnl,v& Director, Eaforceaeat Division Znvizocnencal Broteczinn Agency 1715 Baltimore- tiniai Ciry, Hisaeuri 64108 Telephone: * *(815) 174-2576 for Eniornesent .x l- / AflM 00o9L 214 ADAD21-003784 HARTOLDMON0033740 c s*- FT71TCSL3RIKATT3 3I?KiyfL (?C3) COMPaCTCS OR MlXTgFw* - -- - . ... . ****<- I I I MIN I I 1X1 I --- r"7`' ffithin 14 day* of receipt of this lesser, your company oust provide <11 isfomaciaa concerning your current status and activities ewT^toveringthn.evolve month period teediately preceding receipt of til* latter. - " tfithia 30 days following receipt of this letter, your coopmy neat provide ell information far ell of the prior years indicated. for furposts of this lct, the phrase "pcs cohpqoko or KDCTCRE*' INCLUDES. AM. CHEilCAL SU2STAKCZS HJOWi OR 3ELIEVED 2T TQU TO JE ?C3 COMPOUNDS OR HECTRES OR OF A SBGIA2. CHEItICAL HATERS, IRRESPECTIVE OF TRADE'lSfcs, AMO STSCTTICALLT TNCITUTNC)C CHLORINATED T:~-.?cSynS. ' - . 1. For each. PCS compound or mixture grTfucsd or *'--by your company, for eech caspeny facility, during eech year of 1971, 1372, 1971. 1974, and the first two euerters of 1975: _ e. The total mount of eech PCS csapeund or aixtura produced or deported. ` '. . b. The cere and addre** of eech of your company'* facilities which handle FC3 compound* or mixtures* (including production facilitie* end wholesale end retail outlets), end the - ** mount of eech ?C3 compound or mixture di*crihuced through eech fecility. C. The name end eddreas of each cuatoner of eech ?C3 esspound or mixture, the mount of each PCS eenpound or airture . obtained by eech cu*coaer free each facility, end ..each...... ^.^.tuetjipe.pj.eodelivery'jxiinzxC*) 'dar-thr-receriph'-'Of each''PCS'' cocpound or airture. ;' 2. For each PCS compound or. mixture incorporated by your cospeay data it* products, for each coopany facility, during each - year of 1971, 1972, 1973, 1974, and the first two quarters of 1973: ' - . a, A description of each product.' b. . For each product the total anouat incorporated of each ' FC3 cocpound or mixture. i aQH 006292 215 ADAD21-003785 HARTOLDMON0033741 TT _ (continued) \ ' ^ for each produce Chenone and address of each source from : . whiciTyour coapany obtained each PC3 compound or nixeura. . ad the ssata: sf eiti ?C3 coapound or nixture obtained fraa ' each source. d. The nane and address of each of your company's facilities vhich handia such products (including production facilities and wholesale and retail outlets), and the aaount of each produce distributed through each facility. . __ a. The nane and addrest-of each eusconer of each product, and j , the''aaount of each product obtained by each custoaer froa ! . each facility, for consuaer products list only the total production of each product ac each facility and the total nunber of custcsers. Do not provide the aaae aud addresa. of- each custoaer of coaauser products. - . 3. for each ?C3 coapound or aixrara used by your coapany in its operacions other chan for incorporation into its product*, for each coapany facility, during each year of 1571, 1372, 1372, 1374, and tha firat two quarters of 1375: ` a. A description of each use. b. for each use the total aaount of each ?C3 conpound o: nixture. c. for each use the nma and addresa of each source frea which.......... s ;.isach%Sp3.'_coapound oc-nixture,-. and. the^-w..-. * aaount of each ?C3 coapound os nixture obtained frea each ` source. . . 4. For each ?C3 coapound or sixcure reelaiaed by your conpaay, far e'aeh coapany facility, during each year of 1371, 1372, 1373, 1374, and the first two quarters of 1375: . e. A description of each B*tho<i.af reclaastlon. hi -for each nethad of reclaaacion, the total aaount of ' each PC3 coapound or nixture reelaiaed. ' %. * c. The total aaount of each ?C3 coapound or nixture reclained. AO* 006233 215 ADAD21 -003786 HARTOLDMON0033742 /- V r A. V I 1 c -d. ~ 72 The" name isd address of each sauree from which your company obtained ?C3 confounds or mixtures, sad the taeuac af each ?C3 compound or mixture obtained-from bach source. ' ~ * .. . 5. . . .* * For each, method of rerlsmscian, the location of every reclamation cits, tha Base and address of each parry . involved in Che reelaaadoa of each PCS compound or . six cura, and the amount of each ?C3 compound or mixture reclaimed by each parry. p ' For each ?C3 campound or mixture disposed of by your company Cwirh or without rhe involvement of other parries), for each company facility, during each year of 1371, 1372, 1973, 1374, and Che first cvo quarters of 1375: , . *- A. descripcioa of each method of disposal. ' ^ b. For each method of disposal the total amount of ieach PCS - csspousd o? ^lTturg c. Tha total amount of each ?C3 compound or mixture disposed. The am* and address of each source from vhich your company obtained PCS compounds or mixtures, and the amount of each ?C3 compound or mixture* obtained from each source. V'P' 'A e. For each method of disposal, the location of every disposal ' site, the nans and addresa of each party involved in the disposal . of each.2C3. compound or..mixture,, and. the amount, of eacn-2C3.._ . ^ ^ '^*^c=mpcuhd'_'dt-'nihrure`'2Tipos-ed "Tif*-8y* eatS!`party7`` ' **k' " .* 6. The composition by chemicxl name and percent by weight of each PC3 compound or mixture ---print-rd. imported, sold, reclaimed, used, * and/or. disposed a by your company since January 1. 1971. ` ,,x7. The result! of any and all sampling-sod analysis performed by your company, its agents or contractors since January 1, 1971, concerning tha following: '" , a. Concentrations of ?C3 compounds or mixtures in the effluent 1 of any discharges by the compacy (into waters of the Ccited States or Publicly Owned Treacnenc Vorhj) or in the emissions of the company into the air. AO* 00629V 217 ADAD21-003787 HARTOLDMON0033743 h Th'p.flow and/or casposieion of any discharges or srsissfsas ~ by"che caetyany (Into water* of the On lead State* or Publicly ' Owned Tca*caattc UorJca, or lata tba air) which contain Pa Z^~Z------ eoapomda or alxcuta*. * ' .. * . ... ; _ . c. . . Concentration*: of ?C3 ssspnrjads or aist-rs" is rscslvtag waters (both upstreaa and dovascreaa) of aay discharges by cha eospany which contain PCI conspound* or aixtures xnd concentrations of ?C3 coapouada or nixtures la che air-la Cha area of . Cha ccspaay. ;' . 3. The nechoda by which ?C3 compound* or uixeurt* are transported, to, by, xad/or frrn-your coupany,' including: .. *."' A description of each aechod of transportidea, aad ' che. fora la which PC3 coapouada or nintures are trans parted by each a*chad. Where different nechoda o tnns- ; porcxclon ere used at dlffereac facilities specify which transportation aechod is used at each facility. h. The naaea and addresses of all known transporters of PC2 . ectspouade or nixtures. .. 3. All occasion* Clrcludiag spills) of which you are aware oa which PC3 compounds or nixtures. have or cay have beea introduced laco .the envlromeac. Ia particular, describe such occasions insofar as they Involved ?C3 cat-pounds or aircures la their liquid state, as incorporated into dosed ays tens, or as incorporated into open ayacena. lor each occasion, indicate ease aad addreaa of "-party involved;' dates, tlna, aad`location of the discharge or-....... '-Spcii;" *xs'iu -aha't-"rsyd^ea'.rv"-' --'* - r . 10. X description of say adversa.health or eavironaental effects which you Vnaw or believe to have resulted froa che introduction of PCS coapouada or alztures laco che erwironaest. Indicate say specific occasion* including dates, tinea, locscions, asounta, ATI<4 aaffigi fOTfilv*^ fifjfsCtaS its Vwnvw- 11. Any snd. all ocher iafamacicn which you possess cancerninj: T^ic u__sc *nd disposal of PCZ cospouadt or alxcures* v,t* f i an -* AQM 006295 21S ADAD21-003788 HARTOLDMON0033744 f \ cc b - Tfca discharge s PCS sospounds or niacurea issa eha . avtconaeac. la addition to.- the above, ?A would appreeiaee receiving any ocher labors*eisa which you possess eeueeraiag;ch* discribucion and discharge of PCS conpound* or-.nixcuce* by sources ocher chan your eoapany, including your cctspany's eustwaers and sources. c 4t.i? . . **fV W4' ^ > t- iCH 0GoZ96 i 219 ADAD21-003789 HARTOLDMON0033745 0 !COA wtrn POTENTIAL HAZARDOUS WASTE SITE FINAL STRATEGY DETERMINATION REGION SITE NUM8ER I ,/ QOOOO 12 So File this form in the regional Hazardous Waste Log File and submit a copy to: U.S. Environmental Protection Agency; Site Tracking J System; Hazardous Waste Enforcement Task Force (EN-335)-, 401 M St., SW; Washington, DC 20460. j A. Silt NAMfc z'///v c. CITY / /V/V /L'' ' ' i 7* I. SITE IDENTIFICATION ; OL D. STATE A LA loo ! Jf-2 j E. ZIP CODE ^ r-\ '-i II. FINAL DETERMINATION Indicate the recommended actionfsj and agencyf/es) that should be involved by marking 'X' in the appropriate boxes. RECOMMENDATION MARK'H' ACTION AGENCY PRIVATE j A. NO ACTION NEEDED V 1 e REMEDIAL ACTION NEEDED, BUT NO RESOURCES AVAILABLE f____ fjf yes, complete Section III,) C. REMEDIAL ACTION (If yea, complete Socfion IV*) 0 ENFORCEMENT ACTION (If yea, specify in Part E whether the case will be primarily managed by the EPA or the State and what type of enforcement action ta anticipated-) . RATIONALE FOR FINAL STRATEGY DETERMINATION z. c-:'ezL. c on / / n oO(j$ /y P PL J/ / ah 5 -1n Ori / rxn\. P, c,, Jo ci A CASE DEVELOPMENT PLAN HAS BEEN PREPARED, SPECIFY 1 G. IF AN ENFORCEMENT CASE HAS BEEN FILED. SPECIFY THE THE DATE PREPARED (mo., dav, & yr,) 0 ATE FILED (mo., day, & yr)III. H. PREPARER INFORMATION j 1. NAME ! 1 k'm 0'^. *0- 2. TELEPHONE NUMBER 32 1<3 -(o o s | 3.DATE (mo., day, b yr.) i J/-;-/.1 o ? y> III. REMEDIAL ACTIONS TO BE TAKEN WHEN RESOURCES BECOME AVAILABLE \ Lis: all remedial actions, such as excavation, removal, etc. to be taken as soon as resources become available. See instructions j ior a list of Key Words for each of the actions to be used in the spaces below. Provide an estimate of the approximate cost of the remedy. A. REMEDIAL ACTION B. ESTIMATED COST C.REMARKS ^ ! ADAD21-003790 HARTOLDMON0033746 vvEPA POTENTIAL HAZARDOUS WASTE SITE LOG SITE NUMBER il NOTE: The initial identification of a potential site or incident should not be interpreted as a finding of illegal activity or'confirmation that an actual health or environmental threat exists. All identified sites 'vi 11 be assessed under the EPA's Hazardous Waste Site Enforcement and Response System to determine if a hazardou: vi' *e problem actually exists. SITE NAME "city ' (!/V/ J j -- i ' " ,- 1--:------------- ------------------------------------ SUMMARY OF POTENTIAL OR KNOWN PROBLEM 5 ; J H CC STATE -----------------------------------|7IP--3-5t , . .j L- /- io* J___ cT ^ 'T w iJ L C A Aj 0 f' 1 A--/y r' / ' ' /V ; r / TV.., . ,u c /V I. IDENTIFICATION OF POTENTfAL PROBLEM 2. PRELIMINARY ASSESSMENT APPARENT SERIOUSNESS OF PROBLEM 3. SITE INSPECTION EPA TENTATIVE DISPOSITION (chock approprtaro ltom(a) below) DATE OF DET E RMI N- I ATION OR ! COMPLE* | TION | ,, " RESPONSIBLE ORGANIZATION OR INDIVIDUAL <EPA. State, Contractor, Other) C<i T1 /T- _ - AIG HU ' MMEDIUM : ft\c.a, r/Lf'p^, r~y I I ffif-rS.70 "T j a. NO ACTION NEEDED t>. INVESTIGATIVE ACTION NEEDED ; REMEDIAL ACTION NEEDED 4. tNFORCEMENT ACTION NEEDED ERA FINAL StPATECY DETERMINATION (rhock appnyprleito item(a) boiow) tlO ACTION NEEDED --4 h. REMEDIAL ACTION NEEDED " R E ME bl A L ACTION NEEDED BUT - c' NO RESOURCES AVAU A' e ' '] ____ J. enforcement action NEEOED A case development plan PREPARED - ------ : (2) ENFORCEMENT CASE FILED OR \ '--1 ' ' AC-.INISTRAT1VE ORDER ISSUED 6. STRATEGY completed zra rofm i zu/u-i (iu/y) PERSON MAKING ENTRY TO LOG FORM DATE ENTERED ON LOG Ymo,day,yr) j2. T>1jNKNOWN /.: i N 1 -I \S*J n - ~ , /} ADAD21-003791 HARTOLDMONOQ33747 Q Pp/\ WLiM POTENTIAL HAZARDOUS WASTE SITE identification and preliminary assessment REGION beSITE NUMBER (to igned by Hq) \V_ 1 Qt NOTE: This form is completed for each potential hazardous waste site to help set priorities for site inspe etion. The information submitted on this form is based on available records and may be updated on subsequent forms as a result c f additional inquiries and on-site inspections. AGENERAL INSTRUCTIONS'. Complete Sections I and III through X as completely as possible before Section II (Preliminary aaeaeznenfi. File this form in the Regional Hazardous Waste Log File and submit a copy to: U.S. Envirc nmental Protection (ENm335)\Agency; Site Tracking System; Hazardous Waste Enforcement Task Force 401 M St., SW; Wash!___ ____T\r* nr\*ar\ A. SITE NAME AnN: t t;n plamt C. CITY j Ann isTi/* G. OWNER/OPERATOR (it known) t. NAME I. SITE IDENTIFICATION B. STREET;(or other identifier) lAnl till HVJV D. STATE 2.0 Z. LvLZT E. ZIP CODE I F. COUNTY NAMF Ala 3 Cal u o u n 2. TELEPHONE NUMBER M o N 3 A M TO C C fT.r f; /V / n. TYPt UP OWNERSHIP - D 3 31 1 11 FEDERAL CD2- STATE DD 3 COUNTY ^D4 MUN'C'PAL [3s PRIVATE ~'6 UNKNOWN I 1. SITE DESCRIPTION * A.':'( = /-A ~ r- LANH-t-L J. HOW IDENTIFIED (ia, citixan'a comp taints, OSHA citations, etc>) Eckaardt Report i L. PRINCIPAL STATE LUNiACT j 1. NAME s yAfh=l L A. PC z A /} C5T ,< ^ S J S 11.1 PRELIMINARY ASSESSMENT (complete (his section last) . A. APPARENT seriousness of problem i (DjI-HIGH CD2. MEDIUM " 3. LOW !U. Ptooti-h " ~ 14 NONE ITT^s" UNKNOWN K. DATE IDENTIFIED (mo,, day, & yr.J Oct 6 79 2; TELEPHONE NUMBER 'V-;.' ' " ' --* ^ ij B. RECOMMENDATION J I CD ' NO ACTION NEEDEO (no hazard) . CDi 3. SITE INSPECTION NEEDED ,i * TENTATlVfcLY JCMEOULEO FOR: ' Cj 2. IMMEDIATE SITE INSPECTION NEEDED ' I TENTATVLYSCHEDULED FOR: -------------------------------------------------------b. WILL SE PERFORMED BY: b. WILL BE RCRFORMED BY: `V~l A. SITE INSPECTION NEEDED (low priority) C. PREPARER INFORMATION 1 . N AME 7\l\s / :i J C1 tt- : u 1 l /A--4 '< 1 \ lyr' O --r " rc A. SITE STATUS 2. TELEPHONE NUMBER T T "j - (. ~ ~ III. SITE INFORMATION 3. DA |*E (mo,, day, 4 yr>) TAc-C. $? /77Y TOT^no-TM Continue On f\ ,r\ ADAD21-003792 HARTOLDMON0033748 Continued From Page 2 l ` V. WASTE RELATED INFORMATION (continued) 3. LIST SUBSTANCES OF GREATEST CONCERN WHICH MAY BE ON THE SITE (piece in detcendint order ot heiard). 1, Pee n, fo r- j'vj * a-r. 1 i'JC U ; r n : A. ADDITIONAL COMMENTS OR NARRATIVE DESCRIPTION OF SITUATION KNOWN OR REPORTED TO EXIST AT THE SITE. Dr-- Oner-1 ion / f h\~Y P' > - A/sf: /' /3~/j 5 Jvcpupz * py- /..r , y as.:- , . r- - /^n s rK&rfJj iv/^p j~h p-'S-cZ y/A s>~ L', ' iV; /f' A. TYPE OF HAZARD 1 . NO HAZARD 2 . HUMAN HEALTH _ NON-WORKER ' INJURY/EXPOSURE 9. ' poten tial HAZARD (mark *X') VI. HAZARD DESCRIPTION c. ALLEGED INCIDENT (mark 'X') n. natf o f incidInt (mo,,day,yr*) E. REMARKS ' -:y.. ' : . . ' V f " ** " - ' ' '' * ~ fx s- < A. WORKER INJURY _ CONTAMINATION ` OF WATER SUPPLY CONTAMINATION ' OF FOOD CHAIN =, CONTAMINATION ` OF GROUND WATER . CONTAMINATION * OF SURFACE WATER . . DAMAGE TO ' FLORA/FAUNA. * Si ~r<T,, / . VATK.-Jr CLfi'-t C~/rc\ OF 2 !\io' Ct-U< f4 1 0. FISH KILL ,, CONTAMINATION 1 OF AIR jl2. NOTICEABLE ODORS i 1 3. CONTAMINATION OF SOIL I i jll. PROPERTY DAMAGE - v' jtS. FIRE OR EXPLOSION J _ SPILLS/ LEAKINS CONTAINERS/ J,D* RUNOFF/ STANDING LIQUID5 j t 7 SEWER. STORM 4 ` ORAIN PROELEMS ? * " 18. EROSION PROBLEMS l__________________________- ____ ________________ t |l9. INADEQU ATE SECURITY 3 20. INCOMPATIBLE WASTES |zi. MIDNIGHT DUMPING other ( spectiy): 1 EPA Form T2070-2 (1 0-79) / U>5r 'Ccf \L- PAGE 3 OF 4 Continue On Reverse </ /" / ^ ADAD21-003793 HARTOLDMON0033749 SEPA POTENTIAL HAZARDOUS WASTE SITE SITE INSPECTION REPORT REGION SITE NUMBER fro * aaaitfn- d by Hq) ' A- :A GENERAL INSTRUCTIONS; Complete Sections I and HI through XV of this form as completely as poiiiulc. Then Use the infurina tion on this form to develop s Tentat;ve Disposition (Section 11), File this form in its entirety in the regional Hazardous Waste Log File. Be sure to include all appropriate Supplemental Reports in the file. Submit a copy of the forms to: U.S. Environmental`Pro tection Agency; Site Tracking System; Hazardous Waste Enforcement Tack Force (EN-335); 401 M St., SW; Washington, DC 20460. A. SITE NAME ' I. SITE IDENTIFICATION CTorer , _hjN P 4. a aTT AftN G. SITE OPERATOR INFORMATION 1.NAME / &a.i D~;li ia; V '2-C -- '6'."SrATE E. ZIP CODE ALA L 3. STREET 330 C C: fv[ P_t' /JV __ __ __ 4. CITY /V- L l t . /- i3 ~T~' / M. REALTY OWNER I N FO RM A TION'fi/ dilioront from Operator oi ait 1 . NAME uJg: rre'guH'tvnxwe---------------- cZAl AO -j a/ 2. TELEPHONE NUMBER 3 to 8. STATE 2J 6. ZIP COOE ' 3 L XO 2- 2. TELEPHONE NUMBER 4. STATE 6. ZIP COOE !. SITE DESCRIPTION -------------------------------------------------------- --J _______ y_A^Aj?rV3 J. TYPE OF OWNERSHIP A Am-- ', CH 1. FEDERAL 2. STATE ' ------------------------A--C---L--'-------, ' z~----P~ ' / Q 3. COUNTY Q 4. MUNICIPAL fv|^S. PRIVATE '.// A. ESTIMATE DATE OF TENTATIVE DISPOSITION (mo., dmy, it yr.) HHtHARER N FORMATION 1.NAME II. TENTATIVE DISPOSITION (complete this section last) B. APPARENT SERIOUSNESS OF PROBLEM 1 1 1. HIGH 2. MEDIUM E3 3. LOW llwfcMonvU^ ^ Mrrl. / 2. TELEPHONE NUMBER Q 4. NONE S. DATE (mo., day, Si yr.;, f3r ~ III. INSPECTIOI*1 INFORMATION A. PRINCIPAL INSPECTOR INFORMATION 1 . NA ME 'pA fi. _U-__ 3. ORGANIZATION 3 A_.-it- 2. TITLE 'c " .4 TELEPHONE NO.(area code St no,) __ At-A .3 /" 3. P AINSPECTION h riCiHANTS Pu&Ltr AfAL'W /.?[ VO" / > /slop ) -S* 2-672 ~ 1 . NAME 2. ORGANIZATION S. TELEPHONE NO. ` ' t v~ t. r~-~j " -y ^ ;; ' "'/J-.5-Ij /Jz A L Ar "P / sOr"l / /o / C. SITE REPRESENTATIVES IN T E R VI EWE D (corporate officials, workers, resident*; 2. TITLE a TELEPHONE NO. S. ADDRESS , J AjI* v:;\\ --L* " i:A, HgM. AJ. -/.ZS) W) L . K' ft*-* I ' A C N 1AM Tr\ fj i, W /-uZ u ; -j '( -e* ADAD21-003794 HARTOLDMON0033750 C ontinued From Page 2 C. PHOTOS 5. type of photos 1 ! O. GROUND D. SITE MAPPEO? g ?! b. AERIAL [lUeS. SPECIFY LOCATION OF MAPS: IV. SAMPLING INFORMATION (continued) 2. PHOTOS IN CUSTODY OF. ON IT j l A-7 h. L_A 7>\V o f=~ 1,CL. E. COORDINATES l. l^tituOE (deg.-min,*s ec.) "3 T , y c> N 2. LONGITUDE (deg.-min.-sec.) y^.T'F^ w A . Si T E iiAiUS V. SITE INFORMATION . 1. ACTIVE f7hcise inductrial or municipal sites which are being used for waste treatment, storage, or disposal on a continuing hosts, even if infre quently.) [ i 2. INACTIVE (Those sires which no longer receive wastes.) ! i 3. OTHER (specify): (Those sites that include such incidents like "midnight dumping" where no regular or continuing use of the site for waste disposal has occurred.) S. IS GENERATOR ON SITE' _ | ' NO ry[ 2. Y ES( specify generator's tour-digit SIC Code): 3=1 C. AREA OF SITE fin acres) D. ARE THERE BUILDINGS ON THE SITE? p '-NO 2. YES (specify): VI. CHARACTERIZATION OF SITE ACTIVITY Indicate the major site activityfies) and details relating to each activity by marking 'X1 in the appropriate boxes. "HANbKURYER 8. STORER C.TREATER D. DISPOSER 3. BARGE 4. T HUC K 8. PIPELINE 6.0Ther( specify): 2.SURFACE IMPOUNDMENT 3 . DRUMS 4. TANK. ABOVE GROUND 8. TANK. BELOW GROUND 8. O T H e R (specify): ! . FILTR A TION 2. INCINER A TION 3. VOLUME REDUCTION A. RECYCLING/ RECOVERY 9. C H EM./ PH YS./ TREATMENT t. BIOLOGICAL TREATMENT 7. WASTE OIL REPROCESSING 8 . S OLVENT RECOVERY 9. O TH E R (specify): M/I . LANDFILL 2.LANOFARM 3. OPEN DUMP 4. SURFACE IMPOUNDMENT 3. MIDNIGHT DUMPING 6. INCINERATION 7. UNDERGROUND INJECTION g, O T HER < soeci (y): E. SUPPLEMENTAL REPORTS: Tf the site falls within any ot the cat eg ories I i sled below, Si^iplemental R eports must be completed. Indicate which Supplemental Reports you have filled out and attached to this for.. 1. STORAGE i I 2. INCINERATION pv?l 3. LANDFILL Q 4. SURFACE IMPOUNDMENT ' I 5. DEEP WELL L.E I 6- phycTreatment j----------- ~ 5~A WASTE TYPE IZH 7- lanofarm 8. open dump Q . []H .9 transporter. 10 recyclor/reclaimer "` '' VIL WASTE RELATED INFORMATION (3-0. SLUDGE Q 4. GAS | B. WASTE CHARACTERISTICS SU CORROSIVE 3 2. IGNITABLE 3- 5- TOXIC fVl 6. REACTIVE I I 3. RADIOACTIVE Q 4. HIGHLY VOLATILE 0^7. INERT ! I B. FLAMMABLE l1 | 9. Q TH E R (.poet tv):_________ _____________________ C. WASTE CATEGORIES 1. Are records of waetee available? Specify items such as manifests, inventories, etc. below. Form T2C7C-3 (10-79 PAGE 3 OF 10 Continue On Reverse "Ooc Lsd t. .A/0 ADAD21-003795 HARTOLDMON0033751 . vwmiiiueu * ivut t-a&p * ____________________________________ VIII. HAZARD DESCRIPTION (continued) [^J B. NCN-WORKER INJURY/EXPOSURE I I C. WORKER INJURY/EXPOSURE f>?1 0. CONTAMINATION OF WATER SUPPLY [31 E. CONTAMINATION OF FOOD CHAIN I ! i F. CONTAMINATION OF GROUND WATER CN LiN1 E. - a-aj o " >LL , he; 1 I '/ t r ^ j. CONTAMINATION OF SURFACE WATER j ERA Form T2070-3 (10*79) "PXrf^.4- J-- PAGE 5 OF 10 Continue On Reverse - ADAD21-003796 HARTOLDMON0033752 '-o/m.-rucruj * turn o _____________ _____________ ____vm. hazard description (continued> '] N. FIRE OR EXPLOSION | | O. SPILLS/LEAKING C ON T AI N E R S/R U N O F F/S T A N 0 IN G LIQUID (\ | P. SEWER. STORM DRAIN PROBLEMS ! 1 Q. EROSION PROBLEMS P. INADEQUATE SECURITY | S. INCOMPATIBLE WASTES E PA F orm T2070-3 0 0-79) AGE 7 OP 10 Continue On Reverse ' ^r ADAD21-003797 HARTOLDMON0033753 C ont inued From Page 8 X. WATER AMD HYDROLOGICAL DATA ('continued) H. LIST ALL DRINKING WATER WELLS WITHIN A I/A MILE RADIUS OF SITE 1 . wL L 2. DEPTH (specify unit) 3. LOC A T ION (proximity to population/ buildln $s) 4. NON-COM MUNITY ('mark 'X') . 3. C OMMUN- ITY (mmrk 'X') 1. RECEIVING WATER 1 . NA ME rn 2- SEVERS [ 1 4. LAKES/RESERVOIRS 8. SPECIFY USE AND CLASSiFiCAT ON OF R EC El V ING vTa TERS 3. STREAMS/RIVER! s- T H E R (specify): ' S=== " LOCATION r SITE IS IN: nn A. tnc. * FAULT ZONE XI, SOIL AND VEGITATIQN DATA [Z] s- KARST ZONE Zj c- '00 YEAR FLOOD PLAIN [Z] O. WETLAND iZl E- A REGULATED FLOODWAY F. CRITICAL HABITAT G. RECHARGE ZONE OR SOLE SOURCE AQUIFER XII. TYPE OF GEOLOGICAL MATERIAL OBSERVED Mark 'X' to indicate the typefs) of geological material observed and specify where necessary, the component parts. 'X A.CVER9UPDEN X B. BEDROCK (specify below) X' C. OTHER (specify below) I . SAND \ :lai X 5. GRAVEL * xm. SOIL PERMEABILITY 1r j A. UNKNOWN Q] B. VERY HIGH (100,000 to 1000 cm/src.) ZH c- HIGH (1000 to 10 cm/scc.J -J 0. MODERATE (10 to .1 cm/so o.) E. LOW f.1 to .001 cm/Jec.) SI F. VERY LOW (.001 to .00001 cm/soc.) k O. RECHARGE AREA ---------------------------------------------------------------------------------------------------------------- ------------------------------------------------------------------------- ,____ LYES Z] 2- NO 3. COMMENTS: -Tost' "l O './, nte. ^VtlTSir 1' 1 I' ' t ,:/i j H. DISCH A RGE A REA '" " 5 ..i v ES : 2. HO I. SLOPE t. ESTIMATE OF SLOPE Jo 3. COMMENTS: 2. SPECIFY DIRECTION OF SLOPE. CONDITION OF SLOPE. ETC. - J.UiMtH OtULUGICAL DATA ' fpa Form 12070*3 0 0-79) PAGE 9 OF to Continue On Reverse ADAD21-003798 HARTOLDMON0033754 E PA Fc r2O70-3E (10 -7^TrNrrji^r ADAD21-003799 HARTOLDMON0033755 x X VXWX1 ij X Uil * socd*^ j o<*gr ttqm<v ctn<a). accurnr^ WA*.rt 5 0*<* **U*TiJ*T AITqw^T MQC4 charl.es a. graddicx ATTORNEY GENEHAl. STATE OP AUkBAMA January 22, 1985 ivi'CO^a* lo--m g 1 3a 13031 M.3130 Mr. Richard J. Mahoney President Monsanto Chemical Company 800 N. Lindburgh Blvd. St. Louis, MO 63166 ear Mr. Mahoney: RECEIVED iam " : 1985. >J n i ' ~ R.J.M. My office has made an investigation of Snow Creek in the Anniston, Alabama area near the location of Monsanto's Anniston Chemical Plant. . invest > ^ <3. L. VJ.A. O location indicate the presence of polychlorinated biphenyls (PCB's) in the creek sediments outside Monsanto's site in excess of 400 ppm (parts per million). These figures are well in excess of EPA standards of 5Q ppm. -Monsanto produced PC3*s at its Anniston plant for a number of years up into the 1970's. In view of the high concentrations of PC3'3 and the rather extended areas of creek bottoms contaminated by these substances I would request that representatives of your .company .meet. ...with, members., of .my staff, to. ..discuss . this .matter, as soon as passible. Arrangements for such a meeting should, be made by_contacting Assistant Attorney General Craig' Kneisel of my staff at (205) 834--5150. CAG: sw l/r---- / V-- CHARLES A. GRAD DICK ATTORNEY GENERAL QSU 015250 ADAD21-003800 HARTOLDMON0033756 1 Uffice Of The Attorne y General *L JAMCS R SOLOMON. JR. 0R1/T> ATTORNEY GENCRal H. Waro McMillan jr EXECUTIVE ASSISTANT Walter S. Turner CVRCT ASSISTANT ATTORNCT GCNERAL j<iwc Noaus iLDAQAHNtSTRATTVC ASSISTAl CHARLES A. GRADDICK attorney general STATE OR ALABAMA February 26, 1985 004- Q19 048 Mr. Joe Broadwater Director Alabama Department of Environmental Management 1751 Federal Drive Montgomery, Alabama 36130 r s l - Z 04 * VQ 2 AOMiNtSTRATive BUICO'NG 64 NORTm Union Street Montgomery. Alabama 3 130 area 4205) 834-5150 _Q / Re: 1 Monsanto Chemical Co., j Anniston, Alabama 7 Dear Mr. Broadwater: On Monday, February 25, 1 , -mmecmutbaecjr.so--Oui i-ne Attorney General's staff met with representatives of Monsanto Chemical Company concerning the finding by this office of PCBs in Snpw ^SCr.eefe.Lsedirnents. The levels found in some places were in excess of v4i)Qppm; and were as high asS^98ppm-tin sediments approximately 1'-1:t;1/2The analytical information on the samples is quite voluminus and we would be glad to transmit any of it which you might want. Please contact us on what information you want. We expect to meet with the company again shortly and you or your representatives are invited to attend. We will * inform you of the time of our next meeting and of further developments in this matter. Since this matter involves potential litigation, we would appreciate your office refer ring inquiries from Monsanto to this office and that your office do nothing which might jeopardize this potential 1 itigation. PLAINTIFF'S EXHIBIT I CC : David Ludder Charles Horn Dan Cooper ADAD21-003801 HARTOLDMONOQ33757 Li<y May 15, 1986 Industrial Branch Water Division Alabama Department of Environmental Management 1751 Federal Drive Montgomery, Alabama. 36130... .. ..... .. ......... Dear Mr. Moore: Please-find a copy of the proposed Snow Creek Sediment Removal. .Protocol attached for your review. We will discuss at the meeting scheduled for May 27 at 11:00 A.M. in Anniston. Call if you have questions. Sincerely, C------------------ Terry L. Brown Technology & Engineering Superintendent LETTER/sag Attachments cc Mr. Craig Kneisel ' PLAINTIFFS EXHIBIT )C3 DOCKET NO. 0000200 a unit of Monsanto Co^oa^y oggggi V.-/ tv ADAD21-003802 HARTOLDMON0033758 SNOW CREEK TRIBUTARY SEDIMENT REMOVAL Three sections of the drainage ditch ahd^Snow Creek are proposed for sediment removal. The sediment removal will consist of 4redging_and ^isjjosal .of .bottom sediments, which will also effectively deepen and improve the channel of the drainage ditch. This plan also proposes the installation of a culvert in Section 1 (described below). Section 1: Length of drainage ditch from sampling site 1 to sampling site 2. Effectively, this dredging operation will encompass the length of the ditch from the emergence of the ditch from the culvert under the Bethel Missionary Baptist Church to the culvert under Route 202, 10th Street. This distance is approximately 500 feet. Section 2: Stretch of ditch between the Southern Railway railroad tracks and 11th Street, from where the ditch passes under the tracks, to the confluence of the ditch and Snow Creek. This dis tance is approximately. 1200"to 1500 feet.' *. ' ` '. Section 3: Section of Snow Creek from the confluence to a point approximately 100 feet downstream. , Local authorities in Anniston will be contacted to arrange for necessary easements, approvals, and access rights to properties which wili be affected by the proposed dredging operation. The necessary contracts will be executed with an experienced contractor to carry out the proposed operations. All aspects of the operation will be funded by Monsanto Company, except for any analytical work done by regulatory agencies. The dredging will be done by an experienced contractor. The specific heavy equipment and the dredging procedure will be specified to the contractor. The creek bottoms (sediments) will be dredged to a depth of approximately 12 inches or to bedrock and to a width defined by the width of the water in the ditch and creek. The dredging operation should proceed in a downstream direction to minimize recontamination by resedimentation of particulate material suspended during the dredging. The dredged material is to be deposited on the creek bank for dewatering. (The dewatering is anticipated to take two days at the most.) Following dewatering the dredged material will be loaded and transported to a secured area at the Monsanto Company landfill. The material will be stored at- this location only long enough to sample the dewatered sediment and to perform analyses to determine the average concentration of PCBs. (See below.) . DOCKET NO. 0000200 After the dredging operations in the three sections of the drainage" dlLLb'and------ - Snow Creek have been completed, the ditch and creek bottoms will be sampled in accordance with the sampling method developed for the 1985 program. Sairoling sites will be selected to roughly correspond to sampling points 1, 2, and 3 of the original protocol, with an additional point to be sampled in section 2 of dredged ditch, between 11th Street and the railroad tracks. These samples will ( ADAD21-003803 HART OLDMON0033759 Page 2 be shipped to the Environmental Sciences Center, Monsanto Company, St. Louis, MO., for expeditious analysis to verify the results of the dredging operation. This laboratory will be notified of the dredging schedule, to ensure that the analyses will be done as soon as possible. Results will be communicated by Monsanto Company to the Alabama Department of Environmental Management and thg Alabama State Attorney General's office. Split samples will be made available to either agency upon prior request. Verification that .the_residuaL.sediinents. .riv ^Ln-pthe ditch and: Snow Creek contain less than:.5:0vppm"PCBs"will signal,,successful completion of i- the dredging ^operation. Following acceptance of the results of the dredging program, no further action will be taken at sections 2 and 3 of the dredged ditch. The dredging will have accomplished an effective channelization of the ditch and Snow Creek, which will improve the water carrying capacity of the waterways. However, in section 1, a concrete culvert will be installed to completely enclose the ditch from its emergence from under the church to 10th Street. The culvert will be covered with backfill and seeded. Completion of this operation is predicated upon receiving proper approval from the landowners along this section of the drainage ditch. The dredged materials will be transported to a temporary storage site at the Monsanto Company landfill site. "The site will be' a level'section to eliminate risk of downhill migration of the stored material. The stored material will be covered with polyethylene sheeting or some other water-impervious material to prevent runoff, in the event of rain, and dispersal by wind. The covering will be secured with sandbags to prevent lift off caused by wind. The temporary storage site will be inspected daily to ensure the integrity of the protective cover. The stored, dewatered dredgings will be sampled and analyzed by Monsanto Company to determine final disposition of the material. The sampling will be carried out in accordance with a scheme published in United States Environmental Protection Agency document EPA-560/5-85-026, "Verification of PCS Spill Cleanup by Sampling and Analysis." A 6 group compositing plan for 19 sample points, shown in .. the attached figure, will be used to statistically sample the dredged materials. The sampling plan is based on a hexagonal grid system, centered on the center of the stored sediments. The nineteen samples will be composited as shown in the figure. The six composited samples will be shipped to the Environmental Sciences Center, Monsanto Company, St. Louis, MO., for analysis for PCBs. Sampling will be done using 1" x 18" stainless steel core tubes, as described in the protocol for the 1985 sampling program. The labeling, storage, shipping, and quality assurance aspects of that protocol will also be employed during the sampling of the temporarily stored material. It is felt that this sampling protocol for the stored material will give a valid assessment of the PCS concentration of the bulk of the material. The dredging, loading, and dumping operations preceding this sampling should thoroughly mix the dredged materials. The six composited samples ultimately analyzed will therefore represent the bulk of the material. ,'The analytical results for the six composited samples will be averaged to determine the PCS concentration of the temporarily stored material. i ftU. orj')03 0000200 ADAD21 -003804 HARTOLDMON0033760 Page 3 The results of the analyses of the temporarily stored material will determine the ultimate disposition of the sediments. If the average PCB concentration of. the material is less than 50 ppm, the material will be moved to a cell at the Monsanto Company landfill at th Aim 1 St-Ljfi PlaSiC' rlf.the material is determined to contain PCBs.at an average concentration of ' .^greater-than 50 ppm, the^material will be treated as 'PCB-contaminated waste'. * Monsanto Company will arrange to have'^thV'material dispbsed'~of at an EPA-approved PCB landfill in accordance with all applicable federal regulations. The landfill site is anticipated to be the Emelle, Alabama landfill, operated by Chemical Waste Management. However, Monsanto Company reserves the right to make other arrangements with an alternate permitted disposal site, if necessary. Proper certificates of disposal will be obtained to verify the ultimate disposal of the sediments. : In either case, a few inches of soil from the temporary storage site will be included along with the dredged material, to ensure that no PCB contaminated soil remains at the temporary storage site. Since the PCB concentrations of the sediments during the dredging and trans- porting operations will be unknown, prudence dictates that"all equipment ' involved in these operations be decontaminated in accordance with Section 761.79(b) of the federal PCB regulations. This decontamination involves swabbing surfaces that have contacted the,sediments with a solvent in which PCBs are soluble to at least 5% by weight. Kerosene is one such solvent. The excess solvent and any mops, rags, etc. must be collected and disposed of as PCB contaminated material. . The dredging and transporting operations should not involve personal contact with the sediments. Normal precautions should be exercised. If the sediments are contacted, the affected body parts should be washed thoroughly with soap and water. Affected clothing should be laundered. Sampling the temporarily stored sediments will probably involve contact with the material, including climbing on the piled dredgings. Personnel involved in this sampling should wear protective gloves, protective clothing, and boots. Since this will be an open air procedure, respiratory protection will not be necessary. If the protective clothing is of the disposable type, it should be collected and disposed of as PCB-contaminated material in accordance with federal regulations. This disposal is precautionary, since PCB contamination of the clothing is unlikely. An MSDS for polychlorinated biphenyls is attached for information on occupational control procedures. 0000200 OOCKET NO. ( ADAD21-003805 HARTOLDMON0033761 tiiQfisanio STtaAlTY ZHIM1CMS UVKIOK Mon*4.tto Chemical Company A LM at Momma Company 300 flfandnqtmil I8gtwiay tonluon. *.`8tiama 30S01 Oflto: (206) 230-0301 f April'15, 1988 tfu&i&y bcci. J. L. Brown R. L. Cheever M. R. Foresman - G4WT ' . Honorable Donald Siegelman Attorney General State of Alabama . 11 South Union Street Montgomery, Alabama 36130 Dear Attorney General Siegelman: Thank-you very much for taking time from your busy schedule to address the Alabama Chemical Association and have dinner with us on March 23rd. It was also a pleasure to see you again March 29th at dinner with our government relations group from Monsanto. I applaud your efforts to attack the drug problem in the state and wish you continued success. You made a statement at the Alabama Chemical Association with regard to working with the Attorney General's office to resolve environmental issues that struck a responsive note. In January 1985, the Attorney General brought to Monsanto's attention a matter of polychlorinated biphenyls ;;{PCB's)., in the^sediments v of: Snow Creek downstream of Monsanto * s Anniston;' `Alabama site. In February 1985, representatives of Monsanto met with members of the Attorney General's staff to discuss the findings and plan a course of action. Additional discussions were held in March and April with both the Alabama Department of Environmental Management (ADEM) and the Attorney General's office to develop a mutually acceptable sampling program to define the situation. In May 1985, a sampling protocol was proposed and on June 18, 1985, the " sediments were sampled by representatives of Monsanto, Attorney DOCKET m. 0000299 On October 2, 1985, a meeting was held with representatives of the Attorney General's staff, ADEM, and .EPA Region IV to review the results of the sediment sampling and plan the next course of action. The EPA stated that they would defer anv action to ADEM. It was agreed that Monsanto wo.uld submit a proposed clean-up plan ipp ruvai. uGR 000000'A PLAINTlFrs EXHIBIT AhL * Iss*s%. ' A !`-uu'tu ly Q4 b ANN 1155176 ADAD21-003806 HARTOLDMON0033762 Honorable Donald Siegelman Page 2 .. . April 15, 1988 ................................... . This proposed Snow Creek Sediment Removal Protocol was discussed with and transmitted to representatives of the Attorney General's office and ADEM on May 27, 1986. The representative of the Attorney General said he would push to get approval of the plan, from EPA and others, and would be back to Monsanto withina week with any necessary changes. tAs.,yet, this matter is;stillopen. Monsanto believes that the proposal represents the best resolution of original concerns and Monsanto would like to complete the program in 1988. We are available, at your convenience, to meet with your representative and representatives from ADEM to discuss this matter further. / Please feel free to contact Mr. Jerry Brown at 205-236-6381, extension 206 or Mr. Robert Cheever at 205-236-6381, extension 292, if there are any questions that need to be addressed. We look forward to meeting with you and ADEM on this matter. Sincerely, David K. Denner Plant Manager LETTR3/sag cc Leigh Pegues, Director ADEM 0000299 0000002 : A LOO AO 19 OA 8 ANN U551V ADAD21-003807 HARTOLDMON0033763 Agncuiiur* Sail Conservation S**ve P. 0. Box 311 Auburn, Alabama 36330 C>-*. Hovember 14, 1983 Mr. Jerry Brown Monsanco Agricultural Products Co. P. 0. Sox 249 ' Anniston, AX. 36202 Dear Jerry: This letter confirms plana for a meeting at 10:00 A.M. on December 5, 1983, to discuaa the reaulta of the PCB sampling on Chaccoloceo Creek. The meeting will be in the conference room at the Soil Conservation Service State Office in Auburn. _ .~ Please bring any information you nay have on the sampling. After discussing the findings we will also discuss possible methods for disposing of any contaminated sediment, should that become necessary. If you are unable to attend or need any additional information, please call either Vic Payne or me.- Tour3 Truly, -v Asst. State Conservationist cc: Tarbit Henry, Auburn SO Henry Miller,-Auburn SO Vic Payne, Auburn SO Mason Dollar, Auburn SO Dave Kelly, Auburn SO PENGAD-Bayonne.MJ. Hi# So* Coorv*iiort 3v*c* > vt jqtrtcy o* tn 0*9rtf*nr of Aqr'cuifiir* OS* 024504 ADAD21-003808 HARTOLDMONOQ33764 PLAINTIFF'S EXHIBIT Lo ,,\ri Sco^Ct 5 a. Az* k-~ i---- Zy ky 1`----./ i-6 -/J'-fT-e>f^f J2-Yi- JI^/- /z<? 7L-L/ -T2^ ;f^ 7/y- Sf5-6-j^x-0/ m -*- 5 - C, -i? SS-02--4I toO ' - * 5- - if ~tf -oi-o) io<, ru/ * S- c, - if-fs -Ci-ai 9<? lo$ 5-F3 -c -is-ss-effriotj ,,, /g^ s* rr- /$ - - -fC/J/aS / 07 /ot /ai Jr 5- - /* -ir ~ oq -l <? f /^Z- yo Mo /V[> /V) *1Z.3 yp i09 26( ST i *> till -- , -* t '* / #0 J/D 7 J-J J2.*3 ' //0 /*o / Z-- /<?.J J". x- y.c. /-7-T'Y-? Aso 3-/ T..O x/ r i -C .' (s'~k(,) ton to<j - -- *Y tj" a/o 05w O24506 ADAD21-003810 HARTOLDMON0033766 Snow Cgggfe S<^rii wont- Samole I.D. ' S-6-13-85--01-01 S-6-18-35--02-01 S-6-18--85-03-01 S-6-18-85-04-01 S-6-18-35-06-01 1177 524 io _ 923 NO ND xrn ND PCB 1248 (ipl 1266 ND St UV-f `Oil ND #r c 88 W 190 288 33 7 <lt 5.3 K r^ 3.1 ;.y 2.0 jii.** ~ Total 714 1211 //*" /OLT 121 12.3 tX ^/ % /. JrZ. 1.3. ti/ 5.1 /c. > OSM 024507 ADAD21-003811 HARTOLDMON0033767 ADAD21-003812 HARTOLDMON0033768 March 16, 1983 PREPAREDNESS STATEMENT Anniston Plant PCS Incident We have been advised that the Soil Conservation Service : has found relatively low levels (low ppm range) of Polychlorinated Biphenyls (PCBs) in 8 of 22 core sastples of sediment taken from Choccolocco Creek in the Anniston area. The sampling was done as part of advance prepartion for dredging the creek. The creek River. Monsanto's Anniston plant formerly manufactured PCBs ceasing production there in 1971. Plant officials are assisting the Alabama Department of Environmental Management and the Conservation Service in developing a sound technical plan designed to enable the dredging in an environmentally acceptable manner. PCBs are oily liquids with the consistency of mineral oil. They were and still are used mostly as insulation fluids in closed-system electrical equipment. Prior to 1970, when it wes confirmed that they resist biodegradation once they enter fKe ^ fKmu wave nemj f|nfl| flf Othf? applications such as heat transfer and hydraulic fluids and carbonless copy paper. . It is now known that PCBs are ubiquitous in the environment, i.e., they are commonly found in small trace amounts in many rivers and streams. HONS 019321 ADAD21-003813 HARTOLDMON0033769 V, -1~ . For these reasons, it would b unproductive to try to identify the source of the FCSs in Choeeoiocco Creek, especially since the creek readily accepts surface water runoff from aueh of the City of Anniston. -0O0Notai See attached Monsanto position statement which addresses the toxicity and health effects of PCSs. MQNS 019322 L k ADAD21-003814 HARTOLDMON0033770 ADAD21-003815 HARTOLDMON0033771 Monsanto February 7, 1980 MONSANTO AGRICULTURAL PRODUCTS CO. P. O. Box 249 Anniston, Alabama 36201 Phone: (205) 23B-5381 Mr. Darrell A. Baker, Public Health Engineer Division of Solid Waste and Vector Control Environmental Health Administration State of Alabama Department. of Public Health Montgomery, Alabama 36130 Dear Mr. Baker: FEB II 3980 & VECTOR C'wiNiHOL In your letter of January 31, 1980, you pointed out two concerns which require attention. The first of these was a wash in the north end of the parathion - contaminated waste disposal area. This wash was repaired as soon as possible after it was de tected which is our normal operating procedure. The second concern involved the drums of material. As dis cussed when you were here, these drums contain mixed polyphenyls, a high melting solid. This material was brought from our Newport, England, plant during severe raw material shortages. Changes in the market demand left us with an excess, therefore, all was not consumed as a raw material. During the past weeks we have been evaluating various methods of disposal. As dis cussed when you were here, we have -contacted-Cherpioa 1 Waste .......... Management about accepting this material, and they have agreed to dispose of it if we choose tt-iq The second al ternate under consideration is to utilize this material for its fuel value. The evaluation of this alternate is not com plete at this time. It is now estimated that completion of this evaluation and final disposition will require approximately three months. The polyphenyls are insoluble in water and will not fall under the category of hazardous waste. During our meeting on January 10. it was my understanding that we would receive written approval of the sites chosen for place ment of the monitoring wells. As of this date, we have not heard from Mr. Moser or you on this matter. a unit of Monsanto Company ADAD21-003816 HARTOLDMON0033772 Mr. Darrell A. Baker Page 2 F- oKr*n*<a-..*r. Tjr r - 7f 1 QQW Vfi If you have questions or require further information, please contact me at the above number. Very truly yours, ^^r2^3'`r' ^ ____ ><Ferry L. Brown ' Plant Chief Chemist JLBrsaa ADAD21-003817 HARTOLDMON0033773 riUG$3ntu iN*M( A LOCATION Anniston - 1060 Ext 235 April 27, 1984 ' cc R. L. Cfteever - Biological Detoxification Tests -f'UCNCt TO . - J. L-. Brown The biological detoxification testing of chemically contaminated process items has been completed. The purpose of these detoxification tests was to: a) verify the feasibility of biological detoxification; b) confirm the effectiveness upon different process chemicals and items; and c) establish the ultimate contact time to achieve desired reduction in contaminant concentration. Two separate controlled tests were conducted according to the procedures as described below. Test 1 Test 1 involved the controlled immersion of intentionally contaminated carbon steel pipe. Two pieces of used, rusted, carbon steel pipe, one-quarter of an inch in diameter by two feet long were intentionally contaminated. One test piece was soaked' in a 1% solution of ethyl parathion for two (2) hours. The second test piece was soaked in a solution of p-nitrophencl (PNP), also for two (2) hours. The test pieces were then removed from their respective solutions and left to air dry for 24 hours. The next step involved removing a portion of each test piece and analyzing for ethyl parathion and PNP respectively. Following the determination of original contaminant concentration, the test pieces were immersed in the wastewater treatment aeration basins. There, they were subjected to seven (7) days of direct contact with the biological activity going on in the basin. After this seven (7) day immersion, the test piece was removed from the basin, washed off, and air dried. Another section of analyzed for ethyl respectively. The following page. each test piece was then removed and parathion and PNP concentration, results of this test are as shown on the PLAINTIFFS 1 EXHIBIT | qjO From Beginning To End, Think Safety and Win. ADAD21-003818 HARTOLDMON0033774 J. L. Brown Page 2 April 27, 1984 PNP Contaminated Test Piece Initial Concentration 108 ppm Concentration Followina 7--day Immersion - 4l ppm % Reduction >99 Ethyl Parathion Contaminated Test Piece 4 0 ppm 1.25 ppm 96.6 Test 2 Test 2 involved the controlled immersion of actual items dismantled from the manufacturing facility. Miscellaneous piping, grating, valves and minor equipment, which had been removed from the parathion manufacturing area, were placed into the detoxification basket. Two items were selected as control samples from the total amount of material to the detoxified. The test items were a piece of floor grating and a length of one-half (h) inch diameter pipe. A section of each control piece was removed and analyzed for initial total organophosphate contamination. All items in the basket including the test samples were then immersed in the aeration basin. Following seven (7) days of immersion, the basket of items was removed, all parts were washed and allowed to air dry. A section of each of the control items, grating and h pipe, were analyzed for concentration of total organcphosphates. The results of this test are: Grating V Pipe Initial OP Concentration Final OP Concentration 280 ppm 4 ppm 5.14 ppm 0.17 ppm % Reduction 98.6 96.7 The following conclusions can be made from the above results. 1. Biological detoxification of chemically contaminated piping and miscellaneous process items is feasible. ADAD21-003819 HARTOLDMONOQ33775 J. L. Brown Page 3 April 27, 1984 2. Detoxification is effective on items contaminated with ethyl parathion, paranitrophenol, and total organophosphates. 3. At least seven days immersion should be the guide for single pieces or for large groups of pieces. /sag Gene L." Arnett ADAD21-003820 HARTOLDMON0033776 Monsanto Agricultural Products Company Anniston Plant AP S02 Hazardous Waste Management Monsanto Prepared by Anniston Staff December, 1981 First Revision By R. L Cheever November, 1984 Prepared by: rflGGffGEfTIEnTG TRGID)77G SYSTEfTlS for industry, inc St. Louis, Mo. This manual is for the sole use of Monsanto Company, Anniston, Alabama and any other use is strictly prohibited. ADAD21-003821 HARTOLDMON0033777 CONTENTS Monsanto Anniston AP S02 Hazardous Waste Management Page 1.00 PREPARATION 3 1.10 Scope 3 1.20 Learner Objectives 3 1.30 The Importance Of The Objectives 3 1.40 Supporting Materials 3 1.50 Assumptions 3 1.60 What To Expect 4 1.70 How To Use This Workbook 4 2.00 ABOUT HAZARDOUS WASTE fcjAKi Ari jpiit IVIMINMOCIVICIN 1 5 2.10 What Is Hazardous Waste Management? 5 2.20 Why Is Proper Hazardous Waste Management Important? 5 2.30 What Is A Hazardous Waste? 5 2.40 Characteristics Of Hazardous Waste 6 2.50 Listed Hazardous Wastes 7 2.60 Hazardous Wastes At Anniston 8 3.00 ON-SITE METHODS OF HAZAR DOUS WASTE MANAGEMENT 13 3.10 Treatment Of Hazardous Waste 13 3.20 Storage Of Hazardous Waste 14 3.30 Disposal Of Hazardous Wasta 14 3.40 Containers And Labeling 15 3.50 Inspections And Records 19 4.00 EVIDENCE OF HAZARDOUS WASTE MANAGEMENT 24 5.00 CONTROLLING HAZARDOUS WASTE 25 6.00 EMERGENCY PLANS 26 7.00 SAFETY 27 8.00 AVAILABLE REFERENCE MATERIAL 28 9.00 FEEDBACK 29 PRACTICE ASSIGNMENT NO. 1 PRACTICE ASSIGNMENT NO. 2 PRACTICE ASSIGNMENT NO. 3 10--12 17 -18 21--23 in pi 1(84 mRnRGEmErtT s TRRinmG SYSTEmS Workbook ADAD21-003822 HARTOLDMON0033778 Monsanto Anniston AP S02 Hazardous Waste Management 1.00 PREPARATION 1.10 SCOPE This training workbook covers the management of hazardous waste materials generated at Mon santo's Anniston Plant. 1.20 LEARNER OBJECTIVES By studying this workbook, the learner will achieve the following objectives: 1. State the definition of hazardous waste. 2. List what hazardous wastes are managed at the Anniston Plant. 3. Characterize the hazardous wastes. 4. Acquire a working knowledge of how hazar dous wastes are managed. Identify the equipment and controls us managing hazardous waste materials. 6. Recognize the availability of reference material related to managing hazardous waste materials. 7. Become familiar with plant personnel responsible for proper hazardous waste management. 8. Review the preparation of documents and records pertaining to hazardous waste management. mRnRGErnEnr IMpll/84 9. Incorporate the safety considerations of managing hazardous waste materials. 10. Draw a flow diagram tracing the manage ment of a particular waste from the point of origin to the disposal site. 1.30 THE IMPORTANCE OF THE OBJECTIVES As in all other duties performed at the Anniston Plant, safety is the first objective. Therefore, Ob jective No.9 should be foremost when managing hazardous wastes. Objective No. 10 is a way to show the proper management a given waste material should receive from the time it is recognized as a hazardous waste until it is suitably disposed of. Objectives 1 through 8 are supportive of each other since each enables us to better understand and carry out the task of managing hazardous waste materials. 1.40 SUPPORTING MATERIALS The following materials are recommended when training on hazardous waste management: Learner Materials Copy of this training workbook (AP-S02) Note paper and pencils Instructor Materials Copy of this training workbook (AP-S02) Chalkboard and chalk Copies of specific handling procedures (for reference) 1.50 ASSUMPTIONS To get the most out of this training, the learner should have reviewed the following: APO-SOI "Anniston Plant Overview" Plant and Area Safety Manuais Employee Handbook Safety Handbook Workbook 3 ADAD21-003823 HARTOLDMON0033779 2.00 ABOUT HAZARDOUS WASTE MANAGEMENT In the remaining portions of this workbook, we u/Mj jearn what hazardous wasto roanaQsmsnt Is; how hazardous waste management is performed at Monsanto-Anniston; and why hazardous wastes must be managed in a certain way. 2.10 WHAT IS HAZARDOUS WASTE MANAGEMENT? To help answer this question, let's think for a mo ment about the type of plant in which we work. We know that, during daily operations, a variety of raw materials are used to produce various in termediates and commercial products (finished goods). Many of these raw materials, in termediates and finished goods are classified as "hazardous materials". Let's think a minute and try to answer these questions: 1. How do we manage or handle these hazar dous materials? . 2. What are the procedures, steps or methods used? Some of the way we manage these materials in clude: storage; transportation; processing; and packaging. The procedures used to accomplish these various tasks have been well documented such that raw materials are converted to finish ed commercial products in a safe, straight forward and cost effective manner. The same should hold true for the proper management of Monsanto Anniston AP S02 Hazardous Waste Management hazardous wastes. Hazardous waste manage ment means: ``the systematic control of the col lection, source separation, storage, transporta tion, processing, treatment, recovery and disposal of hazardous waste". Therefore, the management of our waste should receive the same degree of attention as our management of any other hazardous material. 2.20 WHY IS PROPER HAZARDOUS WASTE MANAGEMENT IMPORTANT? Hazardous waste management is important for a number of reasons. The two most important reasons are as follows. First and foremost "it is the law". The law was passed to provide stan dards (regulations) for which all facilities generating wastes must meet. These regulation are to protect human health and the environment from the improper management of hazardous wastes. Improper management of hazardous waste materials has already accounted for major environmental upsets in other areas of the nation. lued adherance to thr legal requirements will minimize the potential for additional adverse impacts. Secondly, Monsanto has a corporate ob jective to, "conduct our business at all times in an ethical, lawful and socially responsible man ner". We, as a company, have the obligation of protecting ourselves and the community against any ill effects stemming from our operation. Pro per hazardous waste management is only one of the ways in which this can be accomplished. The importance of hazardous waste manage ment, as it applies to the Anniston Plant, can on ly begin to be fully expressed in a training workbook of this type. To "put it in a nutshell'', the future continuing operation of this plant may very well depend upon our ability to develop and maintain a program encompassing the proper management of hazardous waste materials. 2.30 WHAT IS A HAZARDOUS WASTE? This section is not intended to make you all ex perts in what constitutes a hazardous waste. It is intended to show that all wastes generated at the Anniston Plant must be fully investigated to determine whether or not it is a hazardous waste. The definition of a hazardous waste is very com plex. Therefore, the following is a attempt to pro vide a simplistic version of this very complex definition. Essentially, "a hazardous waste is a 1rlpll/84 mnnRGEmEDT G TRRininG Sndustijm SYSTEmS isBSbBSS Workbook 5 ADAD21-003824 HARTOLDMON0033780 Monsanto Anniston AP S02 Hazardous Waste Management could be classified as hazardous wastes because they exhibit the characteristic of corrosivity include: Sulfuric Acid Caustic . Thio Acid PCT Mixer-settier Overfiow HCI Scrubber Discharge Reactivity A waste exhibits the characteristic of reactivity if a representative sample has any of the following light properties. First, it is normally unstable and r/"i o H J l\ / i uau11y ft r\ m r.. ... uiiuci y^co nvii/vsli/d^niil vi icu lyv - \viivitmhriv\iuiti detonating. Second, it reacts violently with water. Third, it forms potentially explosive mixtures with water. Fourth, when mixed with water, it generates toxic gases, vapors or fumes in a quantity suf ficient to present a danger to human health or the environment. Fifth, it is a cyanide or sulfide bearing waste which, when exposed to pH con ditions between 2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the en vironment. Sixth, it is capable of detonation or ex plosive reaction if it is subjected to a strong initiating source or if heated under confinement. Seventh, it is readily capable of detonation or ex plosive decomposition or reaction at standard temperature and pressure. Eighth, it is a forbidden explosive as defined in49CFR 173.51, or a Class A explosive as defined in 49 CFR 173.53 or a Class B explosive as defined in 43 CFR 173.38. Examples of plant materials that could be classified as hazardous wastes because they exhibit the characteristic of reactivity include: P2S5 extract is analyzed to determine whether it possesses any of the toxic contaminants iden tified in the National Interim Primary Drinking Water Standards (NIPDWS). If the extract contains any of the contaminants in concentrations 100 times greater than those specified in the NIPDWS, the waste is considered to be hazardous. 2.50 LISTED HAZARDOUS WASTES In addition to the four (4) characteristics used to determine if a particular waste is hazardous, the EPA has developed lists of solid wastes that they have classified as hazardous. The listing of these wastes is based on one or more of the aforemen tioned characteristics. Nonspecific Sources The listing of solid wastes, which are hazardous wastes, from nonspecific sources is a generic listing with reference to no particular type of in dustry. One example of a listed hazardous waste applicable to the Anniston Plant is "The follow ing spent non-halogenated solvents: Xylene, Acetone, Ethyl Acetate, Ethyl Benzene, Ethyl Ether, methyl Isobutyl Ketone, N-butyl Alcohol, Cyclohexanone and Methanol; and the still bot toms from the recovery of these solvents." Therefore, the still bottoms from the acetone recovery column, at the PNP department, is a listed hazardous waste. Specific Source Thg listing of solid wastes which are hazardous wastes from specific sources is a listing of par ticular wastes from specific industries. Current ly, the Anniston Plant has no specific sources on the list. Discarded Commercial Chemical Products, Off-Specification Species, Container Residues And Spill Cleanup Debris The EPA developed the Extraction Procedure (EP) Toxicity test as a means of simulating the tendancy of the constituents of a waste to migrate out and become available to contaminate the en vironment under poor management conditions. Under this procedure, constituents are extracted from the waste by the EPA methodology and the mnnHGrmsriT This listing includes a wide range of materials which can be segregated into four (4) specific categories. The list of commercial chemical pro ducts is extensive and reference will only be made to those currently used at Anniston. The following materials or items are hazardous wastes if and when they are discarded or intend- Workboo 7 ADAD21-003825 HARTOLDMON0033781 hazardous wastes and the waste number which should be used for identification. Hazardous Waste Waste I.D. No. Benzene And Contaminated Debris U019 Acetone Recovery Column Bottoms PNP Fiber Drums PNP Contaminated Trash - F003 U170 U170 Limestone Bed Influent Parathion Contaminated Trash Methyl Parathion Contaminated Trash D002 P089 P071 I fI wyv/Muj oynCrl Iodr>aG+llQC CoZ (VwV UoOeItWo mI IIUIVI IWI thII'aUtI icto nI ntl in(Iifo'l'wtitHvr-f ed in one of the above categories, you should con tact the plant environmental control department for listing instructions. Monsanto Anniston AP S02 Hazardous Waste Management 1H pi 1/84 mnnRGEmEnT G TREUnmG srsTEms Workbook 9 ADAD21-003826 HARTOLDMON0033782 3. State the definition of solid waste and hazar dous waste. Monsanto Anniston AP S02 Hazardous Waste Management 4. List the characteristics of a hazardous waste. npn/84 mnnRGEmEnt SYSTEmS Workbook 11 ADAD21-003827 HARTOLDMON0033783 Monsanto Anniston AP S02 Hazardous Waste Management 3.00 ON-SITE METHODS OF HAZARDOUS WASTE MANAGEMENT Three (3) specific methods for managing hazar dous wastes are in use here at the Anniston Plant. The methods include treatment, storage and disposal. To get a full understanding of the management steps involved, take Fig. 1, "Waste Management Flow Diagram", and lay it alongside the text. Looking at the diagram, we can see that the proper management of waste material begins with the "generator". Through the everyday ac tivities of operating and maintaining our plant facilities, we are all potential generators of waste. For whatever reason (spills, maintenance, opera tions, general housekeeping), when a material becomes a waste, the generator is responsible for initiating the proper steps for disposal. Looking at the flow diagram, we can see that the generator has five (5) options available for waste disposal. The first step the generator should take is to determine if the waste material is hazardous fi(OcaOaP .U.C....O....k...l.l.a.../.l..I Z^_.O' A\). Ti hinito* ucn^iiiiii iquo 11 hi ianso ai i cau y been made on most of our waste materials, (see list in Section 2.60). If the material is determined to be non-hazardous, the generator would simp ly place the material in one of the dumpsters (skiffs) designated for non-hazardous waste. If the waste material is determined to be hazar dous and of a non-routine (first time) nature, the generator shall contact the plant environmental control department. The environmental control engineerwill assist the generatorin selection of the proper management route the waste material will follow. An example of a non-routine waste is the spill cleanup of a raw material. Routinely generated hazardous waste materials that are non-liquid are normally disposed of onside. The generator has two options available for managing these materials. The wastes (con taminated trash, trench cleanings, sample bot tles, filter media, etc.) are either placed into departmental dumpsters (skiffs) or into individual drums. The preferred routing is into dumpsters. Unuseable empty PNP fiber drums are disposed of on-site as individual containers. These fiber drums should not be used to contain any type of waste. They must be disposed of as empty containers. Our routinely yenerated liquid hazardous wastes, which are amenable to biological waste water treatment, are treated in our industrial waste water treatment plant. Wastes disposed of by this method include: still bottoms from the Acetone Recovery Column; HCI Scrubber Water; and Mixer-Settler Overflow. Normal process waste water including washdowns, cleanups and cer tain other de minimus losses are also treated on site. However, normal process waste waters are not considered hazardous wastes. Finally, any liquid wastes which are not biologically degradable (Benzene, Cumene, etc.) which nr'tor>r'aii'' ^-qhIH ho nonoratori must be disposed of off-site. Also included in the off-site disposal routing would be large accumulations of empty PNP fiber drums or any other abnormally large accumulation of a specific item. Waste oils which are not hazardous wastes are included in this off-site disposal route. 3.10 TREATMENT OF HAZARDOUS WASTE The waste treatment facility at our plant is second to none in the pesticide industry. The facilities ability to biologically treat liquid waste streams with extraordinary efficiency allows us a con siderable amount of flexibility In the disposal of certain organic materials. The majority of the treatment takes place within the aeration basins. These basins are concrete tanks either above ground or partially buried and are therefore ex empt from hazardous waste regulation. However, the first step in the treatment train oc- 1r1p11/84 mRHRGEmEn t G TRR/n/RG industty? srsTEms Workbook 13 ADAD21-003828 HARTOLDMON0033784 ticular source of waste". The generator's production department name and number shall be entered in this space. The "date of generation" shall reflect the date the container becomes filled. Hazardous waste should be placed into containers as soon after generation as possible. However, its date of generation does not commence until the con tainer is full. The "description and class of waste" should con tain a brief description of the materials and the EPA hazardous waste identification number(s) which best describes the potential hazards. As an example: ' Trash contaminated with organophosphates from the production of parathion-EPA #P089"(See list of wastes and EPA numbers in Section 2.60) The "total quantity of waste" should be a realistic, reasonable estimate of the weight of all the waste materials in a particular container. The "number and type of containers" states how many and what type of containers are being us ed to contain the waste material. The "date of packaging" is the date the con tainers) is (are) ready for pickup and disposal. It may also be the date the manifest form is com pleted by the generator. Under"comments on particular methods of treat ment, storage or disposal of waste, if any", the generator should note the location of the waste materials to be picked up and any other ap propriate comments. Underthe heading"quantity and type of waste for disposal", the generator should list the materials and the approximate weight of each, if there are several different waste materials being picked up. Under "particular location within a disposal site", the area within the landfill to which the waste material goes should be stated here. At present, three (3) cells are being used in the landfill (See mu ra '*-i> "Kiviioan^ ii uI a^iniUHMftilil uPcaiilulr")) Ti h11owry/ ccumo.1 Monsanto Anniston AP S02 Hazardous Waste Management 3E Non-hazardous chemical waste 4E Most hazardous wastes 5E Contaminated sulfur The final generator responsibility is for the per son filling out the waste disposal record to sign beside "Generator's Signature". After signing the record, the generator contacts material handling to schedule the collection and disposal of the waste described on the record. The response from material handling may not be immediate, however, under normal circumstances, pickup will be made within 24 hours of receipt of call. The material handler will go to the generator to obtain the disposal record. They will not transport wastes unless the record is completely filled out. After obtaining the disposal record, the material handler will pickup the waste container(s) and carry the waste to the landfill. The material handier shall sign the disposal record next to "signature of person who deposited waste in landfill" and enter "date of disposal" to reflect the date the waste materials were placed in the designated landfill cell. Finally, the material handler will forward the completed waste disposal record to the plant environmental con trol department for required recording and filing. 3.40 CONTAINERS AND LABELING The type of container and the amount of labeling required will depend upon the ultimate point of disposal. Wastes being disposed of on-site may be placed in containers which do not necessari-iy meet DOT requirements. Labeling for on-site disposal does not necessarily have to meet DOT requirements either, however, all off-site disposal requires adherence to the DOT regulations. On-Site Disposal The recommended container for hazardous wastes being disposed of on-site are dumpsters (skiffs). The use of dumpsters is the most cost effective and easiest to manage. Each production department has at least one (1) skiff suitable for hazardous waste, conveniently located to the nor ms! points of wssts Qsnsrstion. Dumpstor losds 1Mpi2/84 //IHl /HUEHIErlT s TRfi/ninG systems Workbook 15 ADAD21-003829 HARTOLDMON0033785 PRACTICE ASSIGNMENT NO. 2 1. Stste the methods used et Anniston for managing hazardous waste. Monsanto Anniston AP S02 Hazardous Waste Management 2. Describe the generators responsibility in managing wastes. (Draw your own flow diagram if you wish.) inpii/84 SYSTEms Workbook 17 ADAD21-003830 HARTOLDMON0033786 Monsanto Anniston .... AP S02 Hazardous Waste Management 3.50 INSPECTIONS AND RECORDS We learned earlier that proper hazardous waste management means "the systematic control of the collection, source separation, storage, transportation, processing, treatment, recovery and disposal of hazardous waste". As with any control system, whether for waste management or production, there are procedures to be follow ed. These procedures require the inspections of the processes and the recording of our observa tions. In hazardous waste management, we have "procedures to prevent hazards" which require us to make routine inspections of various por tions of the process and record ourobservations. The following details the inspections and recor dkeeping required to verify the proper operation sw*\if /wMuiir kiic^u^_narr!ulru\iumo uwi/awotlinc miiianniiann^uAimiicnmnt laouiucs. Surface Impoundment i"m'i^nvnuunnHuimiioomnt neutralization basin used to partially neutralize corrosive (low pH) waste streams prior to biological treatment. The impoundment is filled with coarse limestone and is built below grade, in as much as this surface impoundment is an in tegral part of the waste water treatment system, the daily inspection of this facility is the respon sibility of the waste treatment plant operator. The operator (inspector) will tour the surface im poundment area looking for signs of erosion, rivulets, orslides on the side slopes and look for unevenness along the side slopes and edges. Adequate quantity of limestone in the basin will also be assessed. The neutralization sump will be inspected for signs of cracks, flaking, chipping and general deterioration of the structure and ap- purtament facilities. The neutralization sump numne oro /Ka/'l/aW tr\r nnar^+lnn Unl/nnA uiv. ui iwi wpciauuu, ocai icarvayc, piping leaks and excessive noise and vibration which could lead to premature failure. The sump level shall be measured and checked against the indicator to verify its operation and accuracy and the high and iow ievei alarms wiii Detested. Final ly, condition and placement of warning signs is observed and evidence of any housekeeping needs are noted. The inspectorshall initiate a maintenance minor repair order (MRO) if repairs are needed and record the MRO number on the inspection record. The inspection record, shown as Figure 7, is a mnnnGFmmr |?wsan| 1 rl pi 1/84 SYSTEmS two-part form. The inspector shall keep one copy for the department record and forward one copy to tfto environmental control department. These records must be retained for at least three (3) years from the date of the inspection. Container Storage Area The container storage area is located inside the Ag. Warehouse. This area and all containers in storage will be inspected weekly by a member of +UKICa Ani#irAmmAi"i + al Cl I V I I Ul II I IUI Itai /-<~i n + rr\ I Honorfmont uu^uiuuvni. Thfi !"I.iw t< spectorwill tour the area and inspect the floorfor surface cracks, flaking, chips, gouges and areas of excessive wear. The containment curbing will be inspected for cracks, chips, flaking, gouges, excessive wear and presence of iiquids. The building walls and roof will be inspected for evidence of rainwater leakage. The containers will be inspected for legible labels, tight lids and bungs, proper inventory, leaks and signs of cor rosion. The presence and condition of the bar ricade and warning signs will also be inspected. The inspector will fill out an inspection record, as shown in Figure 6, and place the completed record in the hazardous waste operating record file in the environmental control department. Landfill The landfill is inspected weekly, following a storm and during a storm which has a duration of 24 hours or more. The inspection is conducted by a member of the environmental control depart ment. The inspector tours the active portion of the landfill along the run-on and run-off control routes looking for: evidence of deterioration; sub sidence; erosion; rivulets or slides into the u.-J i cmi r-vlaa ysi ac aica, ao!iysitu-oa ui AoAc+u+nlirnryt <arH iuinndoWivonnni.fiCC' and confirm run-off collection system capacity. A sample of collected run-off will be taken to ascertain its nature and determine disposal route. The landfill cell dikes will be toured looking for slides, subsidence, evidence of settling, pooling of water and proper amount of cover to control wind dispersal. The leachate collection and removal system will be checked for proper pump operation, controller operation and integrity of the piping network. The condition of roadways and fence gates will be assessed for evidence of washouts, potholes, tampering and spills. All ground water monitoring wells (including those Workbook 19 ADAD21-003831'J HARTOLDMONOQ33787 PRACTICE ASSIGNMENT NO. 3 1. List the types of containers used to contain hazardous waste materials. Monsanto Anniston AP S02 Hazardous Waste Management 2. List the information required on any drum containing hazardous waste materials to be disposed of: on-site off-site mnm E Workbook 21 ADAD21-003832 HARTOLDMON0033788 5. Discuss the containerization, inspection and recordkeeping required of your specific i <-s K >1o juu cio 1+ ik nnr+oinr pcikanio + iv 10 iimciiuvuw tn/ooto ivagiv management. Monsanto Anniston AP S02 Hazardous Waste Management 6. List the individuals from whom you would seek help in managing your waste and tell why. 1 rl pi 1/84 mnnnGemenr s TRfiin/nc SYSTEmS Workbook 23 ADAD21-003833 HARTOLDMON0033789 Monsanto Annistun AP S02 Hazardous Waste Management 5.00 CONTROLLING HAZARDOUS WASTE MANAGEMENT To say that we have actual devices or instruments for controlling hazardous waste management sounds somewhat misleading. It is true that the waste treatment facilities and material handling equipment have specific controls. The point to be made concerning hazardous waste manage ment is that the majority of the control lies with each individual. Tying the management procedures directly to good safety and housekeeping practices more clearly illustrates where the real control is. Incor porating proper hazardous waste management in to the overall attitude of safety and housekeep ing suggests that using good common sense, along with sound safety procedures, can do much toward making the hazardous waste management program an equal part of the job. 5.10 wha i is Controlled? Logically, the first concern should be with the amount of hazardous waste generated. This is not to say that we can totally stop the generation of hazardous wastes. We can, however, take steps to minimize the amount. One problem area is placing non-hazardous waste into containers already con taminated with hazardous materials. The use of PNP fiber drums is a good example. If someone tainer that previously or currently holds hazardous material, the entire contents become hazardous waste and must be handled accordingly. When replacing lines, we can make efforts to clear them out before dismantling. This helps to prevent drainage or accumulation of materials that will then have to be disposed of. Again, we should note that washing some waste materials to the waste treatment facility is a viable means of disposal and gives us some control over the amount of material that has to be disposed of by other methods. ' Another area where we have some control is in determining the cost of hazardous waste management. The main point to be made is the use of dumpsters (skiffs) versus the use of drums. Drums are expensive to use, hold smaller amounts of material and are more difficult to manage. Remember, we've already stated that our landfill space is limited. 5.20 CONTROL SUMMARY We have established that controlling the amount of hazardous waste generated plays an important role in the overall program. By controlling the amount generated, we also limit the cost. By us ing the waste treatment facility, we reduce costs and conserve vitai iandfiii space. Developing a positive attitude toward hazardous waste management can do much to make the program successful. To state it plainly, we must properly control hazardous waste material if we are to en sure continued operation of our plant. Ifl pi 2/84 Him imjC/l/Ci 1/ S TRRininG SYSTEniS Workbook 25 ADAD21-003834 HARTOLDMON0033790 Monsanto Anniston AP S02 Hazardous Waste Management 7.00 SAFETY The safety considerations to be taken into ac count when managing hazardous waste materials are not very different from everyday practices per taining to materials used in the production pro cess. Handling instructions have been written for each chemical substance used in the plant. These provide personnel with information on the safest methods to use when handling materials. Using full face cannister masks when handling in termediate is a common preventive measure to pi vnoui aycm loicCMy/c/n Kuauiirn\ 1a0. t i ic ayau4iAoni + Inl mai ly i i+ I n Laum* ty of certain materials is known to most, if not all, personnel dealing with them. The fact that acetone, methanol, xylene, and other liquids are highly flammable demands that they be isolated from certain pieces of equipment and areas of the plant. Through our awareness of the characteristics of hazardous waste materials, we should be able to see that, to safely handle them, we need to apply the universal rule-take time to think "safety first". Anytime non-routine or emergency conditions exist, we know that, in order to prevent making the situation worse, we must consider the materials involved. The best handling method may not be readily evident, but by contacting key personnel we can gain a great deal of input toward finding that method. Keep in mind that "hazardous" is the key word. If a material is classified as hazardous, there is some characteristic of that material that must be considered before attempting to handle it. lrlpll/84 mRnRGEmEPT 8 TRRiniRG SYSTEmS Workbook 27 ADAD21-003835 HARTOLDMON0033791 Monsanto Anniston AP S02 Hazardous Waste Management 9.00 FEEDBACK In this section of the workbook, you will be ask ed to suppiy written feedback to the instructor. This will give you an opportunity to show what you have learned about hazardous waste manage ment. This is the time to discuss and obtain clarification on any topics that are not clear to you. Jot down any questions or points that you wish to discussed and forward them to the in structor. Be critical and feedback suggestions as to how the program could be modified to be of more benefit to you and your job. 1r1p11/84 rtiHriHutintriT G TRH/ninti srsTEms Workbook 29 ADAD21-003836 HARTOLDMON0033792 Monsanto Anniston AP S02 Hazardous Waste Management tn pVW84 Fig. 1 mnnHGEmenr G TRRIHinG SYSTEmS Waste Management Flow Diagram Workbook 31 ADAD21 -003837 HARTOLDMONOQ33793 Monsanto Anniston AP S02 Hazardous Waste Management HAZARDOUS WASTE DRUM OPERATING RECORD Source Of Waste(Department No.) DOT Container Type- Date Of GenerationDOT Labels Used- EPA ID No.Date Placed In Storage- Description Of Waste(DOT Proper Shipping Name) nHI1I U. v f Drums Volume Of Esch Drum (Gal) Total Weight (lbs) I certify that the above stated drums are either empty or at least 90% full (circle one) and have been labeled and packaged according to the latest DOT regulations. Generator Signature NOTE: Once drums are put into the storage area, forward one copy to the plant environmental control department and place one copy in generator department file. 1rlpi 1/84 Fig. 3 Hazardous Waste Drum Operating Record mRnRGEmEn t G TRRiniRG SYSTEmS Workbook 33 ADAD21-003838 HARTOLDMON0033794 Monsanto Anniston AP S02 Hazardous Waste Management LANDFILL INSPECTION RECORD INSPECTOR! ________________ WEEKLY/AFTER STORM/DURING STORM INSPECTION (Circle One) DATE AND TIME OF INSPECTION? AM/PM ITEM ACTION REQUIRED YES NO ACTION UNDERTAKEN TYPE AND DATE I. RUN-ON CONTROL SYSTEM - Checked for Integrity - Checked for Blockage - Checked for Clogging II. RUN-OFF CONTROL SYSTEM - Checked for Integrity . - Checked for Blockage - Checked for Clogging - Run-Off Collection Capacity - Sample Taken -- YES/NO {Circle One) III. LEACHATE COLLECTION/REMOVAL SYSTEM - Pump Operation - Controller Operation - component: xHteyii-uy IV. ACTIVE AREA - Waste Covered - Subsidence - Erosion V. SECURITY - Gate(s) Locked/Guarded - Fence Integrity - Warning Sign Integrity - Tampering VI. ROADWAYS - Washouts - Pot Hole - Spills VII. GROUNDWATER WELLS - Caps Locked - Standpipes Intact - Subsidence VIII. INACTIVE AREAS - Erosion - Cover - Subsidence - Vegetation - Drainage REQUIRED ACTION: (1) Contractor notified, repair to original elevation? Determine nature of liquid, dispose of properly; (3) Install sign, lock, chain; (4) Repair equipment to original state; (5) Clean-up and dispose of properly (2) 1f1p '1/84 Fig. 5 Landfill Inspection Record mnnnoEm^nT s TRR/nmG indnstip srsrEms Workbook 35 ADAD21-003839 HARTOLDMON0033795 * Monsanto Anniston AP S02 Hazardous Waste Management SURFACE IMPOUNDMENT DAILY INSPECTION RECORD INSPECTOR: ___________________ DATE: INSPECTION ITEM I. PHYSICAL STRUCTURES: CONDITION OKAY YES NO tIMb: REPAIRS NEEDED YES NO - Limestone Bed: - evidence of subsidence - bank erosion - good limestone level - flow being by-passed* - Neutralization Sump: - cracks in concrete ' - concrete flaking - concrete chipping - deteriorated grating II. MECHANICAL EQUIPMENT: - Neut. Sump Pumps: - pump operable - seal leaking - piping leaking - excessive noise or vibration III.. CONTROLS AND ALARMS: - Level Control: - working - level indication is _ -- -- -- -- -- -- ---- -- DATE MRO SUBMITTED MRO NO. - Alarms: - nigxi ie'v'ei WujLKiHy - low level working IV. OTHER: - Warning Signs: - in place - in good condition - Housekeeping: - painting - lubrication - clean up _ , | -- -- _ * If yes, why? 1. TRsrva^wfnwr-e- P-----n---n---v- 2. Environmental Control Copy Irlpil/M Fig. 7 Surface Impoundment Daily Inspection Record mnnnGEmtm e mamma SYSTEmS Workbook 37 ADAD21 -003840 HARTOLDMONOQ33796 VEHICLE INSPECTION LOG Monsanto Anniston AP S02 Hazardous Waste Management VEHICLE: INSPECTOR: _________________________________________ DATE: TIME:AM/PM NEEDS OK REPAIR ITEM Oil Level Brakes Parking Brake Air Pressure Leakage Test Warning Device Horn Lights Tires Leaks INSPECTION 1) Check engine dip stick for safe operating oil level. 2) Check transmission dip stick for safe operating oil level. 3) Check power steering dip stick for safe operating oil level. 1) Push pedal down; if it goes down more than h way to floor, brakes need adjustment. 2) Push pedal down hard and hold down and count to 10; if pedal keeps going down, have brakes repaired. 3) Drive vehicle and step on brakes; if vehicle swerves to side or anything feels suspicious, have checked. Stop vehicle, set parking brake firmly, and attempt to move vehicle, if vehicle moves, brakes need adjustment or repair. Check air pressure reading and record psi. With engine stopped and no brakes applied, observe gauge reading - loss should not exceed 3 lbs. per minute; apply full brakes for 2 minutes loss should not exceed 4 lbs. per minute (if loss exceeds limit, check out further). Must be visible or audible and operate at all pressures at or below 50% of cut out pressure. Test: Run engine at fast idle - time to raise pressure to cut out should not exceed 5 minutes. Teat to be sure it is working. Check to be sure all - headlights; emergency flashers; parking lights; turn signals; dash lights; tail lights; brake lights; back-up lights are working. 1) Check tire pressure with gauge for correct pressure and record values. , , , , > _____ 2) Check tire thread wear. 3) Check both sides of tires for bulges or large cracks in sidewalls. Check under vehicle for apparent fluid leaks from: radiator, transmission; differential; engine; fuel tank; brake line and cylinders. lrlpll/84 mnnRGEmEnT Fig. 9 Vehicle Inspection Log Workbook 39 l ADAD21-003841 HARTOLDMON0033797 1 rlpl ir84 FORK TRUCK BRAKES HORN LIGHTS WORKING? WORKING? WORKING? STEERING OKAY? PORK CONDITION OKAY? TILT LIFT DATE YES NO 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 YES NO YES NO Yes NO YES NO res NO i ! NOTE: All unsafe conditions must be reported to foreman. 1. Inspector Copy 2. Environmental Control Copy Fig. 10 / / /finfit9fniEHT s TRfurvnG sys ifms Fork Truck Daily Inspection Log Workbook 41/42 ADAD21-003842 HARTOLDMON0033798 PLANT: Monsanto-Anniston SO: Hazardous Waste Management TRAINEE: INSTRUCTOR: Hazardous Materials Generated Characteristics Of Materials Use Of Proper Containers Treatment Areas Storsjs Ar93S Regulations Equipment Inspection Records Manifest Preparation Landfill Disposal Cells Waste Management Personnel Emergency Plans Reference Materials Other Monsanto Anniston AP S02 Hazardous Waste Management Comments tr1p12/84 mnnftGEmmT s TRRiniriG SYSTEmS Fig. 11 Analysis Sheet Workbook 43 ADAD21-003843 HARTOLDMON0033799 Figure 6. Site Location Map for the West-End landfill. 35 ADAD21-003844 HARTOLDMON0033800