Document jN3gpxgywj5MGm2Qwx0va6QqO

STATE OF ALABAMA IN THE CIRCUIT COURT FOR ETOWAH COUNTY (Transferred from Calhoun County, Alabama) SABRINA ABERNATHY, et al., Plaintiffs, versus MONSANTO COMPANY, et al. CIVIL ACTION NO, CV-2001-832 (Consolidated) Defendants. / DEPOSITION OF CHARLES CHATMAN The deposition of CHARLES CHATMAN was taken before Deborah Salers Garrett, Certified Shorthand Reporter, Registered Professional Reporter, as Commissioner, commencing at 3:10 p.m. on December 28, 2001, by the Plaintiffs, at the law offices of Fite & Miller, Suite 400, SouthTrust Bank Building, Anniston, Alabama, pursuant to the stipulations set forth herein. Regional Reporting Service, Inc. 755 Walnut Street Gadsden, Alabama 35901-0755 3 1 STIPULATIONS 2 IT IS STIPULATED AND AGREED by the 3 parties, through their respective counsel, 4 that the deposition of CHARLES CHATMAN may be 5 taken before Deborah Salers Garrett, CSR, RPR, 6 as Commissioner and Notary Public, Alabama at 7 Large, at Anniston, Alabama, on December 28, 8 2001, at 3:10 p.m. 9 IT IS STIPULATED AND AGREED that the 0 signature to and reading of the deposition by 1 the witness is waived, the deposition to have 2 the same force and effect as if full 3 compliance were had with all laws and rules of 4 Court relating to the taking of depositions. 5 IT IS STIPULATED AND AGREED that it 6 shall not be necessary for any objections to 7 be made by counsel to any questions except as 8 to form or leading questions and that counsel 9 may make objections and assign grounds at the 0 time of trial or at the time said deposition 1 is offered in evidence or prior thereto. 2 IT IS STIPULATED AND AGREED that notice 3 of filing by the Commissioner is waived. REGIONAL REPORTING SERVICE, INC. 2 1 APPEARANCES 2 For the Plaintiffs: 3 CHARLES CUNNINGHAM, Esq. Morrissey Building, Suite 200 4 304 West Liberty Street Louisville, Kentucky 40202 5 6 For the Defendants: 7 EDWARD M. NEWSOM, Esq. SMITH, HELMS, MULLIS & MOORE 8 Suite 750, 1355 Peachtree Street NE Atlanta, Georgia 30309 9 10 INDEX 11 Stipulations 12 Reporter's Certificate Page 3 89 13 14 EXAMINATIONS 15 Witness: CHARLES CHATMAN 16 By Mr. Cunningham 17 Page 4 18 19 EXHIBITS 20 Plaintiffs' Marked Offered 21 One 6 22 No other exhibits were marked for identification, offered or attached as 23 exhibits hereto. REGIONAL REPORTING SERVICE, INC. Ht 1 STATE OF ALABAMA, ANNISTON, DECEMBER 28, 2001 2 3 CHARLES CHATMAN, 4 after having been first duly sworn, was 5 examined and testified as follows: 7 EXAMINATION 8 BY MR. CUNNINGHAM: 9 Q. Sir, my name is Charlie Cunningham, and . 10 11 I'm going to ask you some questions today to find out what factual knowledge 12 you may have that would be helpful for 13 parties in a lawsuit styled Abernathy, 14 et al., versus Monsanto, et al., filed 15 in Calhoun Circuit Court. 16 Have you ever been in a deposition 17 before? 18 A. Yes, I have. 19 Q. So you understand that the lady to your 20 left is taking down everything we both 21 say, and therefore we need you to answer 22 orally with words as opposed to nods of 23 the head or grunts. REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013974 5 1 A. 2 Q. 3 4 5 6 A. 7 Q. 8 9 10 11 12 13 14 15 16 17 A. IB Q. 19 20 21 22 23 Right. And secondly I'm going to give you just some idiosyncrasies of my own that you may not have encountered in the previous deposition testimony. Okay. One bad habit of mine is that you will be answering a question that I have asked you and I will mistakenly believe you have finished with that answer or I'll have a brilliant idea of another question I want to ask, and I'll go to another question before you are done. We certainly want you to have a chance to answer completely and fully. So if I do that to you, just let us know. okay. A second thing I have a bad habit of doing is I'll ask a question and the way I'll say it makes it sound like I know exactly what I'm talking about and that it must be so when in fact I don't know what I'm talking about and it isn't so. REGIONAL REPORTING SERVICE, INC. 7 1 2 3 4 5 6 A. 7 Q. e A. 9 Q. 10 11 A. 12 Q. 13 A. 14 15 Q. 16 17 18 A. 19 Q. 20 A. 21 22 Q. 23 Exhibit One. Have you seen that document before? MR. NEWSOM: Take a look at it. I don't know that you have, but you may have. I don't think so. Okay. No. No, I haven't. All right. What is your address. Mr. Chatman? My mailing address or street address? Street address. 41050 Highway 21 South, Munford, Alabama, 36268. And I believe Munford is the community Donald Stewart is from that is south of here. Right. Maybe fifteen, twenty miles? About thirteen miles south of Oxford. So about fifteen or twenty from here. And how long have you lived in Munford, Alabama? REGIONAL REPORTING SERVICE, INC. 6 ; 2 3 4 5 6 A. 7 Q. S 9 A. 10 11 12 Q. 13 A. 14 Q. 15 16 17 A. 18 19 20 21 Q. 22 23 So if I say something, even if sounds like 1 know it is sure, but it is not consistent with what you understand the truth to be, let us know that. All right? Yes. Okay. Let's start with a very easy one. What is your full name, please? Charles Thomas Chatman, and I use senior since I have a junior. But my work record is just Charles Thomas. Is that spelled C-h-a-t-m-a-n? Yes. Do you know if there was a fellow at the plant out there whose name was Chapman, C-h-a-p-m-a-n? Yes. (Plaintiffs' Exhibit Number One was marked for identification.) I'm going to enter into evidence as an exhibit to your deposition the notice of your deposition. We have marked that as REGIONAL REPORTING SERVICE, INC. CD 1 A. 2 Q. 3 4 5 A. 6 7 8 9 10 11 Q. 12 13 14 A. 15 16 17 18 19 20 21 Q. 22 A. 23 About four years. Prior to that take me back in time to the different places you have resided. please. I moved to Munford in September of '98, and I lived in Golden Springs from January '97 to September of '98. And I lived in the west Anniston area from '63, the year I came to Anniston, until January of '97. Now, when you say west Anniston, what particular street or neighborhood in west Anniston? 1423 Pine Avenue. I lived there from '65 to '76, and from '76 until '97 I lived at 2524 Paul Circle. That is a subdivision out in west Anniston by Union Foundry on - - I guess you would call it the northwest side of Union Foundry. Okay. And from '63 to '65 I lived at 1407 Stevens Avenue. REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013975 9 1 Q. 2 A. 3 Q. 4 5 A. 6 Q. 7 B 9 A. 10 0. 11 A. 12 Q. 13 A. 14 Q. IB A. 16 Q17 18 19 20 A. 21 Q. 22 23 Okay. All that was west Anniston area. And Golden Springs and Munford are a fair distance from the plant? Right. But the addresses you have given me for west Anniston would be relatively close to the plant? Yes. Are you married? Yes . What is your wife's name? Leslie, L-e-s-l-i-e, K. Chatman. What was her maiden made? Hilliards, H-i-l-l-i-a-r-d-s. And do either of you all have relatives who reside in Etowah County who would be above the age of eighteen and eligible to serve as potential jurors? No. And I know you have at least one child because you said you now are a senior. How many children do you have? REGIONAL REPORTING SERVICE, INC. 11 1 A. 2 3 Q. 4 5 6 7 8 9 10 11 12 A. 13 14 15 16 17 IB 19 20 Q. 21 22 A. 23 No, sir. The first female that worked out in the plant was 1975. Okay. You've been identified as I understand it on a witness list of persons that Monsanto or Solutia might call in their defense of the lawsuit. What is your understanding of the type of testimony you would be providing in that lawsuit? MR. NEWSOM: Object to the form. You may go ahead. Well, just I was called because I worked in the department during the time of the PCBs, the Aroclor department. That is as far as I know, you know, to give testimony. Or I don't know what is going to be asked, but I was being called because of my experience in that department. when were you first contacted about potentially testifying in the case? Let me see. Probably September of this year, and I think I was scheduled to REGIONAL REPORTING SERVICE, INC. 10 1 A. Six all total. I have four by my first 2 wife and then I have to two additional 3 ones. 4 Q. 5 Your first wife, was she -- Would she have been married to you during the time 6 frame at all before 1971 or '72? 7 A. Right. 8 Q. And what is her name? 9 A. Mary Lois. Maiden name was Stamps, 10 S-t-a-m-p-s. 11 Q. Do you know if she has ever had her 12 serum PCB level determined? 13 A. No, I don't. 14 Q. What about your current wife? Has she 15 ever been tested to your knowledge? 16 A. No. 17 0. IB And I presume the same for your children. They have never been tested? 19 A. No, sir. 20 Q. 21 Do you remember if there were any females who worked at the plant in the 22 era from 1971 back that would have been 23 involved in the Aroclor department? REGIONAL REPORTING SERVICE, INC. * 12 1 testify before the Trade Center bombing, 2 sometime before that. 3 Q. Okay. And who have you talked to about 4 this since hearing about the fact you 5 might testify other than attorneys? 6 A. I mean -- 7 Q. In other words, did you speak with any 8 other folks who worked out there to 9 share recollections or talk about what 10 . might be coming up? 11 A. No, sir. 12 Q. So you have only talked to lawyers about 13 being a witness? 14 A. Right. 15 Q. Aside from talking to lawyers have you 16 looked at anything in the way of 17 documents, photographs, books, records, IB or anything like that? 19 A. No, sir. 20 Q. 21 A. 22 Q. How is your health today, Mr. Chatman? Pretty good for a fifty-eight year old. Okay. Have you any historical health 23 problems such as cancer? REGIONAL REPORTING SERVICE, INC- HARTOLDMONOQ13976 13 1 A. 2 Q. 3 A. 4 5 Q. 6 A. 7 e 9 Q. 10 A. 11 Q. 12 A. 13 Q. 14 15 A. 16 17 IB Q. 19 20 21 22 A. 23 Q. I had prostate cancer. And that is under control now? Right. I had the operation in '93 January of '93. Okay. Do you consume alcohol at all? Very -- maybe in a month's time maybe a six-pack of beer or a wine cooler or two within a month, very light. Do you consume any tobacco products? No, sir. Have you ever consumed tobacco? Yes, sir. Tell me your history of tobacco use. please. I started smoking when I was sixteen. and quit when I was twenty-five. And I haven't smoked since March 10th, 1969. Good man. You are really good with dates. When you were twenty-five, when would that have been? I have to work that backwards. Probably '69. When were you born? REGIONAL REPORTING SERVICE, INC. 15 1 A. 2 3 4 Q. 5 A. 6 7 8 Q. 9 A. 10 Q. 11 12 13 A. 14 Q. 15 16 A. 17 Q. 18 19 A. 20 Q. 21 A. 22 Q. 23 At Union Foundry, about eighteen months, from October '63 to May of '65, Union Foundry in west Anniston. What did you do there? Started out as laborer, just doing general cleanup, when I left I was a grinder, grinding the pipe. Smooth out the castings? Yes. In your eighteen months at Union Foundry what sort of Aroclor or PCB containing products did you use? I never heard of it. Okay. All right. Let's talk about -- I take it that was your first job? First job, right. And you moved up in the world so to speak and went to work for Monsanto? Right. Then you retired out of Monsanto? No. I'm still employed. Let's start with the first job you had when you went to work at Monsanto and REGIONAL REPORTING SERVICE, INC. 14 1 A. 2 Q. 3 4 5 A. 6 7 Q. 8 9 A. 10 11 12 13 14 15 16 17 18 19 20 Q. 21 22 23 ' 43 . So that would have been in 1960. So you were a smoker at least part of the time -I quit before '69, though. Anyway I quit in '69, March 10th. I know that. Was there something particular about that date? Yes, because whenever anybody asked me if I smoked, me and my wife both smoked. And we both had been^alking about quitting. And we got up on that Monday morning and she didn't have any cigarettes, and I had one. And I told her she could have mine, and I quit. And we lived together until June of '78, and I never smoked again, and she still smokes to this day. That is why I can remember that date, sir. Okay. Aside from your work with Monsanto that we will talk about here in a moment, have you held any other gainful employment? REGIONAL REPORTING SERVICE, INCi 16 1 2 A. 3 4 Q. 5 A. 6 Q. 7 8 9 10 A. 11 12 13 14 15 16 17 18 19 20 21 22 23 Q. tell me what your title was. I was a general laborer for the first eleven months. And that was in '65? Late 1965. Okay. And then what did you do as a general laborer? Was it a bunch of different things, or did you have a specific job? ' Well,-we did all the drumming, the capping. Not really ---We did some of the drumming in the --we did the bagging. To operate -r to operate as laborer, which I went to in Aparil, I did the bagging of the material. We used to palletize and put caps on and the labels on. We also did all the cleanup. hauling all the trash and stuff like that for the first eleven months. As a general laborer you did that all throughout the plant. General labor. you were the ones they called. I have seen some historical documents REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013977 17 1 2 3 4 5 6 A. 7 8 9 Q. 10 11 12 A. 13 14 15 16 Q17 ie A. 19 20 Q21 22 23 from the Anniston plant from back in the '30s where the laborer in the charts specifically said it would be Negro. By the time you were there in the '60s was it mixed race as far as laborers? Well, I guess you called it colored or Negro or whatever. We were the Negro race then I guess, still. But I'm saying by the '60s had it been integrated for work for both whites and blacks to do labor work? Not in '65. It happened in 1966 when it integrated. That is when I went from a laborer to an operator. I went into the operating room. So you were one of the pioneers, if you will? I was the first black that went from a laborer to an operator. My next question would be why did you move to another position? That is kind of self-evident, isn't it? And which department, if it was limited to one REGIONAL REPORTING SERVICE, INC. 19 1 2 3 4 A. 5 6 7 8 09 10 11 A. 12 Q 13 A. 14 Q. 15 A. 16 Q 17 18 19 20 A. 21 22 O23 things that get clogged in the system or anything like that. Did you do any of that sort of stuff? Only if you're flaking when I was an operator's laborer. That is the only time we did anything like that as far as I remember. So would you basically -- when you reported to work -- And I assume y'all were on shift work back then? At what particular time? This 1966 era. Right, right, on shifts. Do you recall what shift you -We were on rotating shifts. So you would show up for your shift and basically show up at the Aroclor department and be at the machine filling bags? Right, relieve other laborers. operator's laborers. But you spent eight hours a day essentially putting product into its REGIONAL REPORTING SERVICE, INC. 18 1 2 3 A. 4 Q5 A. 6 7 Q. 8 A. 9 010 A. 11 Q12 A. 13 14 15 Q. 16 17 A. IB 19 20 Q. 21 22 23 particular area, did you work in as a laborer? Aroclor department. Okay. I went from a laborer to an operator's laborer. Operator's laborer? Right. And that began in '66? Around April of '66. Okay. And there you were bagging? Bagging, drumming, and flaking, when it flakes we put it in bags. That is the same thing. So you were -working pretty much exclusively with the finished product? Right, right. See, at that time I was still a laborer. We weren't doing any manufacturing or processing. I would have assumed that laborers would have had some role to play in cleanup. taking care of Montars or still bottoms, taking care of bad batches, you know, REGIONAL REPORTING SERVICE, INC. ^eV 20 1 2 3 4 5 6 1 8 9 10 11 12 . 13 14 15 16 17 18 19 2D 21 22 23 AQA. Q. A. QA. 0A. Q. A. containers? Yes. Tell me about the next position you held as a Monsanto employee. In October of '66 they started up a P2S5 department or phosphorus pentasulphide department- I went in for that. At that time the plant had been integrated, and I put in for one of the jobs and was selected as .one of the operators for that particular department. Pentasulphide - P2S5, phosphorus pentasulphide. Basically that come from -- we use two parts phosphorus and five parts sulfur. react together to make P2S5. which in turn was a feed stock for one of your finished products? in another department. But your title was? An operator. Okay. Everybody that operated had the same REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013978 21 1 2 3 Q. 4 5 A. 7 8 9 10 11 Q. 12 13 A. 14 Q. 15 16 A. 17 Q. 18 19 20 21 A. 22 Q. 23 title regardless of what department you were an operator in. And what sort of task did you perform as an operator in that P2S5 department? We processed the chemical, did the mixing and all that, made the chemical. our part of the operations. In fact it was a two-man operation for about eight months, and then it became a one-person operation after that. So you would do a lot of turning of valves and monitoring -Right. -- needles and making sure the stuff was flowing the way it was supposed to? Right, sampling and stuff like that. And by sampling, you would take some of your finished product and send it off to the lab to find out if the product was finishing out to spec? Right. But you didn't actually take it up and do the measuring yourself, I trust? REGIONAL REPORTING SERVICE, INC. 23 1 2 3 A. 4 5 6 7 Q. 8 A. 9 Q. 10 11 A * 12 Q. 13 14 15 16 17 A. 18 Q. 19 20 A. 21 22 23 Q. position that you held there at the company? Well, I just changed from one department to another one. I went from the P2S5 department in January '75 to the biphenyl department. Okay. And you were an operator? I was operator. So you were a P2S5 operator for about nine years? Right. And by the time you would have gotten back to the biphenyl department in '75, they weren't making -- they weren't chlorinating any of that biphenyl any more? No, sir, they wasn't. What did you do in the biphenyl department as an operator? Process the chemical, in fact the same chemical we are making today, the Therminol heat transfer fluid and all. Was this again a one-man kind of REGIONAL REPORTING SERVICE, INC. 22 I A. 2 Q. 3 4 5 6 A. 7 Q. 8 9 10 A. 11 12 13 14 Q. 15 16 17 18 19 20 A. 21 22 23 Q. No, sir. I assume though that there was a pretty precise way they wanted you to draw that sample and what you drew it into and how it was collected? Right. And I would also assume that you had a fair amount of instruction on how to operate that system? We had to be trained and had to be qualified in order to be able to be responsible for that one-person operation. Because I'm also presuming that if you screwed up on that-job you could cause not only a lot of financial damage to the company but possibly some physical damage as well. MR. NEWSOM: Object to the form. Well, you had to know the operation. If you weren't trained and didn't follow the procedure, you could do that, yes. Okay. What would have been the fourth REGIONAL REPORTING SERVICE, INC. * 24 1 2 A. 3 4 5 6 7 Q. B 9 10 11 12 A. 13 14 15 16 Q. 17 18 A. 19 Q. 20 21 22 A. 23 Q. operation? No, sir. There was about -- depends on the department. There were two of three operators in one department and one or two in another department. There were several operators on each shift. I take it you all were kind of interchangeable. You didn't have a set task that you did as an operator in that nine years, but you probably did all of them? Well, we rotated. We were trained to rotate a job on a weekly or biweekly basis. So eventually we operated on all the jobs, all operators. Everything from getting benzine into the reactor vessel where -Right. --it would be blended together to make biphenyl to controlling the catalyst to getting the final product out? Right, yes, sir. Okay. What happened after 1975? REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013979 25 1 A. 2 3 Q. 4 5 A. 6 Q. 7 8 9 10 A. 11 Q. 12 13 A. 14 15 16 17 18 Q. 19 20 A. 21 22 23 In 1981 I became one of the chief operators. Okay. And what department did you -was that in? That was in the biphenyl department. And I didn't ask, but I'm assuming when you went from the P2S5 department to the biphenyl department that was your choice? Right. Was that in some sense a step up for you? No. It was just -- We had the bid system, and there was an opening. If you had seniority and wanted to move from one department to another one and you had seniority. Why would you want to move from that department to another one? Well, I guess you would call it a step up. It was from a one-person operation -- I wanted to learn more about the plant, and so I moved to this REGIONAL REPORTING SERVICE, INC. 27 1 2 Q. 3 A. 4 Q. 5 6 7 A. 8 9 10 11 12 13 14 15 Q. 16 17 10 A. 19 Q. 20 21 A. 22 23 Q. department. Did you say polyphenyl? Well, biphenyl. It is the same thing. Okay. Was there some discussion back in the mid '80s time frame that the plant might actually be sold? Yes. There was an announcement came out October '85. I remember it because I was one of the union committee representatives. And they said by the end of '86 if it wasn't sold it would be closed. That is when we had a major layoff in '86, in two different sections. Well, let's talk about that for a minute. You were a union rep. What is the union out there? ICW chemical workers. And do you recall when that plant went union? I don't know. it was union when I went to work there in '65. But you were a shop steward in the mid REGIONAL REPORTING SERVICE, INC. 26 1 2 3 4 Q. 5 6 A. 7 Q. B 9 10 A. 11 12 13 14 15 Q. 16 17 A. 18 19 20 21 22 23 department, which it wasn't any upgrade as far as pay or as far as job status. You just went to a different department. But I'm guessing when you went to chief operator that was a step up? Right. What different responsibilities did you have as a chief operator from those you had as just an operator? Well, you were the shift coordinator. You were the person responsible on the off shifts. You were responsible for the operators. You were the lead person per se on that shift. Okay. And what would have been the next title which you held? Well, in 1986 when the plant downsized and we went to -- the plant went to plant-wide chiefs because of the smaller plant, I got rolled out of my job. Someone else that had more seniority bumped me out of it. So I went back as an operator in the polyphenyl REGIONAL REPORTING SERVICE, INC. i 28 1 2 3 A. 4 5 6 7 8 9 0. 10 11 12 A. 13 Q. 14 15 16 A. 17 Q. 18 19 20 21 22 23 A. '80s? What was your title that you held? I was a department steward, but when the plant downsized, I was a committeeman, which is one of the executive committees that handled all the grievances, did the contract negotiations. I was part of that group. Okay. And you were told by management, I take it, that the plant, would either be sold or closed? Right. But something happened, obviously, that caused the plant to be neither closed nor sold? Right. And that thing of course was the environmental law where they realized they had these mountains of PCBs sitting around and realized they couldn't very well afford to -MR. NEWSOM: Object to the form. I don't know. I haven't heard that REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013980 29 1 before. 2 Q. what were you told as to why they 3 changed their mind? 4 A. Well, the plant got out of -- the 5 parathion department closed. And at 6 that time Monsanto closed lots of its 7 small plants. They were downsizing, per 8 se. And we had a sister plant in 9 England that was going to stay open. 10 And I think after they -- what I 11 understand, after they researched it, 12 they found out England would not be able 13 to handle all the business. So we were 14 able to keep the polyphenyl part at 15 Anniston. 16 Q. Okay. Do you know if the union out 17 there ever took any steps to have the 18 work force checked for PCB levels? 19 A. Yes. 20 Q. When was that? 21 A. In the '90s. I don't remember the exact 22 date, '98, '99, sometime in the '90s. I 23 can't tell you the exact day. I was one V. REGIONAL REPORTING SERVICE, INC. 31 1 2 03 A. 4 5 6 Q. 7 8 A. 9 10 Q. 11 A. 12 13 Q. 14 15 16 17 A. 16 19 20 21 22 23 all happened. What did you move to next? Moved back to an operator in the polyphenyl department, biphenyl department. After that what is the next title that you held? I went back to chief operator in '98, which I am today, chief operator. Still in biphenyl? Well, plant chief now, other than department chief. Okay. If I understand it correctly, you would have only had actual contact or daily work activity in the Aroclor area from May of 1965 until October of '66? No, sir. There was two or three more times. Before P2S5 started up we had finished the training. Around December, the last of the year, we went back for a short term. The P2S5 was used in the parathion they was making. And there were a couple of dry spells we had. We REGIONAL REPORTING SERVICE, INC- 30 1 2 3 Q. 4 A. 5 q. 6 7 8 9 A. 10 11 12 13 14 15 Q. 16 17 18 19 20 A. 21 Q. 22 23 A. that tested. I was on the committee when we requested the testing. So that was initiated by the union? Right. That had never -- in your years there anyway from the mid '60s on had never been offered by the company as far as you knew? Well, as far as I know there had never been a problem. it was only initiated because of the claim around the plant. you know, about the PCBs. So we decided, well, let's test employees, you know, see what -- > Well, I'll come back in a little bit and we'll talk about the results of that. You say even at that point you were still on the committee that was involved in getting that done? Right. Okay. So in '86 you get bumped because the work force is reduced? Right, really '87. Early '87, when it REGIONAL REPORTING SERVICE, INC. * 32 1 2 3 4 5 6 7 Q. 8 9 10 A. 11 12 Q. 13 14 15 16 17 A. 18 Q. 19 20 21 A. 22 23 was filled up on inventory, and the department was shut down, because we made the intermediate for the parathion. I went back to the Aroclor department because that is what my previous experience was. What would you say then was your total years or months working in the Aroclor department? A couple, two years, maybe two years. At least two years. And the two or maybe as much as three years that you were in the Aroclor department, you would pretty exclusively have been involved with drumming or bagging the finished product? Right. Now, when you were drumming or bagging it, I'm assuming that stuff is pretty much at ambient temperature? Yes, yes. It had to be cooled. Some of the drumming was a little bit warm, but the flaking and bagging wasn't. REGIONAL REPORTING SERVICE. INC. HARTOLDMONO013981 33 1 Q. 2 3 4 A. 5 Q. 6 7 e A. 9 ID 11 12 13 14 Q. 15 16 17 A. 10 Q. 19 20 A. 21 22 23 Q. That would have been cooled basically to normal temperatures and then flaked and into the bag? Yes. Was there a lot of dust involved in that flaking process, or did you have equipment -Well, my job basically was the Aroclor flaker, and there was very little dust because it just came off in solid flakes. There wasn't a lot of dust. We didn't have - - Very little dust accumulated in there. Now, by way of comparison, the drumming operation, would some of that be at elevated temperature? Yes. And was there any effort to control fume off that heated -Well, we had masks available if we need them, if there was a problem. There was always safety equipment available. And what would that personal protective REGIONAL REPORTING SERVICE, INC. 35 1 2 3 4 Q. 5 6 7 A. B 9 Q. 10 11 12 A. 13 Q. 14 15 16 17 A. 18 19 20 21 Q. 22 23 there were some rubber gloves available if you needed them. There were two types available if you wanted them. And what sort of ventilation would have been provided in those kinds of settings? Well, there was -- It was open. It was an open area. It wasn't a closed area. Were the shoes and the shirts and the pants that you wore, were these company issued? Yes. And were you provided fresh garments each day? Would you take those home and you or your wife would be responsible for cleaning? No. Monsanto took care of the laundry. They provided for a change of clothes. They did the laundry. All of that was free. Were you allowed to eat or smoke in the area where you would be fooling with the Aroclor products? REGIONAL REPORTING SERVICE, INC. 34 1 2 A. 3 4 5 6 7 8 Q. 9 10 A. 11 Q. 12 13 14 A. 15 16 17 Q. 18 19 20 21 A. 22 23 equipment consist of? Standard, which is -- over the years I have been out there, safety shoes, long sleeves, gloves, glasses and goggles and shields if you were drumming, because you didn't want to take a chance of splattering. Safety shoes, long sleeves, goggles, face shields. Did I get it all? Glasses, gloves. Now, gloves can be made of various things. Do you recall what these were made of? Well, depends on whether you were drumming or flaking. Basically they were leather gloves. I have heard people tell me in other cases where they worked on PCEs that certain types of Aroclor could be fairly corrosive of certain types of leathers. Well, see, I wasn't in the processing. I was only in the bagging and flaking. We used basically leather gloves, and REGIONAL REPORTING SERVICE, INC. * 36 1 A. 2 3 4 5 06 7 8 A. 9 Q. 10 11 12 A. 13 14 15 16 17 18 19 20 21 Q. 22 A. 23 Q. No. We wasn't allowed to, but we always slipped and ate it sometimes, but we wasn't allowed to. We could have been in big trouble if they had found it out. As far as smoking in a place where there is benzine being used wouldn't be a particularly good idea? Right. But eating, I'm sort of curious about what sort of rule was in place about . eating. Well, any chemical, my understanding. you didn't want to eat it, you kiv>w, whether it was harmful or not. That was just a policy. They provided a lunchroom for breaks and lunch so you wouldn't have to eat out there. In fact they didn't want you to be eating. They wanted you to be working. That is the main thing. That is the real bottom line? Right. Let's talk about what information you REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013982 37 1 2 3 4 5 6 7 A. 8 Q. 9 10 11 12 13 14 15 16 A. 17 18 19 20 Q. 21 A. 22 23 Q. all were provided with regard to PCBs or Aroclors. We talk about in this case PCBs, polychlorinated biphenyl. One of the guys earlier today said that wasn't a term y'all used back them, that y'all just called them Aroclors. Right. what were you told when you first came to work there in the Aroclor department about the toxicity of these things, if anything, about the dangers of them? MR. NEWSOM: You are talking about while he was in the Aroclor department? MR. CUNNINGHAM: Yeah. Well, I don't know. It is a long time ago. They gave us -- told about what the chemical was, to be explained, what the chemical was. Nothing that sticks out in your mind? No, nothing that sticks out as far as a hazard or anything like that. And what about subsequent to that? Do REGIONAL REPORTING SERVICE, INC. 39 1 2 3 A. 4 5 6 7 8 Q. 9 A. 10 11 Q. 12 13 14 15 16 17 A. 18 Q. 19 20 21 22 23 production of this particular family of chemicals? Well, I don't -- I was working in the P2S5, and when they gave the layoff number, my number was in that number. So that was a major concern, but I can't -But I take it you weren't laid off? No, no. But I was scheduled to be laid off, but they didn't go into it. Did you ever hear anyone suggest that the reason they were going to stop making this stuff was that it was creating problems in the environment for animals, that it was toxic to fish? MR. NEWSOM: Object to the form. I don't remember hearing that. Do you remember hearing anything about an incident in Japan sometimes referred to as the Usho incident with people getting heat transfer fluid made of Aroclor or the Japanese equivalent to Aroclor in rice oil and consuming that REGIONAL REPORTING SERVICE, INC. 38 1 2 3 4 5 6 7 8 9 10 11 12 13 A. 14 Q. 15 A. 16 17 18 19 20 21 Q. 22 23 you ever recall any particular event as a Monsanto - - as a Monsanto employee where you were informed either through some sort of documentation provided to you, a meeting where someone got up and spoke, press releases, anything at all that you can recall that stands out in your mind where you learned something about the toxicity or the dangers of PCBs or Aroclors? MR. NEWSOM: Object to the form. Go ahead. At that time frame? At any date. Well, there was concern, because when we lost the department around '72, when we stopped making it, it was a major concern because it caused some layoffs. Monsanto was phasing out its Aroclor business. Well, what did you understand in '72 when they stopped making it as far as the rationale behind their ceasing REGIONAL REPORTING SERVICE, INC. * 40 1 2 A. 3 Q. 4 A. 5 Q. 6 7 8 9 A. 10 Q. 11 12 A. 13 Q. 14 15 16 17 18 A. 19 20 21 Q. 22 23 and getting sick? Back during that time? Yes. No. Were you aware of there being Aroclor-containing waste at the plant as part of the manufacturing operations back in the '60s? Repeat the question, please. Yes. Back when you were working as a laborer in the Aroclor department -Right. -- and even as an operator at the P2S5 department while they still had an Aroclor department, were you ever aware of the fact there were waste streams being generated that contained Aroclor? Yes. As the warehouse laborer my early year, we did transferring of waste to the landfill. Okay. So you knew there were fairly substantial quantities of that material in the landfill? REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013983 41 1 2 3 4 5 6 7 A. 8 9 10 11 12 13 14 15 16 17 Q. 18 19 20 A. 21 22 23 MR. NEWSOM: Object to the form as to what you mean by fairly substantial. MR. CUNNINGHAM: He is a big boy. If he doesn't understand it, he can tell me. Well, I understand -- I don't know about the amount. I can't tell you how much. Whenever it was generated, I can't tell you how long it took to generate what we carried up there. when the waste was generated, we were called from the warehouse laborers to go transfer it. But what kind of time frame it took to generate it, I don't know. You know, I wasn't in there. When you would haul that stuff up there. what were you taking up there? Describe it for me as best you can. The bottoms that they drawed off the Aroclor still, the chlorinator, was in metal containers, sealed metal containers. It was hot when they pulled REGIONAL REPORTING SERVICE, INC. 43 1 2 Q. 3 4 5 A. 6 7 8 9 10 11 12 Q. 13 14 15 A. 16 17 18 19 Q. 20 A. 21 22 23 Q. something like that. And you don't have any recollection of how often you would take a truck load of that stuff? No, I don't. Because see, I didn't -We rotated jobs even then. We didn't have a certain job. And I can't remember, you know, how often we did it. but I know that was part of the laborer jobs, take the waste to the landfill. But I couldn't tell you. Aside from that waste, the still bottoms -- And is Montar another name for the still bottoms? Not off the Aroclor department. Montar is off the heat transfer fluid, the Santowax, the heat transfer fluid is made out of. The biphenyl? Well, it is a bottom that is generated off the raw material that the Therminol is made out of. In other words, when they had a still REGIONAL. REPORTING SERVICE, INC. 42 2 3 4 5 6 7 8 Q. 9 10 A. 11 12 q. 13 14 A. 15 16 17 Q. 18 19 20 A. 21 Q. 22 A. 23 it off. And then when it cooled, they would call us, and we would take it. We had to make sure all the containers was sealed, even though we didn't do the sealing. The operators did the sealing. We had to make sure it was sealed before we carried it up there. And how much of that stuff do you remember taking up there? I couldn't tell you over the period of time. Well, how much would you take up there on any one trip? Oh, I really don't remember. It was several containers. I really don't remember. Just as a matter of practice, I assume you didn't take a barrel and roll it up that hill and push it over the side? No. Put it on a truck? Load it on a truck. And I guess there may have been eight or ten barrels or REGIONAL REPORTING SERVICE, INC. -> 44 1 2 3 4 5 A. 6 7 Q. B 9 10 11 12 A. 13 14 15 Q. 16 A. 17 18 Q. 19 20 A. 21 22 23 there making the benzine and putting it together and putting the hydrogen on to make biphenyl, there was a Montar that came out of the bottom of that? I don't understand. I don't remember making it like you are saying. Well, that is what I'm saying. Don't presume I'm right. I want you to tell me. what are you talking about when you say Montar? What is it and where did it come from? All right. We took the benzine and run it through the furnace and made crude biphenyl. Ran it through which? The tubes in the furnace and heated it and made crude biphenyl. Didn't you run it through molten lead to do that? Not me, I mean, not in my time. The time I operated, the furnace we have now, that's the only one I can tell you about. REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013984 45 1 Q. 2 3 A. 4 5 6 7 Q. 6 9 10 11 A. 12 13 14 Q. 15 16 17 IB 19 A. 20 Q. 21 22 23 what made the benzine molecules mate up into pairs? Now or then? From '75 on 2 can tell you about it. Before '75 I can't tell you because I wouldn't know. I wasn't involved in none of the processes. Well, I'm really interested in the era when y'all were making Aroclors. You are not familiar with how you made the biphenyls? No, sir. I was only a laborer. operator's laborer. I have no knowledge of how they made them. If I was looking at a document generated by the plant describing the different waste streams they generated and they talked about Montars one through nine. nine different Montars -I don't know about that either. With basically each of these stills, the still that made Aroclor 1254 had a still bottom, and that was one of the Montars; and the still that made 1260 had a still REGIONAL REPORTING SERVICE, INC. 47 1 2 3 Q. 4 5 6 7 8 A. 9 Q. 10 11 A. 12 Q. 13 14 15 16 17 A. 10 19 Q. 20 21 A. 22 Q. 23 was chief operator we had a safety meeting at the beginning of each shift. I assume you would have attended these safety meetings even as a laborer. There was a meeting where this information was passed on all the way down to laborers. Repeat the question. You lost me. As a chief operator you went to monthly safety meetings? Right. Was that because they only wanted chief operators to know about this stuff, or was it part of your job to then disseminate that information to people that worked -The safety meeting was open to everybody in the plant. So everybody went to these monthly meetings? Right, everybody that could. So why did you say you went to safety meetings as a chief operator? Did you REGIONAL REPORTING SERVICE, INC. 46 1 2 3 4 A. 5 6 Q. 7 A. 8 Q. 9 10 A. 11 12 13 14 15 Q. 16 17 18 19 20 21 A. 22 23 A. bottom that was a Montar eight or whatever. All of that would be news to you. You never heard anything like? Well, I used to drum all that. I used to drum 1254 and all that. The finished product? Finished product. But you weren't involved in the process of taking off the still bottoms? No, sir. What was in the container we took up there, I can't tell you what it was, whether it was 1254 or whatever. We were called when the waste was generated to take it to the landfill. Were you ever involved in your capacity as a union representative or as a chief operator with making sure that the people -- the workers in the plant knew about the hazards there in the plant to their health and safety? Yeah. MR. NEWSOM: Object to the form. Yeah, we had a safety meeting -- When I REGIONAL REPORTING SERVICE, INC. CO 1 2 A. 3 4 5 6 7 8 9 10 q. 11 12 13 14 15 A. 16 Q. 17 18 19 20 21 Q. 22 23 A. not go -No. I said as a chief operator we had monthly -- daily meetings at the beginning of my shift. I had daily meetings on each shift. At the beginning of each shift as chief operator, we would go over the safety to remind each other to be safe. That is the meetings I was talking about. I'm sorry. So those would be among some of the higher-ups, like chief operators daily, but you are saying the entire work force would be involved in monthly meetings? Right, right. Were those exclusively devoted to safety, or did they also get into health type questions? MR. NEWSOM: Which one? Are you talking about safety? The monthly meeting where everybody was invited. Well, the monthly meetings, if there was REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013985 49 1 2 3 4 5 Q. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 an Incident where somebody got hurt, a near miss, they were addressed, things like that. But I don't remember the monthly meetings when I was a laborer. What I'm trying to work toward is -- I was a little surprised when I asked you about what you were told about the toxicity of Aroclor when you started working there given that was the department you went to. And I want to read you something and ask if you have ever heard anything like this before. And that is that prolonged exposure to Aroclor vapors evolved at high temperatures or repeated oral ingestion will lead to systemic toxic effects. MR. NEWSOM: Let me object to the form. It's vague, Charlie, when you say have you heard something like this. That opens it up to a world of possibilities. MR. CUNNINGHAM: That is what I'm REGIONAL REPORTING SERVICE, INC. 51 1 2 3 4 5 A. 6 Q. 7 8 A. 9 10 11 12 13 Q. 14 15 16 A. 17 Q. 18 19 20 21 22 23 extensive bodily contact with the liquid Aroclors should prevent any untoward effects. I take it that is something you were familiar with? Yeah. And you had ventilation and/or suitable garments at all times? Yes. MR- NEWSOM: I think he has testified it was largely open. MR. CUNNINGHAM: Right. But inside the facility, where you might have had enclosed areas where Aroclors were present, there were hoods and fans? Right, right, ventilation. Do you ever recall being advised that Aroclors could cause skin problems for people if they got on you? MR. NEWSOM: Charlie, are we back -- when? MR. CUNNINGHAM: Any time, any time. REGIONAL REPORTING SERVICE, INC. 50 1 2 3 A. 4 5 6 7 8 0. 9 10 11 12 A. 13 Q. 14 A. 15 16 17 18 Q. 19 20 21 22 23 looking for, the whole world of possibilities. I can't remember. We could have. I can't remember, you know. Back in 1966 that's a long time ago. I don't remember all the documents that we were showed. Do you recall ever hearing anything like or reading anything like repeated body contact with the liquid Aroclors may lead to an acne form of eruption? No. You don't remember anything like that? I don't remember. I know we were required to wear our safety and it is required today. The same requirements today as then. That hasn't changed. You are reading my mind, because the next thing I was going to ask you is if you understood that suitable draft ventilation to control the vapors evolved at elevated temperatures as well as protection by suitable garments for REGIONAL REPORTING SERVICE, INC. V 52 1 Q. 2 3 4 A. 5 6 7 8 9 Q. 10 11 12 13 14 15 16 17 18 19 20 21 22 A. 23 You tell me when. First off, have you ever heard it? Then we can get to when and where you heard it. Yeah. We have heard a lot of things. But I can't tell you the dates when I heard it. We also heard that it has never been proven, you know, only in rats. Well, let's start with skin problems. When do you think, to the nearest decade, if you can do so, do you think you first heard that Aroclors could possibly cause, theoretically cause problems for people on their skin? MR. NEWSOM: Just object to the form of the question. It fails to include things such as nature, degree, duration of exposure. Subject to that, if you understand, you can answer. I can't remember because I'm a little bit -- See, all of this -- I mean, I REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013986 53 1 2 3 4 5 6 Q. 7 8 9 10 11 A. 12 13 14 Q. IS 16 17 18 19 20 21 A. 22 23 heard a lot of things in my years out there since we stopped making, you know. the Aroclors. But I can't give you any dates because I don't remember the dates on them. When you were working with this stuff. when you were bagging it and drumming it, what if anything did you understand could happen to you if you got too much of it on you or in you? Too much on or in me? I know if the hot material got on you it could burn you. That was the main thing. But what if you got too much of it. irrespective of it being at an elevated temperature? If you got too much in your body or on your body was there anything in particular you understood it would cause? MR. NEWSOM: Object to the form. Repeat that question again, I'm trying -- It was so long ago, and I was trying to think. I'm trying to think about -- REGIONAL REPORTING SERVICE, INC. 55 1 Q. 2 3 A. 4 5 6 7 B 9 10 11 12 13 14 15 Q. 16 17 18 19 A . 20 21 22 23 What did you think it could do to harm you? Just like any chemical. But the bags they were bagged in might have said harmful if swallowed. It may have had it on it, had some direction on it. I know if it got on you it would bum you. But you know, like all chemicals in a chemical plant, we were told you are in a chemical plant and you want to keep the chemicals off you. That is why they were very strict on wearing the long sleeves and gloves and all this other equipment. But you weren't told anything particular about Aroclor that you can recall specific to that chemical as opposed to any other chemical in the plant? Not - - MR. NEWSOM: Object to the form. He just said they were told as to all chemicals in a chemical plant to keep them REGIONAL REPORTING SERVICE, INC. 54 1 2 Q. 3 4 5 6 7 e 9 10 11 12 13 14 15 16 17 18 19 20 A. 21 Q. 22 23 A. repeat the question again. When you were there in the '60s bagging the stuff and putting it in the drums, when you were working with it every workday, do you recall having any particular understanding of what this stuff could do to you if you got it on you, on your skin or in your body? MR. NEWSOM: Object to the form, vague and ambiguous, doesn't given him enough to answer, I don't think. MR. CUNNINGHAM: Are you instructing him not to answer? MR. NEWSOM: No. I don't think you have given him enough to answer. If he thinks otherwise -- Well, I would answer it if -Did you think this stuff was harmless? Let's start with something easy. No. I didn't think it was harmless. REGIONAL REPORTING SERVICE, INC. A 56 1 2 3 4 5 Q. 6 7 8 9 A. 10 Q. 11 12 13 A. 14 Q. 15 16 A. 17 Q. IB 19 20 21 A. 22 Q. 23 off. That includes PCBs. think that is an unfair I question based on what he just said. No, You weren't given anything specific about Aroclors as far as toxicity. You were just told avoid skin contact with all the chemicals in the plant? Right. Did you ever have occasion to see the drainage ditches leading away from the plant? Not then, not in the '60s. You know where Snow Creek is, I take it, relative to the plant? Right. Of your own personal knowledge are you able to tell us anything about the condition of Snow Creek below the plant in that time frame in the '60s? No, couldn't tell you anything. Ever have occasion to be on Choccolocco Creek back in that time frame? REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013987 57 1 A. 2 3 4 5 6 Q. 7 A. 8 Q. 9 ID A. 11 Q. 12 A. 13 Q. 14 15 A. 16 17 Q. 18 A. 19 0. 20 21 22 23 I may have. I don't know -- then I probably wouldn't know which part, you know, whether I was on Choccolocco Creek or not. I know I used to fish in different areas and stuff like that. Did you ever fish in Choccolocco Creek? I wouldn't know it if I was. You realize it now has a fish advisory on it? Right. You cross that every day? Right, but I don't know -Would you fish there now, knowing about that fish advisory? No, no. Unless it is just for sport, catch them and throw them back. Catch and release? Yeah. As a person who worked in the plant and in more than one department, could you identify a particular department by smell? Could you walk in a particular area and say I'm in the P2S5 department? REGIONAL REPORTING SERVICE, INC. 59 1 A. 2 3 4 5 Q. 6 7 8 9 10 11 12 A. 13 14 15 16 17 18 19 20 21 22 23 Well, I guess each department probably had, you know, a little different smell. Like PNP department, it had a different smell. Do you recall and particularly perhaps as one of the union committeemen an investigation or study being conducted as to the mortality of the work force there at the plant in terms of how many workers or ex-workers had died and what they had died of? Well, when this -- along I guess about the same time frame of the plant PCB testing, I'm not sure the union initiated that. I know the management safety supervisor asked me about that he was contacting everybody to see -- after it came out, you know, that the PCBs had a long -- was harmful, then they decided to do a survey with the ex-employees and retired employees and compare it with the others in the community and see if there is a higher health risk or not. REGIONAL REPORTING SERVICE, INC. 58 1 A. 2 3 4 5 Q. 6 7 A. 8 9 10 11 Q. 12 13 14 15 16 A. 17 18 19 20 21 Q. 22 23 Definitely. We didn't get too many visitors in the P2S5. If you have ever smelled hydrosulphide, it smelled like rotten eggs. I haven't smelled P2S5, but guessing it was a sulfur product. We didn't get many visitors. MR. NEWSOM: He hasn't smelled that, but he's smelled rotten eggs . Now I know why you transferred from P2S5 to biphenyl. Did biphenyl or, more important. did Aroclor have a distinctive smell as well? The material that we drummed, you know. you could tell, but I wouldn't -Between 1254 or 1232 or whatever, but you could tell when you were -- You weren't in the P2S5 department. Aroclor had a distinctive sort of odor, not as strong as P2S5, but it did have a smell? REGIONAL REPORTING SERVICE, INC. is 60 1 2 3 4 5 6 1 8 Q. 9 10 11 A. 12 13 14 15 16 17 Q. 18 19 A. 20 21 Q. 22 23 A. And I was asked to contact two or three people that they wasn't able to contact. And I did on two of those. And my understanding of the study was that -the employees in the plant was even less than the general area anyway as far as health problems. That the number of deaths in this population was smaller than the expected deaths? Well, deaths or illness. I didn't understand it was just death. It was just health problems, is what I understood, you know. Death was included but just a survey of the health. Did you ever see the actual compilation of the data, or were you just told -No. It was given at a safety meeting, a plant-wide safety meeting. So you had a chance to actually take a look at it for yourself? Right, right. REGIONAL REPORTING SERVICE, INC. HARTOLDMON0013988 61 1 Q. 2 3 4 5 A. 6 Q. 7 8 A. 9 30 Q. 11 12 13 A. 14 15 16 Q. 17 18 19 A. 20 21 22 Q. 23 Do you know if your union. International Chemical Workers Union, has an epidemiologist or a toxicologist in its employ? I think so. And where would they be found, these individuals? Probably the home office up in Ohio, somewhere in that area. Do you know if they were involved at all in this investigation that you have described? I'm not sure. I think they were sent a copy of it. But I'm not sure they were directly involved in it. You think this might have been something Monsanto did in house with Monsanto employees conducting the investigation? I know it was done for the Anniston plant. I don't know how widespread it was. The Anniston plant -But as far as you know, the people -the professionals who were gathering the REGIONAL REPORTING SERVICE, INC. 63 1 2 3 4 Q. 5 A. 6 Q. 7 8 A. 9 Q. 10 11 A. 12 Q. 13 A. 14 Q. 15 A. 16 17 Q. 18 19 A. 20 21 22 23 wanted to, even the retirees or anyone that ever worked there, if they wanted to be tested, they could. Okay. But thiB was voluntary then? Right. And do you recall roughly how many people got tested? No. Were you one of the people who got tested? I was one of the people who got tested. Do you recall what level your level was? It's was twenty-four parts per billion. And do you recall when that was? It was in the '90s. I can't recall what year. And who took that? Where did you go to have the blood drawn? Let me think now if we went down to the doctor's office -- See, at that time we had a plant physician. I mean, we still have a plant physician, but he was coming out to the plant every day. But REGIONAL REPORTING SERVICE. INC. 62 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 V A. Q. A. Q. A. Q. A. data and interpreting this data were Monsanto employees as opposed to somebody from outside the company who was provided the information and said here, tell us what you think? Right, right, I think so. Have you ever visited the Krummrich plant in Illinois? No. So if we wanted to try and talk about differences in the way that Krummrich might have taken steps to control pollution from its facility, you wouldn't have any personal knowledge? I wouldn't have any knowledge. Okay. You were telling us earlier that the union requested that the workers be tested for PCB levels? Yeah. They asked that they be, you know. what happened was since everybody around the plant had been tested and because the company readily agreed, you know, that anybody that REGIONAL REPORTING SERVICE, INC. * 64 1 2 3 4 5 6 7 8 9 10 11 12 Q. 13 14 15 16 A. 17 Q. 18 19 20 A. 21 Q. 22 A. 23 I think we went up to the doctor's office. I can't remember. I really can't. MR. NEWSOM: Gehi? THE WITNESS: Right. I can't remember if we went up there or he came out here. MR. NEWSOM: We have been going about an hour. Do you want to take a break? THE WITNESS: I'm okay. After you found out you had a twenty-four -- You say you had a twenty-four. Do you know what that is. twenty-four what? Twenty-four parts per billion. And what if any did you -- what if anything did you understand about that as far as its being relative -That it was ---to anyone else? That it was surprisingly low since I worked in it and probably ate some of it REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013989 65 1 2 3 4 5 6 7 B Q. 9 10 11 12 A. 13 Q. 14 15 16 17 IB 19 20 21 22 23 too, because I ate in there every day. Didn't have no more than that, but I was told -- don't know if I read it or what, but anybody can have up to twenty parts per billion even if they have never been close to a PCB. And mine was only twenty-four. Were you present when some professionals from Monsanto came down and talked to some of the work force explaining these results? Right. I was there. Someone typed up some of the questioning, and there is a reference here to a question asked by Chapman. It says why is there so much concern about having PCBs across the street if the evidence is so strong that there are no ill effects. And the answer given was there are regulatory limits set by the government for allowable levels of PCB in the environment. There are levels that exceed those levels, and they have REGIONAL REPORTING SERVICE, INC. 67 1 2 A. 3 04 5 6 1 8 9 A. 10 11 Q. 12 13 14 15 16 17 18 19 A. 20 Q 21 A. 22 23 Q. reported as being fifty-six years old -What now? I'm sorry. Was fifty-two years old and had about one and a half years of exposure. Let me find the questionnaire sheet for that particular sample. Does that look at all familiar to you? MR. NEWSOM: If you know. Well, I'm not sure. I know mine had my name on it. They whited out the names to protect the privacy. Now, that is the questionnaire that went with number 1005. The only reason I'm pulling that out is it is the only one that says twenty-four as a result. I'll ask if that looks like what you recall answering on that questionnaire. Yeah. This looks like mine. Okay. Because I had thirty-one years at the time and '65, '66, '69, and '70. Okay. REGIONAL REPORTING SERVICE. INC. 66 1 2 3 4 5 A. 6 7 Q. B A. 9 10 Q. 11 A. 12 13 14 15 16 Q. 17 18 19 20 21 22 23 to be cleaned up. Do you recall possibly that was you who asked that question and were given that answer? Could have been. How did they spell Chapman? They have it C-h-a-p-m-a-n. Now, there was a C-h-a-p at the plant at that time. Do you know if he got tested? I don't know. I don't think he ever worked in that department, and I don't know if he got tested or not. Like I said, I asked some questions, but I can't remember what questions I did ask. I've got a little chart here I did. When we were provided the raw data on people's serum levels in the plant, all we got was an identifying number. And the only twenty-four parts per billion is number 1005. I'm going to guess that is you. It looks like it was taken June 12 of 1996. At that time the worker was REGIONAL REPORTING SERVICE, INC. * 68 1 A. 2 Q. 3 4 5 6 A. 7 8 9 10 11 12 13 Q. 14 15 16 17 18 19 20 A. 21 Q. 22 23 And twenty-four parts per billion. Very good. Okay. Now, what do your doctors tell you about PCBs when you talk to them about this level that you have in your blood? Well, I really haven't talked to any of them about it. You know, when I had my surgery I asked the doctor could it have anything to do with PCBs, and he said no, that he didn't think, it did. That is the only -- I haven't talked to anybody else about it. Some of the other comments on these questionnaires -- and I don't know the names of these workers, and I don't know if you can help me. Number 1006, the next person behind you, wrote down that he has chloracne frequently. Do you know who out there has chloracne a lot? No. I don't know what that is. You know what acne is, I presume. Chloracne is simply a rather extreme form of acne that is caused by REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013990 69 1 2 A. 3 Q. 4 A. 5 Q. 6 7 8 9 10 11 A. 12 13 14 15 16 17 A. 18 Q. 19 20 21 22 23 chlorinated compounds. NODon't know who that might be? NO. There is another one here, 1013, talks about having had an abnormal liver test five years ago. That would have been in 1991 roughly. Do you know who in the work force that might have been referring to? No. MR. NEWSOM: He is not necessarily saying that is true. He is just asking if his representation matches up with what he has heard. I haven't heard of anybody having it. Number 1035, age sixty-two, mentioned that he carried melted PCB to the dump. I guess that would have been when they were doing it in the trash skits. Do you know who was in charge of doing that or -- REGIONAL REPORTING SERVICE, INC. 71 1 Q. 2 3 A. 4 Q. 5 6 7 8 9 10 A. 11 Q. 12 13 14 15 A. 16 Q. 17 18 A. 19 Q 20 21 A. 22 23 Q. That's the one with the really skinny metal stack? Yes. Well, they had a tepee incinerator up on the hillside. Did you ever see that. kind of a conical device with a heavy spherical screen at the top that you burn trash and debris in, called a tepee incinerator? You don't recall that? No. I don't remember that one. You would have been going up on the hillside, what is called the south landfill, south of 202 when you carried those drums up, right? Right. Is that all you took up there, these drums of still bottoms? No. We took just general trash. And what did you do with the general trash? Put it in the landfill. They had more than one landfill. Okay. Well, more than one cell? REGIONAL REPORTING SERVICE, INC. 70 1 A. 2 Q. 3 A. 4 Q. 5 6 7 8 9 A. 10 Q. 11 12 A. 13 Q. 14 15 A. 16 Q. 17 A. 18 19 20 21 22 Q. 23 A. No. -- who did that? Melted to the dump? Yeah. As opposed to putting it in barrels at various times, they would put it into skits and take it up there liquid and pour it into the dump. Do you know anything about that? No. I'm not aware of it. Did you have any role to play with any of the incinerators at the plant? No. How many incinerators were you aware of that they had there? What area? Anywhere. The only incinerator I'm aware of is the - - when they had the parathion department and had the recycle incinerator. That's the only one I ever -In the parathion department? Right. REGIONAL REPORTING SERVICE, INC. , 72 _____________________________&__________________________________________________^ 1 A. 2 Q. 3 4 5 A. 6 Q. 7 A. 8 Q. 9 10 11 12 13 A. 14 15 16 17 018 19 A. 20 Q. 21 22 A. 23 Q. Yeah, more than one cell. Now, let's talk about that for a moment here. Did any of these cells ever have any water in them? I can't recall. Could have, but you don't remember? I don't remember. And you were putting all this stuff into the same cell? In other words, if you brought up trash, it went in this spot. If you brought up drums of still bottoms, it went in this spot? I don't remember. May have. That's been so long ago. We were on a time schedule, had to take it there and get back. Ever know of things to catch fire up there? I've never known of a fire up there. Ever seen people up there scavenging metal? No. The fellow this afternoon, earlier this REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013991 73 1 2 3 4 5 6 7 8 9 10 11 12 13 14 A. 15 16 17 19 19 Q. 20 21 22 23 A. afternoon, was talking about some material being burned in the boilers. that they were natural gas fed predominantly but at times they also fed those boilers with other waste product. Do you know anything about that? MR. NEWSOM: Are you saying the Aroclor department? MR. CUNNINGHAM: I said waste product. That's what I'm going to find out, which departments and what feed stock. The biphenyl department today, we recycle. See, we recycle all the waste now. If it can be burned, that is part of the fuel. That only started in the ' 90s. So you are not aware of any sort of effort to reduce the waste streams by putting stuff in the boiler in the '60s or '70s? No. We didn't. REGIONAL REPORTING SERVICE, INC. 75 1 2 3 4 5 A. 6 Q. 7 6 9 A. 10 Q. 11 12 A. 13 Q. 14 15 A. 16 Q. 17 19 19 20 21 22 23 A. kind of an open area. Do you have any understanding of whether or not that particular area historically was used to deposit anything by Monsanto? No, sir. Where would you have taken the stuff as best you recall went you were hauling stuff to the dump? Across 202, up in the landfill. Now, back in that era, in the '60s, 202 didn't go as it does now, right? Right, right. Kind of came down where Clydesdale is today? Right, rightWhen you were working as an operator, did y'all ever have occasion to just have a bad batch of something, just wasn't working, wasn't coming out to spec? MR. NEWSOM: Are you talking about operator anywhere? What product? REGIONAL, REPORTING SERVICE, INC. 74 1 Q. 2 3 4 A. 5 Q. 6 7 e 9 A. 10 11 Q. 12 13 14 15 16 A. 17 Q. 18 19 20 A. 21 Q. 22 23 Did you have any role to play when people would return Aroclor to the plant with what happened with that? I don't recall any returns. You don't know anything about when they stopped making this stuff and people were changing out from the chlorinated products to the non-chlorinated product? No. I was in P2S5. I wasn't aware of that. There is an area that I have had people call Sweet Valley. I don't know how familiar you are with the area out there. Do you know where the Mars Hill Missionary Baptist Church is? Yes. You know, just to the east of that there is what is now a pond or retention basin. Right. I have had people tell me that is called Sweet Valley. And if you look at old historical aerial photographs, it is REGIONAL REPORTING SERVICE, INC. 76 1 Q. 2 3 4 5 6 7 8 A. 9 10 11 12 13 14 15 Q. 16 17 18 19 20 21 22 23 A. Any product. Did you ever have when you were an operator or chief operator, on your watch, where a batch of stuff just wasn't coming together and you just at the end had to say we are just going to have to toss this stuff, it has gone south on us? Basically we would have recycled it, reworked it. If it was biphenyl or Santowax we would drum it out and put it back in the system, melt it up later. put it back in the system. I don't remember just dumping a batch because we could always recycle it. What about ruptures, spills, where stuff would -- pipes or valves or fittings or tanks would leak or break? And let me just limit it to Aroclor. Were you ever aware of any Aroclor getting away from you all because of a break in a pipe, break in a valve, a seam in a tank or anything like that? The only recollection I have -- Like I REGIONAL, REPORTING SERVICE, INC- HARTOLDMONO013992 77 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Q. 16 17 A. 18 0. 19 A. 20 Q. 21 22 23 said, I did the packaging. If we had a drum that was overfilled, we would clean it up and put it in one of those drums that they drawed the bottoms with and seal it up. And it went to -- but I don't ever remember -- Like I said, I didn't work in the processing, so I don't know what they did with a valve open. But if we had a spill or one of the bags busts and we couldn't put it in another bag, we had a waste can that we would get it all in that and then seal it off. And it would go up to the landfill. Okay. Do you own any property in west Anniston today? No. I did, a house, but I don't today. You moved out of west Anniston in '97? Yes. My ex-wife still has the property. We're not going to talk about leaving ex-wives with the property in west Anniston. Do you know if that property has ever been tested? REGIONAL REPORTING SERVICE, INC. 79 1 A. 2 3 4 Q. 5 6 7 8 9 A. 10 Q. 11 A. 12 13 14 , 15 Q. 16 17 18 A. 19 Q. 20 A. 21 Q. 22 23 No more than a couple of miles. MR. NEWSOM: Then you have to figure out how a crow flies. If you drew a straight line on an aerial photograph. Is the reason you left west Anniston because you got divorced from your first wife? No, second wife. From your second wife. Okay. First wife got the 1423 Pine property. The second wife got 2524 Paul Circle property. So I moved out. I moved to Munford after that. First you went to Golden Springs, which is on the other side of the mountain, kind of southeast? Yes. And then down to Munford? Yes. Have you heard at all or read in the paper, heard people talk about there having been a lot of PCBs found in REGIONAL REPORTING SERVICE, INC- 78 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 8 9 A. 10 11 12 13 14 15 16 17 18 19 Q. 20 21 A. 22 Q. 23 No, sir. As far as I know it hasn't. You know it hasn't? It hasn't as far as I know. Is that 1423 Pine Avenue? 2524 Paul Circle. I have to confess. I don't know where Paul Circle is. If you left, how would you go home to get to Paul Circle? Go to Fifteenth and Quintard, and go all the way until it ends. And you take a right by Union Foundry, going west on Fifteenth. You go through the little business district of Fifteenth Street, and when you get to a couple of railroad tracks, take a right. Then there is McWayne, used to be Union Foundry, where I used to work. Paul Circle is a subdivision right -That is a pretty fair distance then from the Monsanto plant? Right, right. Maybe two to three miles as the crow flies? REGIONAL REPORTING SERVICE, INC. o CD A 1 2 3 4 5 A. 6 7 6 Q. 9 10 11 A. 12 13 14 15 Q. 16 A. 17 Q. 18 19 20 21 22 23 people's yards and people's bodies out there around the plant? MR. NEWSOM: Object to the form. What do you mean by a lot of? I mean, I read the newspaper and read of the amounts. I can't tell you what amount it was. okay. Did it surprise you when you read about that and heard about that? MR. NEWSOM: Object to the form. Well, I mean, I don't know how to answer that because I didn't -- you know, for many years I didn't know that PCBs -still don't know -Still don't know what? That it is really harmful. Right. And I'm not asking you whether you think it is harmful or not. I'm asking you did it surprise you to learn chat it was being found as far away from the plant as it seems to be based on what you read? MR. NEWSOM: Object to the form. REGIONAL REPORTING SERVICE, INC- HARTOLDMONO013993 81 1 A. 2 3 Q. 4 A. 5 6 7 B 9 10 Q. 11 12 13 A. 14 15 16 17 18 19 20 21 22 23 No, sir. Can I answer that? I can tell you why it didn't surprise me. Okay. It did surprise you? Didn't surprise me. Because all of the yards in west Anniston and the two houses I owned in west Anniston has pipe shop sand in them. And pipe shop sand has PCBs from the different foundries, and that is why it is so widespread. Let me see if I've got this straight. You know that every yard in west Anniston has pipe shop sand? Well, I'm saying the two houses I owned in west Anniston -- the one at 1423 Pine Avenue, I used pipe shop sand to help fill in the low spots as a base. And at 2524 Paul Circle, I could get out there and dig in the yard to put a fence post up, and I could dig up pipe shop coal and pipe shop sand, because sand was -That was just a hilly area. And it was a new subdivision, and to my knowledge they used pipe shop sand as a base to REGIONAL REPORTING SERVICE, INC. 83 1 2 3 A. 4 5 6 7 Q. 8 9 A. 10 Q. 11 A. 12 Q. 13 14 15 16 17 A. 18 19 Q. 20 21 22 23 you ever hear or see anything that made you think - - I didn't even know what PCB was when I worked at the foundry. I never heard of PCBs when I worked at the foundry. That is what I was basing my assumption on. These yards of yours, have you had them tested -- No. -- to see if there is PCB in them? No. So if we tested your yard and you didn't have PCBs and you know you had foundry sand put there, that would be a pretty good indication that's not the source of the PCBs? No, I can't say that. It may be just a bad batch - - or a good batch. Are you saying it would surprise you if somebody suggested PCBs had gotten away from the plant and into the neighborhoods around the plant? It would surprise you? REGIONAL REPORTING SERVICE, INC. 82 1 2 3 4 5 6 7 8 Q. 9 10 A. 11 12 13 14 15 16 17 Q. 18 A. 19 Q. 20 21 A. 22 23 Q. fill in. And that was common to see. the truck with pipe shop sand stopped at people's yards. I gave five dollars. you know, to keep from taking it to the landfill. He will gladly -- And most of the yards in west Anniston has pipe shop sand. And who told you that is where the PCBs came from? Well, I either read somewhere that the PCBs was used in the pipe making, but I can't recall just, you know, just when or where. But at one time I read that. The pipe shop sand -- a lot of Aroclor was sold to the pipe shop to use in their core making. I'm asking where I can't remember. Do you remember what kind of Aroclor it was? No. All I know is just Aroclor was used. And when you worked at the foundry did V REGIONAL REPORTING SERVICE, INC. i 84 1 2 A. 3 4 Q. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. NEWSOM: Object to the form. Ask that question again. It sounds like a trick question. No. I wish I was smart enough to ask trick questions. I'm saying to assume for the sake of my next question that there are documents from Monsanto that said PCBs were not sold for use in casting waxes in the kinds of foundries we have down here. Assume for the sake of my question that the EPA has gone out to all the foundries in this area and tested and not found evidence of large scale PCB contamination or any PCB contamination in some of the sites. Assume for the sake of my question that in areas where one can horizon out what appears to be sand from a foundry versus native soil, there is more PCB in the native soil than there is in the sand. Assume all of those facts for the purpose of my question, which would tend REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013994 65 1 2 3 4 5 6 A. 7 Q. 6 9 10 11 12 13 14 15 : 16 17 18 19 20 21 22 23 to indicate that foundry sand is not a source of PCBs, that PCB is being found all around this plant. AsBume all of those facts which you don't agree with, but assume -I'm following you. -- all of that is true. Would that then surprise you? Would you be surprised if PCB appears to have gotten from the plant into the neighborhoods around it? MR. NEWSOM: Let me object to the form of the question. It includes facts not in evidence, fails to include pertinent facts that will be in evidence, such as the Smith brothers, your own witnesses, and what they have testified to. Your question is asking him whether he was surprised. Are you now asking him whether with this additional information he is REGIONAL REPORTING SERVICE, INC. 87 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 Q. 20 21 A. 22 Q. 23 MR. CUNNINGHAM: I'm just being sure. MR. NEWSOM: Well, you gave him two possibilities, neither of which is what he testified to. MR. CUNNINGHAM: No. He said he didn't know about it. MR. NEWSOM: No. He said he didn't have knowledge, and you are saying it didn't happen. Your question includes two possibilities -read it back -- neither of which is what he testified to, which is that he didn't have knowledge of it. You can read it back. Are you saying it never happened, or are you saying you just don't know? I don't know. If there were documents in this case to show that PCBs got away from the dumps. REGIONAL REPORTING SERVICE, INC. 86 1 2 3 Q. 4 5 6 7 8 9 10 11 12 13 A. 14 15 16 17 18 0. 19 20 21 22 23 still surprised or not surprised? would you then -MR. NEWSOM: whether he is surprised or not surprised is not relevant either to anything. He is asking you a hypothetical question I guess. Further grounds. obviously he is not an expert, hasn't been designated as an expert. The only way I can answer is like this. I have no knowledge of PCBs leaving the plant from a spill or discharge. I have no knowledge of that ever leaving the plant there, you know, from Monsanto. Are you saying it didn't happen, or you just don't know about it? MR. NEWSOM: Object to the question. What he said was he didn't have knowledge about it. REGIONAL REPORTING SERVICE, INC. 88 1 2 3 4 5 Q. 6 7 8 9 10 11 12 13 A. 14 15 16 17 18 19 20 21 22 23 got out in the air, got out in the water from this plant, you are saying that would be the first you ever heard of it? MR. NEWSOM: Object to the form. If I showed you documents where people literally could see PCB in the ditches, leaving the dump, leaving the plant. where people measured PCB in the air around the plant, Monsanto people, that would be the first you have heard of that? MR. NEWSOM: Object to the form. I mean, yeah. Because I don't have any knowledge of it getting out. I have no knowledge of PCBs getting out of the plant, so I have to say that. MR. CUNNINGHAM: have. That's all I {The deposition concluded at 4:35 p.m.) REGIONAL REPORTING SERVICE, INC. HARTOLDMONO013995 89 1 I do hereby certify that the witness 2 whose attached deposition was taken before me 3 was by me first duly cautioned and sworn to 4 tell nothing but the truth in the cause 5 aforesaid; that the testimony contained herein 6 was by me reduced to writing in the presence 7 of said witnesses by means of stenography and 8 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 I am not 13 connected by blood or marriage with any of the 14 parties or their attorneys or agents and that 15 I am hot an employee of any of them, nor 16 interested in the matter of controversy. 17 IN WITNESS WHEREOF, I have hereunto set 18 my hand and affixed my notarial seal at 19 Gadsden, Alabama, County of Etowah, this 6th 20 day of January 2002. 21 Deborah Salers Garrett 22 Certified Shorthand Reporter Registered Professional Reporter 23 Notary Public, Alabama-at-Large My Commission expires: 3-6-05 REGIONAL REPORTING SERVICE, INC- CHATMAN. TXT j '30s 17:2 j `43 14:1 j '60S 17:4,9; | 30:6; 40:8; I 54:2; 56:13,20; | 73:21; 75:10 | '63 8:9,22; 15:2 | '65 8:15,22; j 15:2; 16:4; [ 17:12; 27:22; | 67:22 [ '66 18:9,10; ! 20:5; 31:16; i 67:22 | *69 13:22; 14:5, | 6; 67:22 j '70 67:22 | '70s 73:22 I '72 10:6; 38:16;, I 21 j '75 23:5,13; | 45:3,4 j '76 8:15 | '78 14:16 j '80S 27:5; 28:1 j '85 27:8 J *86 27:11,13; | 30:21 j '87 30:23 j `90S 29:21,22; j 63:15; 73:18 | '93 13 : 3,4 j '97 8:7,10,15; j 77:18 i '98 8:5.7; 29:22; { 31:8 j '99 29:22 1 1005 66:21; 67:13 1006 68:16 1013 69:5 1035 69:18 10th. 13 : 17 ; 14:6 12 66:23 1232 58:18 1254 45:21; 46:5, 12; 58:18 1260 45:23 1355 2:8 1407 8:22 1423 8:14; 78:4; 79:11; 81:14 1965 16:5; 31:16 1966 17:12; 19:12; 50:4 1968 14:2 1969 13:17 1971 10:6,22 1975 11:2; 24:23 1981 25:1 1986 26:17 1991 69:8 1996 66:23 2 200 2:3.5 2001 1:15; 3:8; 4 :1 2002 89:20 202 71:13; 75:9, 10 21 7:13 Page 1 2524 8:16; 78:5; 79:12; 81:17 28 1:15; 3:7; 4:1 3 3 2:11.5 3-6-05 89:23.5 30309 2:8.5 304 2:4 35901-0755 1:21.5 36268 7:14 3:10 1:14; 3:8 4 4 2:16.5 400 1:17 40202 2:4.5 41050 7:13 4:35 68:21 6 6 2:21 6th 89:19 7 750 2:8 755 1:21 8 89 2:12 A ABERNATHY 1:3.5; 4 : 13 able 22:11; 29:12,14; 56:18; 60:2 abnormal 69:6 above 9: 18 accumulated 33:13 accurate 89:10 acne 50:11; 68:21,23 across 65:17; 75 : 9 ACTION 1:5 activity 31:15 actual 31:14; 60: 17 actually 21:22; 27:6; 60:21 additional 10:2; 85:23 address 7:9,11,12 addressed 49:2 addresses 9:6 advised 51:17 advisory 57:8,14 aerial 74 :23 ; 79 : 4 affixed 89:18 afford 28:21 aforesaid 89:5,11 afternoon 72:23; 73 :1 afterwards 89:8 age 9:18; 69:18 agents 89:14 ago 37:17; 50:5; 53:22; 69:7; 72:14 agree 65:4 } agreed 3:2,9,15, | 22; 62:23 | ahead 11:11; | 38:12 j aided 89:9 j air 88:1,8 [ al. 1: 3.5,6.5 ; | 4:14 | ALABAMA 1:1,2,18, j 21.5; 3:6,7; | 4:1; 7:14,23; | 89:19 | Alabama-at-Large 89:23 | alcohol 13:5 | allowable 65:21 | allowed 35:21; | 36:1,3 | ambient 32:20 | ambiguous 54:10 | among 48:10 | amount 22:8; j 41:8; 80:7 | amounts 80:6 [ and/or 51:6 | animals 39:15 j Anniston 1:17; j 3:7; 4:1; 8:8,9, | 11,13,17; 9:2,7; j 15:3; 17:1; | 29:15; 61:19,21; j 77:16,18,22; j 79:7; 81:5,6,12, 1 14; 82:6 j announcement 27:7 | another 5:11,13; | 17:21; 20:19; | 23:4; 24:5; | 25:16,19; 43:13; | 69:5; 77:11 | answer 4:21; | 5:10,15; 52:21; | 54:11,15,18,20; j 65:19; 66:4; j 80:11; 81:1; | 86:13 | answering 5:8; j 67:17 | anybody 14:9; | 62:23; 65:4; | 68:12; 69:17 | anyway 14:5; | 30:6; 60:6 | appears 84:19; I 85:9 j April 16:14; | 18:10 j area 8:8; 9:2; | 18:1; 31:15; | 35:8,22; 57:23; [ 60:6; 61:9; j 70:15; 74:11,13; | 75:1,3; 81:21; | 84:13 | areas 51:14; | 57:5; 84=18 | Aroclor 10:23; [ 11:14; 15:11; j 16:3; 19:17; j 31:15; 32:4,8, j 13; 33:8; 34:19; j 35:23; 37:9,13; j 38:19; 39:22,23; j 40:11,15,17; j 41:21; 43:15; | 45:21; 49:8,14; | 55:16; 58:14,21; j 73:8; 74:2; J 76:18,19; 82:14, | 19,21 | Aroclor-containi | ng 4 0:6 [ Aroclors 37:2,6; ! 38:10; 45:8; | 50:10; 51:2,14, J 16; 52:12; 53:3; j 56:6 | around IB:10; [ 28:20; 30:11; | 31:19; 36:16; [ 62:21; 80:2; ! 83:22; 85:3,10; | 88 : 9 | Aside 12:15; j 14:20; 43:12 j assign 3:19 | assume 19:9; | 22:2,7; 42:17; j 47:3; 84:6,11, j 17,22; 85:3,5 [ as siimed 18:20 | assuming 25:6; | 32:19 | assumption 83:6 j ate 36:2; 64:23; j 65: 1 | Atlanta 2:8.5 | attached 2:22.5; | B9:2 | attended 47:3 | attorneys 12:5; | 89:14 | available 33:20, | 22; 35:1,3 | Avenue 8:14,23; | 78:4; 81:15 | avoid 56:7 | aware 40:5,15; | 70:9,13,17; | 73:19; 74:9; ! 76:19 ( away 56: 11; | 76:19; 80:20; | 83:20; 87:23 j jB j | back 8:2; 10:22; | 17:1; 19:10; j 23:13; 26:22; | 27:4; 30:15; | 31:3,8,20; 32:4; | 37:5; 40:2,8,10; | 50:4; 51:20; j 56:23; 57:16; | 72:16; 75:10; j 76:11,12; 87:14, | 18 | backwards 13:21 j bad 5:7,18; j 18:23; 75:18; | 83:18 j bag 33:3; 77:11 | bagged 55:4 | bagging 16:13,15; \ 18:11,12; 32:16, | 18,23; 34:22; | 53:7; 54:2 j bags 18:13; j 19:19; 55:3; J 77 : 10 j Bank 1:17 | Baptist 74:15 j barrel 42:18 | barrels 42:23; j 70 : 5 | base 61:16,23 j based 56:3; 80:21 | basically 19:8, j 17; 20:14; 33:1, j 0; 34:15,23; j 45:20; 76:8 | basin 74:19 | basing 83:6 | basis 24:14 j batch 75:18; | 76:3,13; 83:18 | batches 18:23 | became 21:9; 25:1 | beer 13:7 | began 18:9 | beginning 47:2; | 48:4,6 | behind 38:23; | 6B:17 | believe 5:9; 7:15 | below 56:19 j benzine 24:16; | 36:6; 44:1,12; j 45:1 j best 41:19; 75 : 7 ] Between 58:18 j bid 25:13 j big 36:4; 41:4 j billion 63:13; j 64:16; 65:5; j 66:20; 68:1 | biphenyl 23:6,13, | 15,18; 24:20; | 25:5,8; 27:3; | 31:4,10; 37:3; | 43:19; 44:3,14, j 17; 58:12,13; | 73:14; 76:9 ] biphenyls 45:10 j bit 30315; 32:22; | 52:23 j biweekly 24:13 j black 17:18 | blacks 17:11 j blended 24:19 j blood 63 :16; | 68:5; 89:13 J bodies 80:1 | bodily 51:1 I body 50:9; 53:17; | 54:8 | boiler 73:21 | boilers 73:2,5 | bombing 12:1 I books 12:17 j bora 13:23 j both 4:20; 14:10, j 11; 17:10 | bottom 36:21; | 43:20; 44:4; j 45:22; 46:1 ] bottoms 18:22; j 41:20; 43:12,14; j 46:9; 71:17; j 72:12; 77:4 | boy 41:4 | break 64:10; | 76:17,20,21 | breaks 36:16 | brilliant 5:11 j brothers 85:17 ] brought 72:10,11 ] Building 1:17; | 2:3.5 | bumped 26:22; | 30:21 j bunch 16:7 | burn 53:12; 55:7; 71:8 burned 73:2,16 business 29:13; 38:20; 78:13 busts 77:10 C C-h-a-p 66:8 C-h-a-p-m-a-n 6:16; 66:7 C-h-a-t-m-a-n 6 : 12 Calhoun 1:2; 4:15 call 8:19; 11:6; 25:20; 42:2; 74 :12 called 11:12,18; 16:22; 17:6; 37:6; 41:12; 46:13; 71:8,12;' 74:21 came 8:9; 27:7; 33:10; 37:8; 44:4; 59:18; 64:7; 65:9; 75:13; 82:9 cancer 12:23; 13:1 capacity 46:15 capping 16:11 caps 16:16 care 18:22,23; 35:17 I carried 41:11; j 42:7; 69:19; S j 71:13 I case 11:21; 37:2; j 87:22 | cases 34:18 | casting 84:9 j castings 15:8 j catalyst 24:20 ] catch 57:16,17; j 72:17 | cause 22:15; | 51:18; 52:13; j 53:19; 89:4 | caused 26:14; ] 38:18; 68:23 | cautioned 89:3 | ceasing 36:23 j cell 71:23; 72:1, I5 j cells 72:3 j Center 12:1 | certain 34:19,20; j 43:7 j certainly 5:14 | Certificate 2:12 j Certified 1:12; j 89:22 j certify 89:1,12 | chance 5:14; j 34:6; 60:21 | change 35:18 | changed 23:3; j 29:3; 50:17 | changing 74:7 j Chapman 6:15; | 65:15; 66:6 j charge 69:22 j CHARLES 1:9.5,11, j 2:3,15.5; 3:4; | 4:3; 6:9,11 | Charlie 4:9; | 49:16; 51:20 I chart 66:16 HARTOLDMONO013997 CHATMAN. TXT Page 2 charts 17:2 ! 62:3,22 1 ............................................. ! discharge 66:15 CHATMAN 1:9.5,11; j compare 59:21 1 o 1 discussion 27:4 2:15.5; 3:4; 4:3; 6:9; 7:10; | comparison 33:14 | .............................................. | disseminate 47:15 ] compilation 60:17 | daily 31:15; j distance 9:4; 9:13; 12:20 checked 29:18 | completely 5:15 [ compliance 3:13 | 48:3,4,12 j damage 22:16,18 I 78:19 J distinctive chemical 21:5,6; J compounds 69:1 j dangers 37:11; | 58:14,21 23:20,21; 27:16; j computer 89:6 | 38:9 1 district 78:13 36:12; 37:18,19; j concern 38:15,18; j data 60:18; 62:1; | ditches 56:11; 55:3,9,10,17,18, j 39:6; 65:16 | 66:17 | 88:6 23; 61:2 j concluded 68:20 j date 14:0,19; | divorced 79:7 chemicals 39:2; | condition 56:19 | 29:22; 38:14 | doctor 68:8 55:6,11,22; 56:8 | conducted 59:7 | dates 13:19; | doctor's 63:20; chief 25:1; 26:4, | conducting 61:18 8; 31:0,9,11,12; | confess 78:6 | 52:5; 53:4 | 64 :1 j day 14:18; 19:22; | doctors 68:3 46 : 16; 47:1,9, j conical 71:6 | 29:23; 35:14; | document 7:2; 12,23; 48:2,6, 11; 76:2 | connected 89:13 ( consist 34:1 | 57:11; 63:23; j 65:1; 89:20 | 45 : 14 | documentation chiefs 26:19 child 9:21 children 9:23; 10: 18 | consistent 6:3 | Consolidated 1:6 i consume 13:5,9 | consumed 13:11 | death 60:12,14 | 38 : 4 j deaths 60:8,10,11 | documents 12:17; | Deborah 1:12; j 16:23; 50:6; j 3:5; 89:21.5 j 84:8; 87:22; chloracne 66:16, j consuming 39:23 | debris 71:8 | 88 : 5 19,22 | contact 31:14; chlorinated 69:1; | 74:7 j 50:10; 51:1; 56:7; 60:1,2 | decade 52:11 j December 1:15; | 3:7; 4:1; 31:19 | doing 5:19; 15:5; j 18:18; 69:21,22 | dollars 82:3 chlorinating | contacted 11:20 | decided 30:13; | Donald 7:16 23 : 15 | contacting 59:17 chlorinator 41:21 | contained 40:17; | 59:19 | done 5:13; 30:19; | Defendants 1:7.5; j 61 : 19 Choccolocco | 89:5 | 2:6 down 4 :2 0; 32:2; 56:22; 57:3,6 ] container 46:10 [ defense 11:6 j 47:7; 63:19; choice 25:9 Church 74:15 cigarettes 14:14 Circle 0:16; 78:5,7,8,17; J containers 20:1; | 41:22,23; 42:3, | 15 | containing 15:11 | contamination j Definitely 58:1 j 65:9; 68:17; | degree 52:18 | 75:13; 79:19; 1 department 10:23; | 84 : 10 [ 11:13,14,19; | downsized 26:17; j 17:23; 16:3; | 28 : 4 79:12; 81:17 j 84:15,16 | 19:18; 20:6,7, | downsizing 29:7 CIRCUIT 1:1.5; 4 : 15 [ contract 28:7 ( control 13:2; j 11,19; 21:1,4; | draft 50:20 | 23:3.5,6,13,19; j drainage 56:11 CIVIL 1: 5 claim 30:11 clean 77:2 cleaned 66:1 cleaning 35:16 cleanup 15:6; 16:17; 18:21 clogged 19:1 close 9:7; 65:6 closed 27 :12 ; 28:11,14; 29:5, | 33:18; 50:21; | | 62:12 | \ controlling 24:20 j j controversy 89:16 | j cooled 32:21; j 33:1; 42:1 j j | cooler 13:7 j ( coordinator 26:10 | j copy 61:14 | j core 82:16 | correctly 31:13 | j 24:3,4,5; 25 ;3, j draw 22:3 5,7,8,16,19; 26:1,3; 27:1; j drawed 41:20; j 77 -.4 28:3; 29:5; J drawn 63:18 31:4,5,12; 32:2, | drew 22:4; 79:4 4,9,14; 37:9,14; j drum 46:4,5; 38:16; 40:11,14, j 76:10; 77:2 15; 43:15; J drummed 58:16 49:10; 57:20,21, j drumming 16:10, 23; 58:20; 59:1, | 3; 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3:6,23 committee 27:9; | CSR 3:5 | CUNNINGHAM 2:3, | device 71:6 [ devoted 48:16 |* |-- 30:1,18 [ committeeman 28:4 | 16.5; 4:8,9; 37:15; 41:4; | died 59:10,11 | each 24:6; 35:14; | differences 62:11 j 45:20; 47:2; committeemen 59:6 1 49:23; 51:12,22; | different 6:3; | 48:5,6,8; 59:1 committees 28:5 | 54:13; 73:9; | 16:8; 26:3,7; j earlier 37:4; common 82:1 community 7:15; | 87:1,7; 88:17 j curious 36:9 | 27:13; 45:15,18; | 62:16; 72:23 j 57:5; 59:2,3; j early 30:23; 59:22 | current 10:14 | 81:8 j 40:18 company 1:6-5; | CV-2001-832 1:5.5 j dig 81:18,19 | east 74:17 22:17; 23:2; ] direction 55:6 [ easy 6:7; 54:22 30:7; 35:10; j directly 61:15 j eat 35:21; 36:13, 1 17 | eating 36:9.1- , 18 j EDWARD 2 : 7 | effect 3:12 1 effects 49:16; 51:3; 65:19 effort 33:18; 73:20 1 eggs 58:4,10 eight 19:22; 21:8; 42:23; 46:1 eighteen 9:18; 15:1,10 either 9:16; 28:10; 38:3; 45:19; 82:10; 86:6 elevated 33:16 50:22; 53:15 eleven 16:3,19 eligible 9:18 employ 61:4 employed 15:21 employee 20:4; 38:2; 89:15 employees 30:13; 59:21; 60:5; 61:18; 62:2 employment 14: 23 enclosed 51:14 encountered 5: 4 end 27:11; 76: 5 ends 78:10 England 29:9,12 enough 54:11,17; 84 : 4 enter 6:21 entire 48:12 envi rotment 39:14; 65:22 environmental 28 : 18 EPA 84:12 epidemiologist 61:3 equipment 33:7 . 22; 34:1; 55: 14 equivalent 39: 22 era 10:22; 19: 12; 45:7; 75:10 eruption 50:11 Esq 2:3,7 essentially 19 :23 et 1:3.5,6.5; 4 : 14 ETOWAH 1:1.5; 9:17; 89:19 even 6:1; 30:17; 40:13; 42:4; 43:6; 47:4; 60:5; 63:1; 65:5; 83:3 event 38:1 eventually 24: 14 everybody 20:23; 47:17,19,21; 48:21; 59:17; 62 :21 everything 4:20; 24 :16 evidence 3:21; 6:21; 65:18; 84:14; 85:14, 16 evolved 49:14; 50:22 ex-employees 59:20 ex-wife 77:19 ex-wives 77:21 ex-workers 59:10 exact 29:21,23 exactly 5:21 EXAMINATION 4:7 examined 4:5 exceed 65:23 except 3:17 exclusively 18:16; 32:14; 46 : 16 executive 28:5 exhibit 6:18,22; 7:1 exhibits 2:22,23 expected 60:9 experience 11:18; j 32:6 expert 86:11,12 expires 89:23.5 explained 37:18 explaining 65:10 exposure 49:13; 52:19; 67:5 extensive 51:1 extreme 68:22 i ------------------------ -------------* --------------- -------------- face 34:9 facility 51:13; 62 : 13 fact 5:22; 12:4; 21:7; 23:20; 36:17; 40:16 facts 64:22; 85:4,13,15 factual 4:11 fails 52:17; 85:14 fair 9:4; 22:8; 70 :19 fairly 34:19; 40:21; 41:2 familiar 45:9; 51:4; 67:7; 74 : 13 family 3 9 1 fans 51:15 far 11:15; 17:5; 19:6; 26:2; 30:7,9; 36:5; 37:21; 38:22; 56:6; 60:6; 61:22; 64:19; 78:1,3; 80:20 fed 73:3,4 feed 20:17; 73:12 fellow 6:14; 72:23 female 11:1 females 10:21 fence 81:18 fifteen 7:19,21 Fifteenth 78:9, 12.13 fifty-eight 12:21 fifty-six 67:1 fifty-two 67:3 figure 79:3 filed 4:14 filing 3:23 fill 81:16; 82:1 filled 32:1 filling 19:18 final 24:21 financial 22:16 HARTOLDMON0013998 CHATKAK.TXT Page 3 t find 4:11; 21:19; j 67:5; 73:11 ( finished 5:10; j 18:16; 20:18; | 21:18; 31:19; | 32:16; 46:6,7 j finishing 21:20 j fire 72:17,19 ! first 4:4; 10:1, | 4 ; 11:1,20; | 15:15,16,22; j 16:2,19; 17:18; j 37:8; 52:1,12; j 79:8,11,15; j 88:3,10; 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68:15 | objections 3:16, j 21:8,10; 22:13, 70:3 j native 84:20,21 I 19 | 20; 24:1; 25:21; mentioned 69:18 | natural 73:3 | obviously 28:13; 1 33:15 me tal 41:22; | nature 52:16 | 86:10 j operations 21:7; 71:2; 72:21 i NE 2 : 8 | occasion 56:10, 40:7 mid 27:5,23; 30:6 ( near 49:2 | 22; 75:17 i operator 17:14, might 11:5; 12:5, 10; 27:6; 51:13; 55:4; 61:16; 62:12; 69:3,9 j nearest 52:10 l necessarily 69:12 j necessary 3:16 j need 4:21; 33:20 | October 15:2; | 20:5; 27:8; j 31:16 | Odor 58:21 | 19; 20:21; 21:2, j 4; 23:7,8,9,19; | 24:9; 26:5,8,9, | 23; 31:3,8,9; miles 7:19,20; j needed 35:2 j offered 2:20, | 40:13; 46:17; 78:22; 79:1 [ needles 21:14 | 22.S; 3:21; 30:7 | 47:1,9,23; 48:2, Miller 1:16 [ negotiations 28:7 j office 61:6; mind 29:3; 37:20; j Negro 17:3,7 | 63:20; 64:2 | 7; 75:16,22; j 76:2 38:8; 50:18 | neighborhood 8:12 | offices 1:16 } operator's 18:5, mine 5:7; 14:15; | neighborhoods | often 43:3,8 | 7; 19:5,21; 65:6; 67:9,19 minute 27:16 j 83:22; 85:10 | neither 28:14; | Ohio 61:8 j oil 3 9;2 3 | 45:12 | operators 20:10; miss 49:2 Missionary 74:15 ! 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67:6; 75:3 | particularly | 36:7; 59:5 ] parties 3:3; j 4:13; 89:14 | parts 20:15; j 63:13; 64:16; | 65:4; 66:20; | 68:1 | passed 47:6 | Paul 8:16; 78:5, | 7,8,17; 79:12; | 81:17 | pay 2 6:2 j PCB 10:12; 15:11; | 29:18; 59:13; | 62:18; 65:6,21; | 69:19; 83:3,10; | 84:15,20; B 5:2, | 9; 88:6,8 PCBe: 11 : 14 26 : 19; 30 : 12 ; 34 : 18 ; 37 : 1, 3 ; 38 : 10; 56 : 1 ; 59: 18 ; 65 : 17 68 : 3,9 ; 7 9 : 2 3; 80 : 13 ; 81 : 8 ; 82 : 8,1 1 ; 83 : 5, 13, 16, 20; 84 : 8 85 : 2 ; 86: 14 ; ] 87:23; 88:15 | Peachtree 2:8 | pentasulphide j 20:6,12,13 | people 34:17; j 39:20; 46:18; j 47:15; 51:19; j 52:14; 60:2; | 61:22; 63:7,9, j 11; 72:20; 74:2, j 6,11,21; 79:22; j 88:5,8,9 | people's 66:18; [ 80:1; 82:3 ] per 26:14; 29:7; | 63:13; 64:16; | 65:5; 66:20; | 68:1 j perform 21:3 | perhaps 59:5 | period 42:10 [ person 26:11,13; j 57:19; 68:17 J personal 33:23; | 56:17; 62:14 ( persons 11:5 [ pertinent 85:15 j phasing 38:19 | phosphorus 20:6, I 13.15 [ photograph 79:5 | photographs j 12:17; 74:23 j physical 22:17 | physician 63:21, I 22 j pine 8:14; 78:4; | 79:11; 81:14 j pioneers 17:16 | pipe 15:7; 76:20; | 81:6,7,12,15,19, | 20,23; 82:2,6, | 11,14,15 [ pipes 76:16 j place 36:5,10 | places 8:3 | Plaintiffs 1:4.5, | 15; 2:2 j Plaintiffs' 2:20; I 6:18 I plant 6:15; 9:4, 8; 10 : 21 ; 11 : 2 ; 16: 21 ; 17 ; 1 20: B; 25: 23; 26: 17 , 18, 20; 27: 5, 19; 28: 4 10, 14 ; 29 : 4 , B; 30: 11 ; 31 : 11 ; 40: 6; 45: 15; 46: 18 ,19; 47 -.18 55: 9, 10,18,23; 56: 8, 12,15,19; 57: 19 ; 59 - 9, 13 ; 60: 5 61: 20, 21; 62: 8 21; 63 : 21, 22, 23 ; 66 ; 8 , 18; 70: 11 ; 74 : 2 ; 78 . 20 ; 8 0 : 2, 21; 83 21 , 22; 85 : 3 , 10, 86 :15 , 17 ; 88 : 2 , 7,9, 16 plant-wide 26:19; 60:20 plants 29:7 play 18:21; 70:10; 74:1 please 6:8; 8:4; 13:14; 40:9 | { | | | | j j | | | | } j j j j | f | | J j | j | j | | | \ | j ( | | | j | | | | j | | | ( I I | j j j ) | j | | HARTOLDMONO014000 CHATHAM. TXT PNP 59:3 point 30:17 policy 36:15 pollution 62.-13 polychlorinated 37 : 3 polyphenyl 26:23; 27:2; 29:14; 31:4 pond 74:18 population 60:9 position 17:21; 20:3; 23:1 possibilities 49:22; 50:2; 87:4,13 possibly 22:17; 52:13; 66:2 post 61:18 potential 9:19 potentially 11:21 pour 70:7 practice 42:17 precise 22:3 predominantly 73 : 4 presence 89:6 present 51:15; 65:8 press 38:6 presume 10:17; 44:8; 68:21 presuming 22:14 pretty 12:21; 18:15; 22:2; 32:14,19; 78:19; 83 : 14 prevent 51:2 previous 5:4; 32 : 5 prior 3:21; 8:2 privacy 67:12 probably 11:22; 13:22; 24:10; 57:2; 59:1; 61:8; 64:23 problem 30:10; 33 : 21 problems 12:23; 39:14; 51:18; 52:9,14; 60:7,13 procedure 22:22 process 23:20; 33:6; 46:8 processed 21:5 processes 45:6 processing 18:19; 34:21; 77:7 product 18:16; 19:23; 21:18,19; 24:21; 32:16; 46:6,7; 58:6; 73:5,10; 74:8; 75:23; 76:1 production 39:1 products 13:9; 15:12; 20:18; 35:23; 74:8 Professional 1:13; 89:22.5 professionals 61:23; 65:8 prolonged 49:13 property 77:15, 19,21,22; 79:11, 13 prostate 13:1 protect 67:11 j protection 50:23 | protective 33:23 | proven 52:7 j provided 35:5,13, j 18; 36:15; 37:1; [ 38:4; 62:4; j 66:17 J providing 11:8 | Public 3:6; 89:23 | pulled 41:23 | pulling 67:14 ! purpose 84:23 j pursuant 1:18 | push 42:19 j put 16:16; 18:13; | 20:9; 42:21; | 70:5; 71:21; | 76:10,12; 77:3, J 10; 81:18; 83:14 | putting 19:23; j 44:1,2; 54:3; | 70:4; 72:8; 73:21 Q qualified 22:11 quantities 40:22 question 5:8,12, 13,19; 17:20; 40:9; 47:8; 52:16; 53:21; 54:1; 56:3; 65:15; 66:3; 84:2,3,7,12,17, 23; 85:12,19; 86:8,21; 87:12 questioning 65:14 questionnaire 67:5,12,18 questionnaires 68:14 questions 3:17, 18; 4:10; 40:18; 66:14,15; 84:5 Quintard 78:9 quit 13:16; 14:5, 6,15 quitting 14:12 R race 17:5,8 railroad 78:14 Ran 44:15 rather 68:22 rationale 38:23 rats 52:8 raw 43:21; 66:17 react 20:16 reactor 24:17 read 49:11; 65:3; 79:21; 80:5,8, 22; 82:10,13; 87:14,18 readily 62:22 reading 3:10; 50:9,18 real 36:21 realise 57:8 realized 28:18,20 really 13:18; 16:11; 30:23; 42:14,15; 45:7; 64:2; 68:6; 71:1; 80:16 reason 39:12; 67:14; 79:6 recall 19:14; resided 8:3 | screen 71:7 27:19; 34:12; respective 3:3 } screwed 22:15 38:1,7; 50:8; responsibilities i se 26:14; 29:B 51:17; 54:5; 26:7 | seal 77:5,12; 55:16; 59:5; responsible 1 89:18 63:6,12,14,15; 22:12; 26:11,12; | sealed 41:22; 66:2; 67:17; 35:15 ( 42:4,6 71:9; 72:5; result 67:16 | sealing 42:5 74:4; 75:7; results 30:16; j seam 76:21 82:12 recollection 65:11 retention 74:18 { second 5:18; j 79:9,10,12 43:2; 76:23 retired 15:20; | secondly 5:2 recollections 59:21 | sections 27:14 12 :9 retirees 63:1 ! see 11:22; 18:17; record 6:11 return 74:2 j 30:14; 34:21; records 12:17 returns 74:4 i 43:5; 52:23; recycle 70:19; reworked 76:9 | 56:10; 59:17,22; 73:15; 76:14 rice 39:23 | 60:17; 63:20; recycled 76:8 risk 59:23 | 71:5; 73:15; reduce 73:20 role 18:21; i 81:10; 02:1; reduced 30:22; 70:10; 74:1 j 83:1,10; 88:6 89:6 reference 65:14 referred 39:19 roll 42:18 rolled 26:20 room 17:15 ] seems 60:21 j seen 7:1; 16:23; j 72:20 referring 69:10 rotate 24:13 | selected 20:10 regard 37:1 rotated 24:12; | self-evident regardless 21:1 Regional 1:20.5 43:6 rotating 19:15 j 17:22 j send 21:18 Registered 1:13; rotten 58:4,9 | senior 6:9; 9:22 89:22.5 roughly 63:6; | seniority 25:15, regulatory 65:20 69:8 [ 17; 26:21 relating 3:14 RPR 3:5 \ sense 25:11 relative 56:15; rubber 35:1 | sent 61:13 64 :19 rule 36:10 ) September 8:5,7; relatively 9:7 rules 3:13 I 11:22 relatives 9:16 run 44:12,18 | serum 10:12; release 57:17 ruptures 76:15 I 66:18 releases 38:6 | serve 9:19 relevant 86:6 relieve 19:20 S | Service 1:20.5 | set lift; 24:8; remember 10:20; S-t-a-m-p-s 10:10 | 65:20; 89:17 14:19; 19:7; SABRINA 1:3-5 | settings 35:6 27:8; 29:21; 39:17,18; 42:9, safe 48:8 safety 33:22; j several 24:6; j 42:15 14,16; 43:8; 34:3,8; 46:20, | shall 3:16 44:5; 49:3; 50:3,4,6,13,14; j 23; 47:1,4,10, j 17,22; 48:7,17, | share 12:9 | sheet 67:6 52:22; 53:4; | 20; 50:15; 1 shields 34:5,9 64:2,6; 66:15; 71:10; 72:6,7, | 59:16; 60:19,20 j sake 84:6,11,17 | shift 19:10,14, j 16; 24:6; 26:10, 13; 76:13; 77:6; [ Salers 1:12; 3:5; j 82:18,19 j 89:21.5 | 14; 47:2; 48:4, 5,6 remind 46:8 rep 27:16 j same 3:12; 10:17; | shifts 19:13,15; j 18:14; 20:23; | 26:12 repeat 40:9; | 23:20; 27:3; [ shirts 35:9 47:8; 53:21; 54:1 | 50:16; 59:13; j 72:9 [ shoes 34:3,8; j 35:9 repeated 49:15; 50:9 j sample 22:4; 67:6 | shop 27:23; Bl:7, jj sampling 21:16,17 12,15,19,20,23; reported 19:9; 67:1 } sand 81:7,12,15, j 20,23; 82:2,7, | 82:2,6,14,15 | Short 31:21 Reporter 1:13,14; ] 89:22,22.5 j 14; 83:14; 84:19,21; 85:1 | Shorthand 1:13; | 89:22 Reporter's 2:12 j Santowax 43:17; j Show 19:16,17; Reporting 1:20.5 | 76:10 | 87:23 representation [ saying 17:9; ( showed 50:7; 88:5 69:15 representative 46:16 j 44:6,7; 48:12; { 69:13; 73:7; j 81:13; 83:19; | shut32:2 | sick40:1 J side8:19;42:19; representatives | 84:6; 86:18; | 79:16 27:10 | 87:11,19,20; [ signature 3:10 requested 30:2; ] 88 :2 ) simply 68:22 62:17 j says 65:16; 67: IS | since 6:10; 12:4; required 50:15,16 ] scale 84:15 j 13:17; 53:2; requirements { scavenging 72:20 | 62:20; 64:22 50:16 j schedule 72:15 | Sir 4:9; 10:19; researched 29:11 [ scheduled 11:23; [ 11:1; 12:11,19; reside 9:17 J 39:9 j 13:10,12; 14:19; Page 5 22:1; 23:17; J 24:2,22; 31:17; 45:11; 46:10; j j 75:5; 76:1; 81:1 j sister 29:8 j sites 84:16 j sitting 28:19 j Six 10:1 | six-pack 13:7 j sixteen 13:15 j sixty-two 69:18 | skin 51:18; 52:9, | 14; 54:8; 56:7 J skinny 71:1 j skits 69:21; 70:6 | sleeves 34:4,6; J 55:13 | slipped 36:2 j small 29:7 | smaller 26:19; | 60:9 .j smart 84:4 j smell 57:22; j 58:14,23; 59:2,4 | smelled 58:3,5.8, | 9 SMITH 2:7.5; I j 85:17 ( smoke 35:21 | smoked 13:17; | 14:10,17 [ smoker 14:3 | smokes 14:18 j smoking 13:15; j 36:5 j Smooth 15:8 | Snow 56:14,19 | soil 84:20,21 I eold 27:6,11; j 26:11,15; 82:15; J 84:9 j solid 33:10 | Solutia 11:5 | somebody 49:1; 62:3; 83:20 | \ someone 26:21; [ 38:5; 65:13 | something 6:1; j 14:7; 28:13; | 38:B; 43:1; | 49:11,20; 51:3; 54:22; 61:16; | j 75:18 | sometime 12:2; j 29:22 [ sometimes 36:2; [ 39:19 | somewhere 61:9; j 82:10 | sorry 48:10; 67:3 sort 15:11; 19:3; 21:3; 35:4; | j j 36:9,10; 38:4; | 58:21; 73:19 j sound 5:20 j sounds 6:1; 64:2 | source 83:15; J 85:2 | jsouth 7:13,16,20; 71:12,13; 76:7 j southeast 79:17 j SouthTrust 1:17 | spec 21:20; 75:20 | specific 16:9; 55:17; 56:5 specifically 17:3 | j J spell 66:5 | Spelled 6:12 | HARTOLDMON0014001 CHATMAN. TXT Page 6 | Spells 31:23 j spent 19:22 | spherical 71:7 j spill 77:9; B6:15 J Spill 76:15 | splattering 34:7 j spoke 38:6 | sport 57:15 subdivision 6:17; j 78:18; 81:22 j 28:17; 36:20; 50:19; 53:13 Subject 52:20 \ things 16:8; subsequent 37:23 | 19:1; 34:12; substantial | 37:10; 49:2; 40:22; 41:3 j 52:4,17; 53:1; suggest 39:11 | 72 :17 suggested 83:20 j thinks 54:18 | turn 20:17 | turning 21:11 [ twenty 7:19,21; I 65:4 | twenty-five | 13:16,19 j twenty-four j 63:13; 64:13,14, valves 21:12; 76:16 vapors 49:14; 50:21 various 34:11; 70:5 ventilation 35:4; 50:21; 51:6,16 j 89:1,11,17 | witnesses 85:16; | 89:7 I words 4:22; 12:7; | 43:23; 72:9 j wore 35:10 | work 6:10; 13:20; j 14:20; 15:18,23; j spot 72:10,12 suitable 50:20, | thirteen 7:20 | 15,16; 65:7; versus 1:5.5; ( 17:10,11; 18:1; | spots 81:16 23; 51:6 j thirty-one 67:21 | 66:20; 67:15; 4:14; 84:19 | 19:9,10; 27:22; j springs 8:6; 9:3; j 79:15 | stack 71:2 j Stamps 10:9 { Standard 34:2 [ s tands 38:7 j Start 6:7; 15:22; | 52:9; 54:22 i started 13:15; Suite 1:16; 2:3.5,8 j Thomas 6:9,11 j though 14:5; sulfur 20:15; j 22:2; 42:4 SB : 6 ; three 24:3; supervisor 59:16 j 31:17; 32:12; supposed 21:15 ] 60:1; 70:22 surgery 66:8 j throughout 16:21 surprise 80:8,19; j throw 57.-16 81:2,3,4; 83:19, | title 16:1; j 68:1 j two 10:2; 13:7; j 20:14; 24:3,5; I 27:13; 31:17; ] 32:10,11,12; j 35:2; 60:1,3; j 78:22; 81:5,13; j 87:4,13 j two-man 21:8 vessel 24:17 visited 62:7 visitors 58:2,7 voluntary 63:4 W | waived 3:11,23 ( walk 57:22 | 29:18; 30:22; [ 31:15; 37:9; 1 48:13; 49:5; | 59:8; 65:10; 1 69:9; 77:7; | 78:17 | workday 54:5 | worked 10:21; j 11:1,12; 12:8; j 15:5; 20:5; 23; 85:8 | 20:20; 21:1; I type 11:7; 48:18 | Walnut 1:21 | 34:18; 47:16; j 31:18; 49:8; j 73:17 j STATE 1:1; 4:1 | status 26:2 | stay 29:9 | stenography 89:7 | step 25:11,20; j 26:5 | steps 29:17; | 62:12 | Stevens 8:23 surprised 49:6; j 26:16; 28:1; ( typed 65:13 85:8,21; 86:1,2, | 31:6 ' 5 i tobacco 13:9,11, I types 34:19,20; j 35:3 surprisingly | 13 64:22 [ today 4:11; survey 59:20; | 12:20; 23:21; 60:15 | 31:9; 37:4; j under 13:2 swallowed 55:5 | 50:16,17; 73:14; I understand 4:19; Sweet 74:12,22 j 75:14; 77:16,17 | 6:3; 11:4; sworn 4:4; 89:3 [ together 14:16; | 29:11; 31:13; system 19:1; | 20:16; 24:19; | 38:21; 41:5,7; l wanted 22:3; | 25:15,22; 35:3; | j 57:19; 63:2; 64:23; 66:12; | 36:19; 47:12; | 82:23; 83:4,5 ( 62:10; 63:1,2 | worker 66:23 | warehouse 40:18; j 41:13 | workers 27:18; j 46:18; 59:10; { warm 32:22 j 61:2; 62:17; j waste 40:6,16,19; j 68:15 j 41:11; 43:10,12; | working 18:15; j 45:16; 46:13; j 32:6; 36:19; j 73:5,9,15,20; | 39:3; 40:10; ) steward 27:23; 22:9; 25:14; | 44:2; 76:4 | 44:5; 52:21; | 77:11 ( 49:9; 53:6; j 28:3 | Stewart 7:16 76:11,12 systemic 49:16 [ took 29:17; | jj 35:17; 41:10,14; 53:8; 60:12; 64:16 j watch 76:3 | water 72:4; 88:1 j 54:4; 75:16,19 | world 15:17; | sticks 37:20,21 j Still 14:17; | 15:21; 17:8; J 18:18,22; 30:18; j | 31:10; 40:14; j j 41:21; 43:12,14, j talked 12:3,12; 45:17; 65:9; 68:6,11 44:12; 46:11; 63:17; 71:16,IB top 71:7 j toss 76:6 j total 10:1; 32:7 t toward 49:5 | understanding | waxes 84:9 j 11:7; 36:12; ] way 5:19; 12:16; j 54:6; 60:4; 75:2 | J understood 50:20; j | 53:18; 60:14 j I unfair 56:2 I 21:15; 22:3; 33:14; 47:6; 62:11; 78:10; 86:13* | 49:21; 50:1 | writing 89:6 j wrote 68:17 | 23; 45:21,23; j 46:9; 63:21; | talks 69:5 j tank 76:21 | 71:17; 72:11; j tanks 76:17 j| 77:19; 80:14,15; task 21:3; 24:9 j 86:1 | temperature | Stills 45:20 | 32:20; 33:16; j toxic 39:15; | 49 :16 | union 8:18,19; | wear 50:15 i 15:1,2,10; 27:9, ] wearing 55:12 j y'all 19:9; 37:5; j 45:8; 75:17 | toxicity 37:10; j 16,17,20,21; | weekly 24:13 j yard 81:11,18; jj 38:9; 49:8; 56:6 29:16; 30:3; j west 2:4; 8:8,11, j 63:12 | toxicologist 61:3 | 46:16; 59:6,14; j 13,17; 9:2,7; | yards 80:1; 81:5; | tracks 78:15 | 61:1,2; 62:17; j 15:3; 77:15,18, l 82:3,6; 83:7 | STIPULATED 3:2,9, | ( 15,22 | | stipulations j 1:18; 2:11.5 | j 53:16 temperatures 33:2; 49:15; 50:22 | Trade 12:1 { trained 22:10,21; j 24 : 12 | training 31:19 | 78:11,16 ( Unless 57:15 | until 8:9,15; j 14:16; 31:16; j 21; 78:11; 79:6; | year 8:9; 11:23; j 81:5,6,11,14; I 12:21; 31:20; j 82:6 | 40:19; 63:16 | whatever 17:7; j years 8:1; 23:10; | Stock 20:17; | ten 42:23 j transcribed 89:6 | 78:10 | 46:2,12; 58:18 | 24:10; 30:5; | 73:13 ] tend 84:23 j Stop 39:12 | tepee 71:4,8 |] stopped 38:17,22; term 31:21; 37:5 j 53:2; 74:6; 82:2 | terms 59:9 | straight 79:4; j test 30:13; 69:6 | 81:10 | tested 10:15,18; | transcript 89:10 j transcription j 89:9 | transfer 23:22; j 39:21; 41:13; | 43:16,17 - | untoward 51:2 j whenever 14:9; J up 12:10; 14:12; j 41:9 | 15:17; 19:16,17; I WHEREOF 89:17 | 20:5; 21:22; | whether 34:14; j 22:15; 25:11,21; | 36:14; 46:12; | 26:5; 31:18; j 57:3; 75:2; ( 32:8,10,11,13; j 34:2; 53:1; j 67:1,3,4,21; J 69:7; 80:13 ) yourself 21:23; I 60:22 | s treama 40:16; j 45:16; 73:20 j 30:1; 62:18,22; | transferred 1:2; j 32:1; 3B:5; | 63:3,7,10,11; j 58:11 j 41:11,17,18; 80:17; 85:20,22; 86:4 I Street 1:21; 2:4, j 8; 7:11,12; j 8:12; 65:17; j 78:13 j j { j 66:10,13; 77:23; | trans ferring 83:8,12; 84:14 j 40:19 testified 4:5; 51:10; 85:19; j trash 16:18; ] 69:21; 71:8,16, j 42:7,9,12,18; ) 45:1; 46:11; | 49:21; 61:8; | 64:1,6; 65:4,13; whited 67:11 whites 17:10 whole 50:1; 89:10 widespread 61:20; / 1:8 | strict 55:12 | strong 58:22; | 65:18 | study 59:7; 60:4 | Stuff 16:18; | 19:3; 21:14,16; | 87:5,15 | 20; 72:10 j testify 12:1,5 j trial 3:20 j testifying 11:21 j trick 84:3,5 | testimony 5:5; | trip 42:13 | 11:8,16; 89:5,11 | trouble 36:4 j testing 30:2; | truck 42:21,22; | 66:1; 69:15; 81:9 j 70:6; 71:4,11, wife 10:2,4,14; j 14,16; 72:10,11, 14:10; 35:15; j 17,19,20; 75:9; j 79:8,9,10,11,12 | 76:11; 77:3,5, j wife's 9:12 | 13; 81:19 j will 5:7,9; 89:21 | 32:19; 39:13; j 59:14 j 43:3; 82:2 | upgrade 26:1 j 14:21; 17:17; | 41:17; 42:8; | theoretically | true 69:13; 85:7; Usho 39:20 ( 49:16; 82:5; | 43:4; 47:13; (52:13 | 89: 9 85 : 15 | 53:6; 54:3,7.21; ( therefore 4:21 j trust 21:23 V wine 13:7 J 57:5; 72:8; | thereto 3:21 j truth 6:4; 89:4 j 73:21; 74:6; | Therminol 23:22; ] try 62:10 j 75:6,8; 76:3,6, ] 43:21 j trying 49:5; vague 49:18; 54 : 10 wish 84:4 within 13:8 witness 2:15.5; I 15 ) styled 4:13 ] thing 5:18; j 18:14; 27:3; | 53:21,22,23 j tubes 44:16 Valley 74:12,22 valve 76:21; 77:8 3:11; 11:4; 12:13; 64:5,11; HARTOLDMONO014002