Document qa3Ee5zNwRRKvomDpnj84egqq
1 STATE OF ALABAMA
IN THE CIRCUIT COURT FOR ETOWAH COUNTY
2 (Transferred from Calhoun County, Alabama)
3
SABRINA ABERNATHY, etal.,
4
Plaintiffs,
5 CIVIL ACTION NO.
versus
CV-2001-832
6 (Consolidated)
MONSANTO COMPANY, et al.,
7
Defendants.
8/
9
DEPOSITION OF AARON TAYLOR
10
11 The deposition of AARON TAYLOR was
12 taken before Deborah Salers Garrett, Certified
13 Shorthand Reporter, Registered Professional
14 Reporter, as Commissioner, commencing at 11:00
15 a.m. on December 28, 2001, by the Plaintiffs,
16 at the law offices of Fite & Miller, Suite
17 400, SouthTrust Bank Building, Anniston,
18 Alabama, pursuant to the stipulations set
19 forth herein.
20
Regional Reporting Service, Inc.
21 755 Walnut Street
Gadsden, Alabama 35901-0755
22
23
Page 1
Page 3
1 STIPULATIONS 2 IT IS STIPULATED AND AGREED by the 3 parties, through their respective counsel, 4 that the deposition of AARON TAYLOR 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 11:00 a.m. 9 IT IS STIPULATED AND AGREED that the 10 signature to and reading of the deposition by 11 the witness is waived, the deposition to have 12 the same force and effect as if full 13 compliance were had with all laws and rules of 14 Court relating to the taking of depositions. 15 IT IS STIPULATED AND AGREED that it 16 shall not be necessary for any objections to 17 be made by counsel to any questions except as 18 to form or leading questions and that counsel 19 may make objections and assign grounds at the 20 time of trial or at the time said deposition 21 is offered in evidence or prior thereto. 22 IT IS STIPULATED AND AGREED that notice 23 of filing by the Commissioner is waived.
1 APPEARANCES
2 For the Plaintiffs:
3 HARRISON COLEMAN, Esq.
KASOWITZ, BENSON, TORRES & FRIEDMAN, LLP
4 1633 Broadway
New York, New York 10019
5
CHARLES CUNNINGHAM, Esq.
6 Morrissey Building, Suite 200
304 West Liberty Street
7 Louisville, Kentucky 40202
8
For the Defendants:
9
EDWARD M. NEWSOM, Esq.
10 LAWRENCE J. MYERS, Esq.
SMITH, HELMS, MULLIS & MOORE
11 Suite 750, 1355 Peachtree Street, NE
Atlanta, Georgia 30309
12
INDEX
13 Page
Stipulations
3
14 Reporter's Certificate
68
15
EXAMINATIONS
16
Witness: AARON TAYLOR
Page
17
By Mr. Coleman
4
18
19 EXHIBITS
20 Plaintiffs'
Marked
Offered
21 One
4
22
No other exhibits were marked for
23 identification, offered or attached as
exhibits hereto.
Page 2
Page 4
1 STATE OF ALABAMA, ANNISTON, DECEMBER 28, 2001
2
3 AARON TAYLOR,
4 after having been first duly sworn, was
5 examined and testified as follows:
6
7 EXAMINATION
8 BY MR. COLEMAN:
9 Q. Mr. Taylor, my name is Harrison Coleman.
10 I'll be taking your deposition this
11 morning. 1 work for the plaintiffs in
12 this case.
13 Would you please state your full
14 name for the record, please?
15 A. Jessie Aaron Taylor.
16 MR. COLEMAN: And, Mr. Myers, did
17 y'all have an opportunity to
18 talk about the notice of
19 deposition?
20 MR. MYERS: 1 didn't ask him that.
21 (Plaintiffs'Exhibit Number
22 One was marked for
23 identification.)
Pages 1 - 4
HARTOLDMONO019042
1 Q. 2 3 4 5 A. 6 Q. 7 8 9 10 11 12 13 14 15 16 Q. 17 18 19 A. 20 Q. 21 22 23
Page 5
Have you seen this document? It is a
1
notice of deposition requiring you to be
2
here at this office to take your
3
deposition.
4 A.
No. 5 Q.
In this notice of deposition we had
6
asked you to bring along any documents 7
in your possession which are responsive 8
to that request. Can you just scan
9
that --
10
MR. MYERS: Read it if you would, 11
Mr. Taylor. Take your time,
12
and read one, two, three, and
13
four. Go ahead and take a
14
minute and read that.
15
Do you have any documents in your
16
possession or at home that are
17
responsive to those requests?
18
No, not to my knowledge.
19
Okay. If you come across any documents;20 A.
that you believe are responsive to these 21
requests, would you please make them 22
available to your attorney, who will
23
Page 7
that dealt with PCBs. Mr. Taylor, have you had a
deposition before? Yes. So you know the rules about speaking clearly and verbally. In other words, don't give an uh-huh or uh-uh as an answer because the court reporter here is going to trying to take down everything, you say and that doesn't come across very well in the record. So if you will please do that, we will all appreciate it.
If you don't understand my question, just let me know and I'll rephrase it. If you need to take a break or want a timeout to talk to your attorneys, just let us know, and we will do that? Okay.
MR. MYERS: And try to speak up just a little because there is a fan over your head.
Page 6
Page 8
1 then review them and make them available
1
THE WITNESS: Okay.
2 to us?
2 Q. Will you please state your current
3 A. Yes.
3 address, please?
4 MR. MYERS: And without speaking
4 A. 4700 Amberwood Drive, Anniston, Alabama,
5 for Mr. Coleman, what they
5 36207.
6 are interested in is anything
6 Q. Where in relation to the Monsanto plant
7 other than what might have to
7 is your home?
8 do with your retirement and
8 A. East.
9 benefits and things like
9 Q. How far?
10 that.
10 A. Approximately five miles.
11 Q. For example, did you take any MSDSs home 11 Q. Okay. Have you ever lived anywhere else
12 with you?
12 in Anniston?
13 A. No.
13 A. Yes.
14 Q. Did you take any safety manuals home
14 Q. Would you mind going through those
15 with you?
15 addresses starting with the first and
16 A. No.
16 moving forward?
17 Q. While we are on the subject, are you
17 A. How far back?
18 retired from Monsanto?
18 Q. Have you lived here all your life?
19 A. Yes.
19 A. Yes.
20 Q. Those are the types of documents and
20 Q. Okay. Let's say from the '60s forward?
21 materials we are talking about, and
21 A. 1 lived in Saks, north Anniston.
22 specifically also that relate to PCBs or
22 Q. Okay.
23 your work in any department at Monsanto
23 A. 1 lived west of the Anniston plant in
Pages 5 - 8
HARTOLDMONO019043
1 2 Q. 3 A. 4 Q. 5 A. 6 7 Q. 8 A. 9 Q. 10 A. 11 Q. 12 A. 13 Q. 14 A. 15 16 Q. 17 A. 18 Q. 19 A. 20 Q. 21 A. 22 Q. 23 A.
Page 9
the Wellborn community. Wellborn? Yes. Okay. And when did you live there? From --1 think it was 1965 until 1972
- '92, I'm sorry, '92. 1992? Yes. Where is that in relation to the plant? West. How far west? About two miles. And after 1992 where did you live? In the general vicinity where 1 am now,
in the Golden Springs area. Okay. Are you married? Yes. Do you have children? Yes. How many children do you have? Two. Where do they live? One lives in the Dearmanville area,
1 A. 2 3 Q. 4 A. 5 Q. 6 A. 7 Q. 8 A. 9 Q. 10 A. 11 Q. 12 A. 13 14 Q. 15 A. 16 Q. 17 A. 18 Q. 19 A. 20 21 Q. 22 A. 23 Q.
Page 11
I'm going to have to guess at these dates.
That's fair enough. About 1966. Okay. And after 1966? Storeroom. Okay. Shipping and receiving. What was your title in there? Just storeroom clerk. How long did you hold that job? I'm going to say one year. 1 don't know. Okay. And -Chief operator. Okay. Biphenyl department. From '67 to when? I'm going to say '77, in that general vicinity. Okay. And then after that? Maintenance department. What was your title?
Page 10
Page 12
1 which is east of Anniston. The other
1 A. Millwright, mechanic.
2 one lives in Alpharetta, Georgia.
2 Q. Okay. From 1977 to--
3 Q. How about grandchildren? Do you have 3 A. About '80, 1980, maybe.
4 any grandchildren?
4 Q. Was that also in the biphenyl
5 A. Yes.
5 department?
6 Q. When did you -- When did you start
6 A. In the maintenance department you work
7 working for Monsanto?
7 all over the plant. Then 1 became an
8 A. 1961.
8 electrician, E and 1, title is E and 1.
9 Q. 1 want to go through your job history at
9 Q. From 1980 until when?
10 Monsanto job by job beginning in 1961 up 10 A. Retirement.
11 until your retirement with Monsanto.
11 Q. What year did you retire, again?
12 What 1 would start with is if you will
12 A. 1994.
13 just give me your job title and the
13 Q. Okay. And were you an electrician, E
14 years in which you held that job. And
14 and 1 all over the plant or in one
15 let's start at the beginning and work
15 particular department?
16 forward. Then we'll go back, and 1 want 16 A. All of the plant.
17 to ask you about your responsibilities
17 Q. Okay. Now, if you don't mind -- and
18 in those jobs. For now let's just start
18 this may take a little while since you
19 with the list. 1961.
19 had five occupations at the plant. 1
20 A. Operator.
20 just want to kind of ask you some
21 Q. In what division?
21 general questions about what you did
22 A. Aroclor.
22 there and what your responsibilities
23 Q. Okay. And for how long?
23 were. Let's start with when you were an
Pages 9-12
HARTOLDMONO019044
Page 13
Page 15
1 operator from 1961 to 1966. What were 1 A. It was required.
2 your responsibilities in the Aroclor
2 Q. What was the punishment if any for not
3 department as an operator?
3 wearing them?
4 A. Making the products.
4 A. Reprimands, mostly.
5 Q. Okay. And how did you accomplish that? 5 Q. Did you ever know anyone to get
6 Did you take raw materials --
6 reprimanded?
7 A. Yeah. We take the raw materials and put 7 A. Not to my knowledge.
8 them in the vessels, and it was
8 Q. And 1 take it from your answer that you
9 processed in the vessels.
9 yourself did not get reprimanded?
10 Q. And then after production was there a 10 A. No.
11 role that you had, like drumming for
11 Q. During your job as operator between 196'
12 example?
12 and '66, 1 think you testified that was
13 A. No.
13 in the Aroclor department?
14 Q. What were the raw materials that went 14 A. Yes.
15 into those products, if you can
15 Q. Describe the physical attributes of that
16 remember?
16 department. Was it inside? Was it
17 A. One of the products was Santowax, one 17
outside? If it was inside, was it open
18 was biphenyl, chlorine. That's all 1
18 air or just whatever physical attributes
19 can remember.
19 you can remember about that department.
20 Q. Okay. That's fine. That is fair
20 A. Actual production was outside. We had a
21 enough. What safety gear did you wear 21 control room to run samples, and that
22 in your role as operator between 1961
22 was it.
23 and '66?
23 Q. Was -- Let's start with the outside.
1 A. 2 Q. 3 4 A. 5 Q. 6 A. 7 Q. 8 A. 9 Q. 10 A. 11 Q. 12 13 14 A. 15 Q. 16 A. 17 Q. 18 19 20 21 A. 22 Q. 23
Page 14
Gloves. How far up your arm did those gloves extend? Above the wrist. Okay. Anything else? Face shields, goggles, steel-toe shoes. Hard hat? Hard hat, safety glasses. Protective clothing? Just general work clothes. Were those work clothes -- Did you take them off at the end of the day and leave them at the plant? Yes. They were laundered at the plant? Yes, they were laundered. And did you have all of these safety materials from 1961 to '66, for the five years that you were there as an operator? Yes. Was it required that you wear them, or was its optional?
1 2 3 A. 4 Q. 5 6 7 8 A. 9 Q. 10 A. 11 12 Q. 13 A. 14 Q. 15 16 17 18 A. 19 Q. 20 A. 21 22 Q. 23 A.
Page 16
Did you work twelve months a year outside? Yes, yes.
Do you remember any spills outside of any of the products?
MR. MYERS: Object to the form. Go ahead.
Spills? Yeah. I'm sure we had some, but just -- not in general, 1 can't tell you. None that stick out in your memory? No. Do you remember then what your responsibility was if there was a spill, regardless of how big it was or how small it was? Contain and clean up the spill. What did that entail? Had an oil dry type of material, sand, used sands for oil dry. And that was for containing 1 guess? Yes.
Pages 13-16
HARTOLDMONO019045
Page 17
Page 19
1 Q. And how about cleaning up?
1 Q. Well, did you dip a cup down into a
2 A. This was also to absorb the liquid, and
2 bucket and take a sample, or was there
3 it was cleaned up.
3 some more detail than that? 1 just want
4 Q. What did you do with the absorbed
4 to know -
5 material?
5 A. The vessel that the product was made in
6 A. It was put in containers like metal
6 had a sample pourer on it. The sample
7 drums.
7 was taken in that container and carried
8 Q. And what happened to the metal drums?
8 to the control room.
9 A. Shipping took care of that.
9 Q. So the samples were taken outside?
10 Q. Did you have any responsibility for
10 A. Yes.
11 cleaning it up for the drums?
11 Q. And then taken to the control room?
12 A. Just prop it on a pallet.
12 A. Yes.
13 Q. Did you ever see where shipping took
13 Q. Who was in the control room to receive
14 those barrels?
14 the samples, just the title of the
15 A. No.
15 person in there?
16 Q. Do you have any knowledge of where they 16 A. We did the samples.
17 took them?
17 Q. What I'm trying to get to is what did
18 A. 1 was never connected with that. I'm
18 you do with the samples once they were
19 not familiar with it.
19 made?
20 Q. Okay. And how about the room where
20 A. They were brought in the control room,
21 samples were taken? What is that
21 set in the sink. They usually had to be
22 called, again?
22 cooled to a certain temperature to run
23 A. Just the control room.
23 the samples.
Page 18
Page 20
1 Q. Did you have any job duties in the
1 Q. Okay. And who analyzed these samples
2 control room?
2 once they had cooled?
3 A. Yes. As operators we took the samples
3 A. The person that caught the sample.
4 and run the samples.
4 Q. And what were you analyzing the samples
5 Q. Tell me about the ventilation system in
5 for?
6 the control room.
6 A. Finished product like specific gravity.
7 A. It was - the doors were just open on
7 Q. Okay. Anything else?
8 the building. The windows were open.
8 A. No.
9 There was a fan above the sink where the
9 Q. Consistency?
10 samples were cooled and run.
10 A. Well, that was the consistency.
11 Q. Was it a fan that was blowing in or
11 Q. The specific gravity, is that what was
12 sucking air out?
12 tested?
13 A. Just an exhaust fan overhead.
13 A. That was it.
14 Q. Do you know how, if at all, that exhaust
14 Q. All right. Let's move around to when
15 was treated?
15 you were a storeroom clerk in 1966 and
16 A. No.
16 '67. Incidentally, why did you take the
17 Q. Do you know where the exhaust went after 17 job as a storeroom clerk after you were
18 it was pulled out?
18 an operator and before going to chief
19 A. I've never thought anything about it.
19 operator?
20 Q. Okay. What was the process of taking
20 A. I'll have to go into a little detail
21 samples in the control room? How was
21 here.
22 that done?
22 Q. All right.
23 A. 1 don't understand your question.
23 A. With shift work you work around the
Pages 17-20
HARTOLDMONO019046
Page 21
Page 23
1 clock, and storeroom was a daytime job. 1 Q. Did you have any responsibility for the
2 Q. Was the storeroom clerk job in the
2 implementation of safety measures for
3 Aroclor department also?
3 the men under your charge?
4 A. No. It was a separate building.
4 A. The reason I'm taking so long, not -
5 Q. Okay. And let me start at the very
5 No, not generally, you wouldn't.
6 beginning. What's your birthday?
6 Q. Did you distribute gloves, face shields,
7 A. July 29th, 1937.
7 goggles, and others things to them?
8 Q. So if I'm calculating right, you were
8 A. No.
9 about twenty-nine years old when you
9 Q. Who did that?
10 became storeroom clerk, and about a year 10 A. Storeroom.
11 later you became a chief operator in the 11 Q. Who was responsible for making sure they
12 biphenyl department?
12 had the proper materials, proper safety
13 A. 1 hope you understood that these dates 13 gear?
14 are estimates in my mind.
14 A. The company.
15 Q. 1 should have kept that in mind.
15 Q. Did you have the responsibility for
16 Storeroom clerk, just back there --
16 punishing anybody for failing to wear
17 A. Excuse me just a minute.
17 any of their safety materials?
18 Q. Sure. Did you have any safety gear that 18 A. No.
19 you had to wear as a storeroom clerk? 19 Q. Whose responsibility was that? Let's
20 A. No.
20 say a guy didn't wear his hard hat one
21 Q. Did you ever travel outside of the
21 day and there was a reprimand for that.
22 office where you performed your duties? 22 Who was responsible for handing out that
23 Did you go around the plant, for
23 reprimand?
1 2 A. 3 Q. 4 5 6 A. 7 Q. 8 9 10 A. 11 12 13 Q. 14 15 16 17 18 A. 19 20 21 Q. 22 23 A.
Page 22
example?
1 A.
No. 2
I'm sorry to jump around so much. But 3 Q.
back to when you were an operator, where 4
did you take your meals?
5 A.
We had a lunchroom.
6
Do you remember if there was a rule in 7 Q.
place regarding eating your meals
8
anywhere in the plant?
9 A.
1 don't know if it was a rule. We just
10 Q.
had a lunchroom. That is where you
11 A.
went.
12 Q.
All right. Let's move on to when you
13 A.
became a chief operator in approximately 14
1967 to approximately 1977 in the
15 Q.
biphenyl department. What were your
16
responsibilities as chief operator?
17 A.
Each shift had operators, and the chief 18 Q.
was sort of in charge of that particular
19
shift, that crew.
20
Okay. And were you responsible for
21 A.
hiring and firing?
22 Q.
No. 23
Page 24
Ever who saw it would just generally remind him of it.
Not a foreman or chief foreman or supervisor or someone like that?
If it got bad enough, the foreman would be.
And who did you specifically report to as chief operator? The foreman.
Do you remember his name? Had several. Okay. Barbara Curry, Mark Williams. That's all 1 can think of right now. If you think of any more, just let me know. All right. Did you have any responsibility as chief operator for sampling like you did as an operator? No. Did you have any responsibility for the production process that went on outside,
Pages 21 - 24
HARTOLDMONO019047
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1 hands on?
1 sweeping down or any -- Just general
2 A. Only if the operator had problems.
2 cleanup. It could be the building or
3 Q. Okay. Did you have any responsibility
3 outside in the operation area, picking
4 like you did as an operator for cleaning
4 up trash.
5 up spills?
5 Q. Did you hose down any area of either the
6 A. Yes.
6 control room or outside? In other
7 Q. And what were your responsibilities
7 words, did you use hoses or water as a
8 there?
8 part of housekeeping?
9 A. Just assist.
9 A. Yes.
10 Q. Did you have any responsibilities as
10 Q. Do you know if there was any drain for
11 chief operator for the disposal of the
11 that water?
12 waste material after a spill?
12 A. Yes.
13 A. No.
13 Q. And where were the drains?
14 Q. How was a spill reported up the chain? 14 A. The storm drains.
15 MR. MYERS: At what point in time? 15 Q. Okay. Is that outside that you are
16 Q. As soon as the spill happens, what chain 16 talking about?
17 of events takes place?
17 A. Yes.
18 MR. MYERS: 1 guess the
18 Q. And do you know where those storm drains
19
clarification 1 have or want
19 went ultimately?
20
is when he was an operator or
20 A. Not for sure.
21 chief operator?
21 Q. Has anyone ever told you where the storm
22
MR. COLEMAN: Good question.
22 drains went?
23 Q. Either one. As an operator or chief
23 A. 1 believe so.
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1 operator, and if they changed, if the
1 Q. What did they tell you?
2 chain of command kind of changed when 2 A. There was a catch basin inside the
3 you were an operator or chief operator,
3 fenced area.
4 let me know that. What would happen? 4 Q. In what relation to the fenced area is
5 A. My responsibility as a chief operator
5 that catch basin?
6 would be to report it to my foreman.
6 A. Near the highway.
7 Q. And as chief operator did operators
7 Q. Is that highway 202 you are talking
8 report to you the occasional spills?
8 about?
9 A. Yes.
9 A. What used to be --1 don't know what
10 Q. Okay. This may be a tough question to 10
that is now. It used to be Highway 202
11 answer, but was there any spill too
11 for years.
12 small to report?
12 Q. Do you have any knowledge of how that
13
MR. MYERS: Object to the form.
13 basin was treated if at all?
14 A. 1 don't know about that.
14 A. No.
15 Q. Describe if you will your role as
15 Q. Do you know anyone who had ultimate
16 operator and chief operator and the
16 responsibility for that basin?
17 housekeeping measures you had there at 17 A. Ask that again.
18 the plant.
18 Q. Sure. Do you know anyone who had
19 A. Housekeeping was very important. No jot > 19
responsibility for the materials in that
20 was complete until your housekeeping was 20 basin?
21 done.
21 A. No.
22 Q. And what housekeeping measures --
22 Q. Now, the control room, is there a drain
23 A. It would be as far as washing down or 23
in the control room?
Pages 25 - 28
HARTOLDMONO019048
1 A. 2 3 4 Q. 5 6 7 A. 8 Q. 9 A. 10 11 12 Q. 13 A. 14 Q. 15 16 A. 17 Q. 18 19 A. 20 Q. 21 22 A. 23 Q.
Page 29
No. There was -- We didn't use water. There was a drain, but it wasn't a wash-down area.
You talked about a sink earlier in the control room. What was the sink used for? Samples.
Okay. Was it an operating sink? No. It was just a lab type sink, just used just for that particular, you know, process. And how were the samples cooled? Water. Okay. Do you remember whether the samples containers were washed off. They are. Do you know whether the sink's drain went to the basin? 1 don't know. When you first joined Monsanto did you participate in a job interview? Yes. Were you told in the job interview that
1 A. 2 Q. 3 4 5 6 7 8 A. 9 Q. 10 11 12 13 14 15 16 17 A. 18 Q. 19 20 21 A. 22 Q. 23
Page 31
Ask me again, please. I'm sorry. It was very confusing. We talked about you said you had safety meetings. You said you may have had meetings with the medical department. Did you have any meetings specifically related to worker health? 1 can't remember. Okay. For those meetings that you remember, the safety meetings and perhaps the ones that involved the medical department, the few that required the medical department's participation, what was discussed at those meetings? 1 know it was a long time ago. 1 just mean very generally. I'm sorry. 1 can't remember that. Do you specifically remember the subject of the health effects of PCB exposure being brought up in any of the meetings? 1 don't remember. Did anyone ever tell you that PCBs were dangerous?
Page 30
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1 you would be working around Aroclors? 1 A. 1 don't remember that.
2 A. No.
2 Q. Outside of wearing protective gear as a
3 Q. Were you told in the job interview that
3 part of the general rules of the plant,
4 you would be working around PCBs?
4 were you ever provided any special
5 A. No.
5 protective gear when you were handling
6 Q. Did you ever have an opportunity in your 6
Aroclors or PCBs?
7 entire career at Monsanto to interview
7
MR. MYERS: Other than what he
8 workers for positions?
8 described earlier?
9 A. No.
9 MR. COLEMAN: Other than what he
10 Q. Do you know if during the interview
10
described earlier.
11 process -- Strike that.
11 Q. 1 will go through the list. You said
12
When you were an operator in 1961 12
you had gloves to the wrist, face
13 through '66, did you have safety
13 shield, goggles, steel-toed boots, hard
14 meetings within the department?
14 hat, safety glasses and work clothes
15 A. Yes.
15 that were laundered at the plant.
16 Q. Did you have meetings with the medical 16
Anything that was special say for a
17 department?
17 particular job?
18 A. Some of them could have been.
18 A. Now, you are talking about as an
19 Q. Did you have meetings about your health 19
operator?
20 with anyone at the plant management
20 Q. As an operator.
21 level?
21 A. 1 can't remember anything other than
22
MR. MYERS: Same time period?
22 that.
23 MR. COLEMAN: Same time period. 23 Q. How about respirators?
Pages 29 - 32
HARTOLDMONO019049
1 A. 2 Q. 3 4 5 6 7 A. 8 9 Q. 10 11 12 13 A. 14 Q. 15 16 A. 17 Q. 18 19 A. 20 Q. 21 22 23
Page 33
1 don't remember in that time period. Not the respirators with the full canister, but how about the small paper kind of respirator? Did you ever use those?
MR. MYERS: Object to the form. 1 don't remember any respirators at that time. What were you told about -- Strike that.
Okay. When you were a chief operator from 1967 to 1977, do you remember any safety meetings? Oh, yes.
Were you in part responsible for putting on those meetings? No.
How frequent would you say during that period as a chief operator? Monthly.
Of the three types of meetings we talked about, safety meetings, any meetings you had with the medical department, any meetings you had generally about
1 2 3 A. 4 Q. 5 6 7 8 A. 9 10 Q. 11 A. 12 Q. 13 14 15 A. 16 Q. 17 18 A. 19 Q. 20 21 22 A. 23 Q.
Page 35
through breathing? MR. MYERS: Object to the form?
Again, ask me the question. Sure. Were you ever told about the health effects on the human body from breathing PCBs?
MR. MYERS: Same objection. To my knowledge it was brought up in safety meetings. Do you remember the extent of that? No. Incidentally, do you remember in any of these meetings someone was there taking notes about the meeting? Not to my knowledge. Like a secretary or clerk there to kind of write down what people were saying? No. So 1 take it you never read anything after a meeting which reflected the events that happened at the meeting? 1 can't remember. Like minutes of the meeting, did you
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Page 36
1 employee and worker health, I'm kind of
1 ever coming across those?
2 lumping all of those together. Are
2 A. The words, you know, minutes of the
3 those the kinds of meetings you would
3 meeting comes to mind, but 1 can't tell
4 have monthly?
4 you.
5 A. Yes.
5 Q. 1 take it you wouldn't remember the
6 Q. And as a chief operator, do you remember
6 specific contents of any meeting you
7 any discussion about the health risks
7 might --
8 associated with PCB exposure?
8 A. No.
9 A. 1 don't remember any.
9 Q. Were the minutes of the meetings posted
10 Q. Okay. Do you remember any specific
10 anywhere in the plant?
11 instructions on how to handle PCBs or
11 A. 1 can't remember.
12 Aroclors during your tenure as chief
12 Q. Do you remember being shown any MSDSs
13 operator?
13 for the particular products you worked
14 A. 1 don't understand your question,
14 with?
15 really.
15 A. Yes.
16 Q. I'm sorry about that. Were you ever
16 Q. While we are at it, would you mind
17 told about the effects of handling
17 listing the specific Aroclor products
18 Aroclors without any protective gear?
18 and any other PCB containing products
19 MR. MYERS: Object to the form.
19 that you worked with during your tenure
20 A. Not to my knowledge.
20 at Monsanto?
21 Q. Did you ever -- were you ever told or
21 A. 1140, 1142, 1240, 1242. 1 have a lot of
22 did you ever learn of the effects of
22 numbers in mind but can't get them all
23 PCBs on the body through absorption
23 together, 5460, late biphenyl, 1268
Pages 33 - 36
HARTOLDMONO019050
Page 37
Page 39
1 1148, 1248. I'm sure there are a lot
1
certainly as to time and the
2 more 1 can't remember.
2 term products, and he talked
3 Q. If you remember them any time during the 3
about them being raw
4 deposition, just let me know?
4 materials in particular?
5 A. All right.
5 Q. Specifically Santowax, biphenyl, and
6 Q. 1 think you said in the next two
6 chlorine, I'm just trying the get a
7 positions you held as maintenance
7 sense of the structure of the plant.
8 department mechanic from roughly 1977 tc 8 Were they contained in tanks outside or
9 '80 and as El from '80 and until you
9 were they --
10 retired in '94 you weren't working
10 A. Yes.
11
specifically in the biphenyl department;
11 Q. Ever just in barrels?
12 is that correct?
12 A. No.
13 A. That's correct.
13 Q. In your responsibility as a maintenance
14 Q. Let's talk about the health and safety
14 department mechanic and El, did you have
15 protocol at Monsanto during those years 15 any responsibilities for cleaning out
16 and particularly as it related to your
16 the tanks?
17 jobs. Were you required to wear the
17 A. Yes.
18 protective gear as a maintenance
18 Q. How did you accomplish that?
19 department mechanic?
19 A. The tanks were usually emptied by the
20 A. Yes.
20 production department. Let me go back a
21 Q. Besides that list we went through
21 minute. As far as cleaning out in
22 earlier, were there any special
22 particular, tanks, I'd say no, because
23 protective measures that you took?
23 the production department done their
1 A. 2 Q. 3 4 A. 5 Q. 6 7 A. 8 Q. 9 A. 10 Q. 11 12 13 A. 14 15 Q. 16 A. 17 Q. 18 19 20 21 22 23
Page 38
Gas mask, respirator.
1
Why did you have to use a gas mask and 2
respirator?
3 Q.
Parathion department fumes.
4 A.
Did you ever have to use a gas mask or 5 Q.
respirator in the biphenyl department?
6 A.
Yes.
7 Q.
In what respect?
8
Around benzine.
9 A.
Was benzine one of the raw materials in 10
the production of Aroclors to your
11
knowledge?
12 Q.
1 don't know how to answer that really. 13
It was a raw material to the biphenyl.
14
And then biphenyl went in the Santowax? 15 A.
Or it went into the Aroclor production.
16
All right. Were you responsible --
17
Strike that.
18
How was Santowax, biphenyl,
19 Q.
chlorine and other products -- were they 20
held in tanks?
21
MR. MYERS: Let me object to the
22
form. It is overly broad,
23 A.
Page 40
cleaning. We worked on the tank, but we didn't -
Did you ever climb in one, for example? Yes. Were you using a respirator? Yes. And why did you climb in it, for what purpose? It could have been a leak in the tank we were hunting for, could have been adding some equipment to the tank. Okay. And you say you wore a respirator. Was it the canister type respirator? As far as protection, it would depend on what product was in that tank before. You may have fresh air supplied, maybe a respirator, had a gas mask, just air. Okay. You answered my next six questions. Once in the tank did you ever have any responsibility for washing it out with a hose? No.
Pages 37 - 40
HARTOLDMONO019051
1 Q. 2 3 4 A. 5 Q. 6 7 8 9 10 11 12 13 14 Q. 15 16 17 18 19 20 21 22 23
Page 41
Do you know whether that job was ever performed, the cleaning of tanks with water? Yes. And if you can answer this, how often would you say, let's say when you were a -- the entire time you were a maintenance department mechanic from '77 to '94?
MR. MYERS: 1 believe he was in maintenance '77 to '80 and then an El from '80 to '94.
MR. COLEMAN: Yes. Your best guess.
MR. MYERS: Let me just caution you. Mr. Taylor, you are not required to speculate or guess. If you can give him a reasonable estimate or tell him with certainty or reasonably certainty, do that. But you are not required to speculate or
1 2 A. 3 Q. 4 A. 5 6 7 8 Q. 9 10 11 12 A. 13 14 Q. 15 A. 16 17 18 Q. 19 20 A. 21 22 23 Q.
Page 43
production? Yes. And how was that handled? According to the product, you could sweep it out, collect it in drums, or you could -- some tanks may have been washed out. Let's start with -- Those are three common methods. Let's start with the first. What was the product if you remember that you were sweeping out? In these time periods, it could have been any product because -Any of the list we went through earlier? Yeah. It could have been not necessarily those products but could have been raw material products. What did you do with what you had swept out once it was over? Again, it went in drums. From there, the shipping department would take care of it. But you had responsibility for putting
Page 42
Page 44
1 guess.
1 it on a pallet?
2 MR. COLEMAN: Thanks. 1 agree.
2 A. Right.
3 A. No specific times or numbers or anything
3 Q. And that was about it?
4 like that.
4 A. Yes.
5 Q. Okay. Did you have any responsibility
5 Q. What about when you washed out the
6 when you were either an operator or
6 tanks? What was the process there?
7 chief operator for climbing into tanks
7 A. Well, the water was pumped out. 1 was
8 and doing any type of maintenance?
8 trying to remember. 1 don't remember
9 A. You caught me here on the spot.
9 where it was pumped to. The final part
10 THE WITNESS: Can 1 ask you a
10 of the water was mopped up with, like,
11 question?
11 rags or something like this to get
12 MR. MYERS: Yeah. Let's take a
12 everything dry. They were put in drums.
13 short break.
13 Q. Okay.
14 (A break was taken.)
14 A. That's to the best of my knowledge.
15
MR. COLEMAN: Can you read back
15 Q. Do you remember whether the waste water
16 the last question?
16 after that washing was drummed or not?
17 (Requested portion of record
17 A. To my knowledge sometimes it was.
18 read.)
18 Q. And if it was, did you have
19 A. Maintenance and production were separate 19 responsibility for putting that barrel
20 departments. As production, we didn't
20 on a pallet?
21 do any maintenance on them.
21 A. Yes.
22 Q. How about cleaning up? Did you ever
22 Q. And in the other times when it wasn't,
23 crawl into a tank to clean it up in
23 what happened to that waste water?
Pages 41 - 44
HARTOLDMONO019052
Page 45
Page 47
1 A. 1 don't remember. That is what I'm --
1 for and what the results were?
2 I'm trying the remember.
2 A. No.
3 Q. Okay. Do you have any personal
3 Q. Do you remember ever being told or it
4 knowledge of any tests done on animals 4 being put on the bulletin board there in
5 for PCB exposure?
5 the Aroclor department the results of
6 A. No.
6 what the tests were on that basin?
7 Q. Do you have any personal knowledge of 7 A. Not to my knowledge.
8 soil samples taken for analysis for
8 Q. Okay. Do you know where Snow Creek is?
9 PCBs?
9 A. Yes.
10
MR. MYERS: Object to the form.
10 Q. Do you know whether any effluents were
11 Where, when?
11 ever discharged into Snow Creek?
12 Q. In your tenure at Monsanto, anywhere 12
MR. MYERS: Object to the form.
13 around the plant.
13 From where?
14 A. Not to my knowledge.
14 Q. From the plant.
15 Q. Do you have any knowledge of -- during 15 A. 1 have been told that.
16 your time at Monsanto and after, do you 16 Q. Who told you that?
17 have any knowledge of soil samples taken 17 A. You know, just talk, no specific --
18 in the Anniston area by anyone at all
18 particular name. 1 don't remember.
19 for analysis for PCBs?
19 Q. When you say that, do you mean -- Did
20 A. What 1 read in the paper.
20 this come up during your employment at
21 Q. Any other sources of information besides 21
Monsanto?
22 the paper?
22 A. Go back and ask me that question again.
23 A. No.
23 Q. Sure. You said you don't remember
Page 46
Page 48
1 Q. And what do you know about -- from your 1
exactly the person that told you there
2 reading of the paper, what do you know 2 may be some effluent being discharged
3 about the results of those soil samples? 3 into Snow Creek, that it was just talk.
4 A. Results, 1 really don't know anything.
4 Did that talk happen while you were an
5 Q. Okay. Do you remember reading that the 5 employee at Monsanto, or is that
6 soil samples had levels of PCBs?
6 something you learned after you left
7
MR. MYERS: Object to the form.
7 there?
8 A. Yes.
8 A. When you talk about effluents, is that
9 Q. Were you aware of, at any time when you 9 like the storm sewer drain? That is
10 were working at Monsanto, any tests done 10 what 1 was -- Yes, that was during my
11 on water around the plant for the
11 employment.
12 presence of PCBs?
12 Q. Was that the subject of any of those
13 A. Not for PCBs in particular.
13 meetings we talked about earlier, health
14 Q. Okay. But for other --
14 meetings, safety department meetings,
15 A. Water samples were taken.
15 safety meetings?
16 Q. For what tests if you can remember?
16 A. 1 can't remember.
17 A. The laboratory done this. 1 have no
17 Q. Okay. Do you have any knowledge of any
18 idea.
18 tests being done on fish for the
19 Q. Do you remember whether any tests were 19 presence of PCBs?
20 done on that basin we talked about 20 MR. MYERS: Object to the form.
21 earlier?
21 A. What 1 read in the paper.
22 A. Yes.
22 Q. Have you seen the fish advisories around
23 Q. And do you know what those tests were 23 Choccolocco Creek and Lake Logan Martin,
Pages 45 - 48
HARTOLDMONO019053
1 2 A. 3 Q. 4 A. 5 Q. 6 7 8 9 10 11 A. 12 Q. 13 14 15 A. 16 Q. 17 A. 18 Q. 19 20 21 22 23
Page 49
the Coosa River? Not with my eyes. Have you read them in the paper? Yes. 1 think you said earlier you didn't have any responsibility for the disposing of
wastes into landfills during your work there. Is that correct? You said the shipping department usually handled that? Yes. That wasn't in my department.
Did you ever hear of any tests being performed around the landfill for the presence of PCBs? 1 don't know what the tests were for.
Were you aware of tests? Tests were performed. Are you aware of any epidemiological studies on humans for the effects of PCBs?
MR. MYERS: Object to the form, your definition of epidemiology.
1 2 3 4 5 6 7 8 9 10 A. 11 Q. 12 13 14 15 16 A. 17 Q. 18 19 20 21 22 A. 23 Q.
Page 51
read that? MR. MYERS: Object to the form, and ask for a clarification. Are you referencing the period of time of his employment? MR. COLEMAN: No. Just asking if he has ever heard that. MR. MYERS: Object to the form.
1 don't believe I've ever heard that. Have you ever read or heard that repeated bodily contact with the liquid Aroclors may lead to an acne form of skin eruption?
MR. MYERS: Same objection. Not to my knowledge. Okay. Have you ever read or heard that a serous and disfiguring dermatitis may result when PCBs or Aroclors are allowed to remain in contact with the skin?
MR. MYERS: Same objection. Not to my knowledge. Have you ever read or heard or been told
Page 50
Page 52
1 A. Ask me again, please.
1 by anyone that exposures to PCBs at some
2 Q. Sure. Are you aware of any tests done 2 level may result in liver or kidney
3 or any studies made on the -- with
3 damage?
4 regard to PCBs in humans?
4 MR. MYERS: Same objection.
5 A. Yes.
5 A. Just what 1 read in the paper.
6 Q. Do you remember what those tests
6 Q. Have you ever read or heard that PCBs --
7 revealed?
7 Strike that.
8 A. They give a number as far as PCBs, but 1 8
Have you ever read or heard that
9 don't know what it meant.
9 exposure to PCBs can cause -- can cause
10 Q. We'll get back to that in a little
10 any disfigurement in animals like fish?
11 while. Did you have any responsibility 11
MR. MYERS: Object to the form.
12 with regard to -- Strike that. Never
12 A. Just what 1 read in the paper, again.
13 mind.
13 Q. And what did the paper say about that?
14
I'm going to read you a couple of
14 A. Just read about the fish. That is all 1
15 things and ask you if you ever heard
15 can, you know --
16 this or if anyone ever told you these
16 Q. What particularly did the paper say
17 things. Just tell me if you have and in
17 about disfigurement in fish?
18 what context. Experimental work in
18 A. 1 can't remember. You know, 1 just read
19 animals shows that prolonged exposure to 19 general things about it.
20 Aroclor vapors evolved at high
20 Q. Okay. That's fine. Have you ever read,
21 temperatures or by repeated oral
21 heard, or been told this statement: The
22 ingestion will lead to systemic toxic
22 amounts of PCBs being found in the
23 effects. Has anyone -- Have you ever
23 environment are not considered a danger
Pages 49 - 52
HARTOLDMONO019054
Page 53
Page 55
1 to humans or fish; the whole question on 1 A. 1 read it in the paper.
2 chlorinated pesticides relates to birds?
2
MR. COLEMAN: Give me just a
3
MR. MYERS: Object to the form.
3
minute, guys.
4 A. Read it again, please.
4 (Discussion held off record.)
5 Q. Have you ever read or heard or been told 5 Q. With regard to the Krummrich plant we
6 this statement: The amounts of PCBs
6 were just talking about, do you have any
7 being found in the environment are not
7 knowledge of whether the Krummrich plant
8 considered a danger to humans or fish;
8 sent any PCBs to be incinerated in
9 the whole question on chlorinated
9 Anniston?
10 pesticides relates to birds?
10 A. Not to my knowledge.
11 MR. MYERS: Same objection. 11 Q. Did you have any role in your tenure at
12 A. 1 can't say yes, that 1 have heard it
12 Monsanto with regards to incineration?
13 just for birds.
13 A. Yes.
14 Q. Okay. What do you know about birds anc 14 Q. What was your job then?
15 PCB exposure?
15 A. The word "incineration" --
16 A. 1 don't know anything.
16 THE WITNESS: Can 1 ask you
17 Q. Okay. Have you ever heard of Dr. Renat*317
another question?
18 Kimbrough? Does that name sound
18
(Discussion held off record.)
19 familiar?
19 A. Incineration?
20 A. Not to me.
20 Q. Yes.
21 Q. What if any contact did you have with 21 A. There was fuel put into the boiler.
22 the Krummrich plant during your entire 22 This was a type of incineration, 1
23 tenure?
23 assume. It was -- That is the way it
Page 54
Page 56
1 A. No contact.
1 was put in there.
2 Q. Did you ever meet anyone from Krummrich? 2 Q. I'll try to be more specific. Did you
3 A. Yes. 1 have had people that visited
3 have any involvement with -- Strike
4 from that plant.
4 that.
5 Q. Did they ever talk to you about their
5 How many incinerators were at the
6 plant operation?
6 Anniston plant that you know about
7 A. No.
7 during your career there used for the
8 Q. Did they ever talk to you about PCBs?
8 incineration of waste material?
9 A. No.
9 A. 1 say three that 1 know of.
10 Q. Did you ever hear about the study that
10 Q. Was one specifically designated for the
11 was performed in the '70s on Krummrich
11 biphenyl department or the Aroclor
12 employees for exposure to PCBs?
12 department where you worked?
13 MR. MYERS: Object to the form,
13 A. Only the boiler. This was the biphenyl
14 particularly to the
14 department.
15 definition or the statement
15 Q. The biphenyl department, there was a
16 that this was a study.
16 boiler but not an incinerator for waste
17 A. I'm not aware of it.
17 material?
18 Q. Have you ever read, heard, or has anyone 18
MR. MYERS: 1 think the confusion,
19 ever told you the following statement:
19
Harrison, if there is any, is
20 Polychlorinated biphenyl in Inerteen can
20
that on one hand you are
21 have permanent effects on the human
21
talking about incineration,
22 body?
22 and then you are talking
23 MR. MYERS: Object to the form.
23
about a device called an
Pages 53 - 56
HARTOLDMONO019055
1 2 3 A. 4 5 Q. 6 7 A. 8 9 Q. 10 11 A. 12 Q. 13 14 15 A. 16 Q. 17 18 19 A. 20 21 22 Q. 23
Page 57
incinerator. That is where 1 think there is a disconnect. 1 can't remember just for the Aroclor department. Do you know if waste material from your department was incinerated? I'm trying to think. I'm going to say yes, in fuel. But you never had any responsibilities for manning that incinerator? The boiler, 1 did. Okay. Just in my own mind, 1 need to get this right. What was the boiler used for? To produce steam for the plant. What I'm referring to is an incinerator that is used to destroy waste material, a burner. Not that 1 can remember for the Aroclor biphenyl departments, not an incinerator for that department. All right. You testified earlier that sometimes you swept out a tank and the
1 A. 2 Q. 3 4 5 6 7 8 9 10 A. 11 Q. 12 13 14 15 A. 16 Q. 17 A. 18 19 20 21 22 Q. 23
Page 59
I'm sorry. 1 just can't remember. We're talking about during your time as an operator from 1961 to 1966 through the time you were a chief operator from '71 to '77; is that correct?
MR. MYERS: Is that the question now, because the earlier incineration was during his tenure.
Come back and tell me again. Do you remember specifically during your time in the Aroclor department as an operator or chief operator using products as fuel for the boiler? No, no. When were products used for the boiler? When 1 was electrician we were responsible for the boiler. That's when they -- the boiler 1 believe started using -- to my knowledge, they started using this other product as a fuel. Do you remember any products that you know were PCB containing products used
Page 58
Page 60
1 material was put in barrels and then you 1 as fuel for the boiler?
2 put it on a crate and sometimes the
2 A. We keep saying PCBs. When 1 was -- All
3 waste water was put into -- was
3 the time 1 was in the plant, this was a
4 sometimes put into a barrel. 1 just
4 word we never heard used. It was
5 wanted to know if any waste material in
5 Aroclor and biphenyl. PCB just wasn't a
6 your department during your tenure at
6 word for us.
7 Monsanto was to your knowledge taken to 7 Q. Thanks for clarifying that. If you want
8 an incinerator like 1 described.
8 1 will go through the list of Aroclors
9
MR. MYERS: Waste material that
9 you mentioned earlier. I'm talking
10 you just defined or gave
10 about this list of products you said you
11 examples of?
11 worked on and whether those products
12 Q. I'm saying waste materials of any type 12 were used as fuel for the boiler.
13 in your department.
13 A. Back then, no. We weren't using the
14 A. 1 don't remember being incinerated, no. 14
products as a fuel.
15 Q. The boiler that you talked about, was it 15
Now, if 1 can back up a minute,
16 used to incinerate -- was that the fuel
16 you asked me a question. One of the
17 for the -- Sorry.
17 products that was used as fuel was
18
What was the fuel for the boiler?
18 Montar, which is an off-gas that is not
19 A. 1 don't remember -- It was natural gas. 19
PCB.
20 Q. Okay.
20 Q. Okay. During your time at Monsanto the
21 A. And then they took a mixture of products 21
entire time you were there, do you
22 and put it in there as a fuel.
22 remember any explosions or ruptures in
23 Q. Okay. What products?
23 the lines that might have caused an
Pages 57 - 60
HARTOLDMONO019056
Page 61
Page 63
1 escape of products into the atmosphere?
1
talking about what the value
2 MR. MYERS: Object to the form.
2
was.
3 A. Products?
3 MR. COLEMAN: I'm sorry. Thank
4 Q. Any products. Do you remember any
4
you for clearing that up.
5 explosions?
5 Q. You say was somewhere in the sixties?
6 A. Yes.
6 A. That was the number.
7 Q. Do you remember when?
7 Q. When did you take your test?
8 A. Date, no.
8 A. 1 don't remember. I'm sorry. 1 can see
9 Q. Do you remember what job was were doing 9 where that can be confusing.
10 at the time?
10 Q. Has anyone in your family had their
11 A. It was when 1 was in maintenance.
11 blood tested for PCBs?
12 Q. Okay.
12 A. No.
13 A. Parathion department.
13 Q. Have you ever been diagnosed with
14 Q. How about any time you were an operator 14
cancer?
15 or chief operator?
15 A. No.
16 A. Yes.
16 Q. Anyone in your immediate family?
17 Q. Do you remember what happened?
17 A. No.
18 A. The main thing 1 can remember is in the
18 Q. Have you ever been diagnosed with liver
19 wintertime your Montar line was -- would
19 damage?
20 freeze up. And when it would heat up,
20 A. You say immediate family, are you
21 the gasket would give out.
21 talking about my wife or children?
22 Q. And that would cause a rupture?
22 Q. Yes.
23 A. Yes. It became a solid as soon as it
23 A. No.
1 2 Q. 3 4 5 6 A. 7 Q. 8 9 10 A. 11 Q. 12 A. 13 14 Q. 15 A. 16 17 Q. 18 A. 19 Q. 20 A. 21 22 23
Page 62
hit the air.
1
Any other ruptures or explosions?
2 Q.
MR. MYERS: While he was in
3
Aroclor?
4 A.
MR. COLEMAN: Yes.
5
It has been so long, 1 can't remember.
6 Q.
Fair enough. Do you -- Have you ever 7 A.
had your blood tested for the presence
8 Q.
of PCBs?
9
Yes.
10 A.
Do you know what your level is?
11 Q.
It has been a number of years ago. 1
12
think it was in the sixties.
13 A.
Was that performed on site?
14 Q.
1 went to the doctor's office, the
15
company doctor.
16 A.
And you don't know the date?
17 Q.
No. 18 A.
But you think it was in the '60s?
19 Q.
No. It was later than that, much later.
20
MR. MYERS: No, no. 1 think -
21 A.
Somebody is talking about
22
dates, and somebody is
23
Page 64
What was the other question? Have you ever been diagnosed with liver damage or liver problems? No. I'm in good health as far as 1 know. Are you on a pension? Yes. And benefits, does that include benefits too? Yes. Do you have any family working at Monsanto? No. Do you keep in contact with any friends that are presently working at Monsanto? Yes. And who are they? Brian Thrasher. You did say contact? Just, you know, friends that are currently working at Monsanto. I'd say the plant manager, 1 have contacted with him, you know. Most is just in passing contact.
Pages 61 - 64
HARTOLDMONO019057
Page 65
Page 67
1 Q. Did you speak to anyone from Monsanto
1 Q. Yes. That might be wrong here. What
2 prior to this deposition?
2 job was performed by laborers with
3 A. 1 was contacted by Jerry Brown
3 regard to still bottoms?
4 concerning this.
4 A. They were put in metal drums,
5 Q. What did you talk about?
5 containers, cooled and placed on
6 A. He wanted to know when it was convenient 6
pallets.
7 for me to come in, told me Mr. Kelly
7 Q. Did you have any responsibility for
8 would call me and make arrangements.
8 placing them on pallets?
9 Q. Did he tell you about what he thought
9 A. No.
10 you would be testifying about?
10 Q. That was a laborer job also?
11 A. No.
11 A. Yes.
12 Q. Give you any pointers?
12 Q. Do you have any idea where those drums
13 A. No.
13 went?
14 Q. Did you ask for any?
14 A. No, 1 don't.
15 A. No.
15 Q. This 1 think is going to be the last
16 Q. Okay. Do you know -- You said earlier
16 question. Did the boiler that we talked
17 that Montars do not contain PCBs. Is
17 about earlier, did it have a scrubber?
18 that right?
18 A. 1 can't recall.
19 A. PCBs as you are saying is
19 MR. COLEMAN: All right, sir.
20 polychlorinated biphenyls?
20 (The deposition concluded at
21 Q. Correct.
21 12:50 p.m.)
22 A. So this is a product before it went into
22
23 the chlorinator. It is a biphenyl
23
1 2 Q. 3A 4Q 5 A. 6 7 8 9 Q. 10 11 12 A. 13 14 Q. 15 16 A. 17 Q. 18 A. 19 Q. 20 21 A. 22 Q. 23 A.
Page 66
Page 68
product.
1 1 do hereby certify that the witness
Montar is a biphenyl product? Right What are still bottoms? That is after the product was produced and went into a still. They still the
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
product off, and what was left in there
8 afterwards transcribed by means of computer
is called still bottoms.
9 aided transcription. The foregoing is a true
And did you have any responsibility in your entire tenure at Monsanto for cleaning up still bottoms?
No. The labor department did this. In that day we had what is called laborers.
You said in that day. What time period
10 and accurate transcript of the whole of the 11 testimony given by said witness, as aforesaid. 12 1 do further certify that 1 am not 13 connected by blood or marriage with any of the 14 parties or their attorneys or agents and that 15 1 am not an employee of any of them, nor 16 interested in the matter of controversy.
are you talking about here?
17 IN WITNESS WHEREOF, 1 have hereunto set
When 1 was an operator.
18 my hand and affixed my notarial seal at
So '61 to '66? Yes. And did you ever witness these laborers cleaning up these still bottoms? Yes. How was that job performed?
19 Gadsden, Alabama, County of Etowah, this 6th 20 day of January 2002. 21
ueDoran oaiers ocureu 22 Certified Shorthand Reporter
Registered Professional Reporter 23 Notary Public, Alabama-at-Large
Did you say cleaning up?
My Commission expires: 3-6-05
Pages 65 - 68
HARTOLDMONO019058
[& - aroclors]
Transcript Word Index
&
& 1:162:3,10____________
1
10019 2:4
11:00 1:14 3:8
1140 36:21
1142 36:21
1148 37:1
12:50 67:21
1240 36:21
1242 36:21
1248 37:1
1268 36:23
1355 2:11
1633 2:4
1937 21:7
1961 10:8,10,19 13:1,22 14:18 15:11 30:12 59:3
1965 9:5
1966 11:4,5 13:1 20:15 59:3
1967 22:15 33:11
1972 9:5
1977 12:2 22:15 33:11 37:8
1980 12:3,9
1992 9:7,13
1994 12:12
2
200 2:6
2001 1:15 3:84:1
2001-832 1:5
2002 68:20
202 28:7,10
28 1:153:7 4:1
29th 21:7
3 2:13
30309 2:11
304 2:6
35901-0755 1:21
3-6-05 68:23
36207 8:5
4
4 2:17,21
400 1:17
40202 2:7
4700 8:4___________________
5
5460 36:23________________
6
60s 8:20 62:19
61 66:17
66 13:23 14:18 15:12 30:13 66:17
67 11:1820:16
68 2:14
6th 68:19
7
70s 54:11
71 59:5
750 2:11
755 1:21
77 11:1941:8,11 59:5
8
80 12:3 37:9,941:11,12
92 9:6,6
94 37:1041:9,12_______
a
a.m. 1:153:8
aaron 1:9,11 2:16 3:4 4:3,15
abernathy 1:3
absorb 17:2
absorbed 17:4
absorption 34:23
accomplish 13:5 39:18
accurate 68:10
acne 51:13
action 1:5
actual 15:20
adding 40:10
address 8:3
addresses 8:15
advisories 48:22
affixed 68:18
aforesaid 68:5,11
agents 68:14
ago 31:1662:12
agree 42:2
agreed 3:2,9,15,22
ahead 5:14 16:7
aided 68:9
air 15:18 18:1240:17,1862:1
al 1:3,6
alabama 1:1,2,18,21 3:6,7 4:1 8:4 68:19,23
allowed 51:19
alpharetta 10:2
amberwood 8:4
amounts 52:22 53:6
analysis 45:8,19
analyzed 20:1
analyzing 20:4
animals 45:4 50:19 52:10
anniston 1:17 3:7 4:1 8:4,12,21,23 10:1 45:18 55:9 56:6
answer 7:8 15:8 26:11 38:1341:5
answered 40:19
anybody 23:16
appreciate 7:13
approximately 8:1022:14,15
area 9:15,23 27:3,5 28:3,4 29:3 45:18
arm 14:2
aroclor 10:22 13:2 15:1321:3 36:17 38:16 47:5 50:20 56:11 57:3,19 59:12 60:5 62:4
aroclors 30:1 32:6 34:12,18 38:11 51:13,1960:8
HARTOLDMONO019059
[arrangements - coleman]
arrangements 65:8
asked 5:7 60:16
asking 51:7
assign 3:19
assist 25:9
associated 34:8
assume 55:23
atlanta 2:11
atmosphere 61:1
attached 2:23 68:2
attorney 5:23
attorneys 7:18 68:14
attributes 15:15,18
available 5:23 6:1
aware 46:9 49:16,18 50:2 54:17
b
back 8:17 10:1621:1622:4 39:20 42:15 47:22 50:10 59:1060:13,15
bad 24:5
bank 1:17
barbara 24:13
barrel 44:19 58:4
barrels 17:14 39:11 58:1
basin 28:2,5,13,16,20 29:18 46:20 47:6
beginning 10:10,1521:6
believe 5:21 27:2341:1051:10 59:19
benefits 6:9 64:8,8
benson 2:3
benzine 38:9,10
best 41:1444:14
big 16:16
biphenyl 11:17 12:4 13:1821:12 22:16 36:23 37:11 38:6,14 38:15,19 39:5 54:20 56:11 56:13,15 57:20 60:5 65:23 66:2
biphenyls 65:20
birds 53:2,10,13,14
birthday 21:6
blood 62:8 63:11 68:13
blowing 18:11
board 47:4
bodily 51:12
body 34:23 35:5 54:22
boiler 55:21 56:13,16 57:11,13 58:15,18 59:14,16,18,19 60:1,1267:16
boots 32:13
bottoms 66:4,8,11,20 67:3
break 7:1742:13,14
breathing 35:1,6
brian 64:18
bring 5:7
broad 38:23
broadway 2:4
brought 19:20 31:20 35:8
brown 65:3
bucket 19:2
building 1:172:6 18:8 21:4 27:2
bulletin 47:4
burner 57:18_______________
c
calculating 21:8
calhoun
1:2 call
65:8 called
17:22 56:23 66:8,13 cancer
63:14 canister
33:3 40:13 care
17:9 43:21 career
30:7 56:7 carried
19:7 case
4:12 catch
28:2,5 caught
20:3 42:9 cause
52:9,9 61:22 68:4 caused
60:23 caution
41:15 cautioned
68:3 certain
19:22 certainly
39:1 certainty
41:20,21 certificate
2:14 certified
1:12 68:22 certify
68:1,12 chain
25:14,16 26:2 changed
26:1,2
charge 22:19 23:3
Charles 2:5
chief 11:1520:1821:11 22:14,17 22:18 24:3,8,18 25:11,21 25:23 26:3,5,7,16 33:10,18 34:6,12 42:7 59:4,13 61:15
children 9:18,20 63:21
chlorinated 53:2,9
chlorinator 65:23
chlorine 13:18 38:20 39:6
choccolocco 48:23
circuit
1:1 civil
1:5 clarification
25:19 51:3 clarifying
60:7 clean
16:18 42:23 cleaned
17:3 cleaning
17:1,11 25:4 39:15,21 40:1 41:2 42:22 66:11,20,23 cleanup 27:2 clearing 63:4 clearly 7:6 clerk 11:1020:15,1721:2,10,16 21:1935:16 climb 40:3,7 climbing 42:7 clock
21:1 clothes
14:10,11 32:14 clothing
14:9 coleman
2:3,17 4:8,9,16 6:5 25:22 30:23 32:9 41:13 42:2,15
HARTOLDMONO019060
[coleman - drums]
coleman (cont.) 51:7 55:2 62:5 63:3 67:19
collect 43:5
coming 36:1
command 26:2
commencing 1:14
commission 68:23
commissioner 1:14 3:6,23
common 43:9
community 9:1
company 1:6 23:14 62:16
complete 26:20
compliance 3:13
computer 68:8
concerning 65:4
concluded 67:20
confusing 31:2 63:9
confusion 56:18
connected 17:1868:13
considered 52:23 53:8
consistency 20:9,10
consolidated 1:6
contact 51:12,20 53:21 54:1 64:14 64:18,23
contacted 64:22 65:3
contain 16:1865:17
contained 39:8 68:5
container 19:7
containers 17:6 29:15 67:5
containing
dangerous
detail
16:22 36:18 59:23
31:23
19:3 20:20
contents
date
device
36:6
61:8 62:17
56:23
context
dates
diagnosed
50:18
11:2 21:13 62:23
63:13,18 64:2
control
day
dip
15:21 17:23 18:2,6,21 19:8 14:12 23:21 66:13,14 68:20 19:1
19:11,13,20 27:6 28:22,23 daytime
discharged
29:5 21:1 47:11 48:2
controversy
dealt
disconnect
68:16
7:1
57:2
convenient
dearmanville
discussed
65:6 9:23 31:14
cooled
deborah
discussion
18:10 19:22 20:2 29:12
1:12 3:5 68:21
34:7 55:4,18
67:5
december
disfigurement
coosa
1:153:7 4:1
52:10,17
49:1
defendants
disfiguring
correct
1:7 2:8
51:18
37:12,13 49:8 59:5 65:21 defined
disposal
counsel
58:10
25:11
3:3,17,18
definition
disposing
county
49:22 54:15
49:6
1:1,2 68:19
department
distribute
couple
6:23 11:17,22 12:5,6,15
23:6
50:14
13:3 15:13,16,1921:3,12 division
court
22:16 30:14,17 31:5,12
10:21
1:1 3:147:8
33:22 37:8,11,19 38:4,6 doctor
crate
39:14,20,23 41:8 43:21
62:16
58:2 47:5 48:14 49:9,11 56:11 doctor's
crawl
56:12,14,15 57:4,6,21 58:6 62:15
42:23
58:1359:1261:1366:12 document
creek
departments
5:1
47:8,11 48:3,23
42:20 57:20
documents
crew
department's
5:7,16,20 6:20
22:20
31:13
doing
csr
depend
42:8 61:9
3:5
40:15
doors
Cunningham
deposition
18:7
2:5 1:9,11 3:4,10,11,204:10,19 dr
cup 5:2,4,6 7:3 37:4 65:2 67:20 53:17
19:1 68:2 drain
current
depositions
27:10 28:22 29:2,17 48:9
8:2 3:14 drains
currently
dermatitis
27:13,14,18,22
64:20
51:18
drive
curry
describe
8:4
24:13
15:1526:15
drummed
cv
described
44:16
1:5
32:8,10 58:8
drumming
d
damage 52:3 63:19 64:3
danger
designated 56:10
destroy 57:17
13:11 drums
17:7,8,11 43:5,20 44:12 67:4,12
52:23 53:8
HARTOLDMONO019061
[dry - go]
dry 16:20,21 44:12
duly 4:4 68:3
duties 18:1 21:22______________
e
earlier 29:4 32:8,10 37:22 43:14 46:21 48:13 49:5 57:22 59:7 60:9 65:16 67:17
east 8:8 10:1
eating 22:8
edward 2:9
effect 3:12
effects 31:19 34:17,22 35:5 49:19 50:23 54:21
effluent 48:2
effluents 47:10 48:8
ei 37:9 39:14 41:12
either 25:23 27:5 42:6
electrician 12:8,13 59:17
employee 34:1 48:5 68:15
employees 54:12
employment 47:20 48:11 51:6
emptied 39:19
entail 16:19
entire 30:7 41:7 53:22 60:21 66:10
environment 52:23 53:7
epidemiological 49:18
epidemiology 49:23
equipment 40:11
eruption 51:14
escape
f forward
61:1 face
8:16,20 10:16
esq
14:6 23:6 32:12
found
2:3,5,9,10
failing
52:22 53:7
estimate 41:19
23:16 fair
four 5:14
estimates
11:3 13:20 62:7
freeze
21:14
familiar
61:20
et
17:1953:19
frequent
1:3,6
family
33:17
etowah
63:10,16,20 64:11
fresh
1:1 68:19
fan
40:17
events
7:23 18:9,11,13
friedman
25:17 35:21
far
2:3
evidence
8:9,17 9:11 14:2 26:23
friends
3:21
39:21 40:15 50:8 64:4
64:14,19
evolved
fenced
fuel
50:20 exactly
28:3,4 filing
55:21 57:8 58:16,18,22 59:14,21 60:1,12,14,17
48:1 3:23 full
examination
final
3:12 4:13 33:2
4:7 44:9 fumes
examined
fine
38:4
4:5
13:20 52:20
further
example
finished
68:12
6:11 13:1222:1 40:3
20:6
g
examples
firing
gadsden
58:11 excuse
22:22 first
1:21 68:19 garrett
21:17 exhaust
4:4 8:15 29:20 43:10 68:3 1:12 3:5 68:21 fish gas
18:13,14,17
48:18,22 52:10,14,17 53:1 38:1,2,5 40:18 58:19 60:18
exhibit
53:8 gasket
4:21 fite
61:21
exhibits
1:16 gear
2:22,23
five
13:21 21:18 23:13 32:2,5
experimental
8:10 12:19 14:18
34:18 37:18
50:18
following
general
expires
54:19
9:14 11:19 12:21 14:10
68:23
follows
16:11 27:1 32:3 52:19
explosions 60:22 61:5 62:2
4:5 force
generally 23:5 24:1 31:16 33:23
exposure
3:12
31:19 34:8 45:5 50:19 52:9 foregoing
georgia 2:11 10:2
53:15 54:12
68:9
give
exposures
foreman
7:7 10:1341:1850:8 55:2
52:1 extend
14:3 extent
24:3,3,5,9 26:6
61:21 65:12
form
given
3:18 16:6 26:13 33:6 34:19 68:11
35:2 38:23 45:10 46:7
glasses
35:10
47:12 48:20 49:21 51:2,9
14:8 32:14
eyes
51:13 52:11 53:3 54:13,23 gloves
49:2 61:2 14:1,2 23:6 32:12
forth
go
1:19 5:14 10:9,16 16:7 20:20
21:23 32:11 39:20 47:22
HARTOLDMONO019062
[go - landfills]
go (cont.) 60:8
goggles 14:6 23:7 32:13
going 7:9 8:14 11:1,12,1920:18 50:14 57:7 67:15
golden 9:15
good 25:22 64:4
grandchildren 10:3,4
gravity 20:6,11
grounds 3:19
guess 11:1 16:22 25:1841:14,18 42:1
guy 23:20
guys 55:3___________________
h
hand 56:20 68:18
handing 23:22
handle 34:11
handled 43:3 49:9
handling 32:5 34:17
hands 25:1
happen 26:4 48:4
happened 17:8 35:21 44:23 61:17
happens 25:16
hard 14:7,8 23:20 32:13
harrison 2:3 4:9 56:19
hat 14:7,8 23:20 32:14
head 7:23
health 30:19 31:7,19 34:1,7 35:5 37:14 48:13 64:4
hear 49:12 54:10
heard
incidentally
k
50:1551:8,10,11,17,23
20:16 35:12
kasowitz
52:6,8,21 53:5,12,17 54:18 incinerate
2:3
60:4
58:16
keep
heat
incinerated
60:2 64:14
61:20
55:8 57:6 58:14
kelly
held
incineration
65:7
10:14 37:7 38:21 55:4,18
55:12,15,19,22 56:8,21
kentucky
helms 59:8 2:7
2:10
incinerator
kept
hereto
56:16 57:1,10,16,20 58:8
21:15
2:23
incinerators
kidney
hereunto
56:5
52:2
68:17
include
kimbrough
high 64:8 53:18
50:20
inerteen
kind
highway
54:20
12:20 26:2 33:4 34:1 35:16
28:6,7,10
information
kinds
hiring
45:21
34:3
22:22
ingestion
know
history
50:22
7:5,15,18 11:13 15:5 18:14
10:9 inside
18:17 19:4 22:1024:16
hit
15:16,17 28:2
26:4,14 27:10,18 28:9,15
62:1
instructions
28:1829:10,17,1930:10
hold
34:11
31:15 36:2 37:4 38:13 41:1
11:11
interested
46:1,2,4,23 47:8,10,17
home
6:6 68:16
49:15 50:9 52:15,18 53:14
5:176:11,148:7
interview
53:16 56:6,9 57:5 58:5
hope
29:21,23 30:3,7,10
59:23 62:11,17 64:5,19,22
21:13
involved
65:6,16
hose
31:11
knowledge
27:5 40:22
involvement
5:19 15:7 17:1628:12
hoses
56:3____________________ 34:20 35:8,15 38:12 44:14
27:7 j 44:17 45:4,7,14,15,17 47:7
housekeeping 26:17,19,20,22 27:8
huh 7:7
human 35:5 54:21
humans 49:19 50:4 53:1,8
hunting 40:10
january 68:20
jerry 65:3
jessie 4:15
job 10:9,10,10,13,14 11:11 15:11 18:1 20:1721:1,2 26:19 29:21,23 30:3 32:17
48:17 51:16,22 55:7,10 58:7 59:20 krummrich 53:22 54:2,11 55:5,7
I
lab 29:9
labor 66:12
laboratory
41:1 55:14 61:9 66:22 67:2 46:17
idea
67:10
laborer
46:18 67:12
jobs
67:10
identification
10:1837:17
laborers
2:23 4:23
joined
66:13,19 67:2
immediate
29:20
lake
63:16,20
july
48:23
implementation
21:7
landfill
23:2 jump
49:13
important
22:3
landfills
26:19
49:7
HARTOLDMONO019063
[large - notarial]
large 3:7 68:23
late 36:23
laundered 14:15,16 32:15
law 1:16
lawrence 2:10
laws 3:13
lead 50:22 51:13
leading 3:18
leak 40:9
learn 34:22
learned 48:6
leave 14:12
left 48:6 66:7
level 30:21 52:2 62:11
levels 46:6
liberty 2:6
life 8:18
line 61:19
lines 60:23
liquid 17:2 51:12
list 10:19 32:11 37:21 43:14 60:8,10
listing 36:17
little 7:22 12:18 20:20 50:10
live 9:4,13,22
lived 8:11,18,21,23
liver 52:2 63:18 64:2,3
lives 9:23 10:2
Up
mean
montars
2:3
31:1647:19
65:17
logan
means
monthly
48:23
68:7,8
33:19 34:4
long
meant
months
10:23 11:11 23:431:15
50:9
16:1
62:6
measures
moore
lot
23:2 26:17,22 37:23
2:10
36:21 37:1
mechanic
mopped
louisville
12:1 37:8,19 39:14 41:8
44:10
2:7
medical
morning
lumping
30:16 31:5,12,13 33:22
4:11
34:2 meet
morrissey
lunchroom
54:2
2:6
22:6,11_______________________ meeting
move
m
35:14,20,21,23 36:3,6
20:14 22:13
main 61:18
maintenance 11:22 12:6 37:7,18 39:13 41:8,11 42:8,19,21 61:11
making 13:4 23:11
management 30:20
manager 64:21
manning 57:10
manuals 6:14
mark 24:13
marked 2:20,22 4:22
marriage
meetings
moving
30:14,16,19 31:4,5,6,9,10 8:16
31:15,20 33:12,15,20,21,21 msdss
33:23 34:3 35:9,13 36:9
6:11 36:12
48:13,14,14,15
mullis
memory
2:10
16:12
myers
men 2:10 4:16,20 5:11 6:4 7:21
23:3 16:6 25:15,18 26:13 30:22
mentioned
32:7 33:6 34:19 35:2,7
60:9 38:22 41:10,1542:1245:10
metal
46:7 47:12 48:20 49:21
17:6,8 67:4
51:2,9,15,21 52:4,11 53:3
methods
53:11 54:13,23 56:18 58:9
43:9 59:6 61:2 62:3,21_________
miles 8:109:12
miller 1:16
millwright
n
name 4:9,14 24:10 47:18 53:18
natural 58:19
68:13 married
9:16 martin
48:23 mask
38:1,2,5 40:18 material
16:20 17:5 25:12 38:14 43:17 56:8,17 57:5,17 58:1 58:5,9 materials 6:21 13:6,7,14 14:18 23:12 23:17 28:19 38:10 39:4 58:12 matter 68:16 meals 22:5,8
12:1 mind
8:14 12:1721:14,15 36:3 36:16,22 50:13 57:12 minute 5:15 21:17 39:21 55:3 60:15 minutes 35:23 36:2,9 mixture 58:21 monsanto 1:6 6:18,23 8:6 10:7,10,11 29:20 30:7 36:20 37:15 45:12,16 46:10 47:21 48:5 55:12 58:7 60:20 64:12,15 64:20 65:1 66:10 montar 60:1861:1966:2
ne 2:11
near 28:6
necessarily 43:16
necessary 3:16
need 7:16 57:12
new 2:4,4
newsom 2:9
nine 21:9
north 8:21
notarial
68:18
HARTOLDMONO019064
[notary - protective]
notary
operation
pcb
pointers
3:6 68:23
27:3 54:6
31:19 34:8 36:18 45:5
65:12
notes
operator
53:15 59:23 60:5,19
polychlorinated
35:14
10:20 11:15 13:1,3,22
pcbs
54:20 65:20
notice
14:20 15:11 20:18,19 21:11 6:22 7:1 30:4 31:22 32:6 portion
3:22 4:18 5:2,6
22:4,14,17 24:8,19,20 25:2 34:11,23 35:6 45:9,19 46:6 42:17
number
25:4,11,20,21,23 26:1,3,3,5 46:12,13 48:19 49:14,20 positions
4:21 50:8 62:12 63:6
26:7,16,16 30:12 32:19,20 50:4,8 51:19 52:1,6,9,22
30:8 37:7
numbers
33:11,18 34:6,13 42:6,7
53:6 54:8,12 55:8 60:2 62:9 possession
36:22 42:3
59:3,4,13,1361:14,15
63:11 65:17,19
5:8,17
o 66:16
peachtree
object 16:6 26:13 33:6 34:19 35:2 38:22 45:10 46:7 47:12 48:20 49:21 51:2,9 52:11 53:3 54:13,23 61:2
objection 35:7 51:15,21 52:4 53:11
objections 3:16,19
occasional 26:8
occupations 12:19
offered 2:20,23 3:21
office
operators 18:3 22:18 26:7
opportunity 4:17 30:6
optional 14:23
oral 50:21
outside 15:17,20,23 16:2,4 19:9 21:21 24:23 27:3,6,15 32:2 39:8
overhead 18:13
overly 38:23
5:3 21:22 62:15
P
offices
p.m.
1:16 67:21
oh page
33:13
2:13,16
oil pallet
16:20,21
17:12 44:1,20
okay
pallets
5:20 7:20 8:1,11,20,22 9:4 67:6,8
9:16 10:23 11:5,7,14,16,21 paper
12:2,13,17 13:5,20 14:5
33:3 45:20,22 46:2 48:21
17:20 18:20 20:1,7 21:5
49:3 52:5,12,13,16 55:1
22:21 24:12 25:3 26:10 parathion
27:15 29:8,14 31:9 33:10
38:461:13
34:10 40:12,19 42:5 44:13 part
45:3 46:5,14 47:8 48:17
27:8 32:3 33:14 44:9
51:17 52:20 53:14,17 57:12 participate
58:20,23 60:20 61:12 65:16 29:21
old participation
21:9 31:14
once
particular
19:18 20:2 40:20 43:19
12:1522:1929:1032:17
ones
36:13 39:4,22 46:13 47:18
31:11
particularly
open
37:16 52:16 54:14
15:17 18:7,8
parties
operating
3:3 68:14
29:8 passing
64:23
2:11 pension
64:6 people
35:17 54:3 performed
21:22 41:2 49:13,17 54:11 62:14 66:22 67:2 period 30:22,23 33:1,18 51:5 66:14 periods 43:12 permanent 54:21 person 19:1520:3 48:1 personal 45:3,7 pesticides 53:2,10 physical 15:15,18 picking 27:3 place 22:8 25:17 placed 67:5 placing 67:8 plaintiffs 1:4,152:2,204:11,21 plant 8:6,23 9:9 12:7,14,16,19 14:13,15 21:23 22:9 26:18 30:20 32:3,15 36:10 39:7 45:13 46:11 47:14 53:22 54:4,6 55:5,7 56:6 57:15 60:3 64:21 please 4:13,14 5:22 7:12 8:2,3 31:1 50:1 53:4 point 25:15
posted 36:9
pourer 19:6
presence 46:12 48:19 49:14 62:8 68:6
presently 64:15
prior 3:21 65:2
problems 25:2 64:3
process 18:20 24:23 29:11 30:11 44:6
processed 13:9
produce 57:15
produced 66:5
product 19:5 20:6 40:16 43:4,10,13 59:21 65:22 66:1,2,5,7
production 13:10 15:20 24:23 38:11,16 39:20,23 42:19,20 43:1
products 13:4,15,17 16:5 36:13,17 36:18 38:20 39:2 43:16,17 58:21,23 59:14,16,22,23 60:10,11,14,1761:1,3,4
professional 1:13 68:22
prolonged 50:19
prop 17:12
proper 23:12,12
protection 40:15
protective 14:9 32:2,5 34:18 37:18,23
HARTOLDMONO019065
[protocol - samples]
protocol 37:15
provided 32:4
public 3:6 68:23
pulled 18:18
pumped 44:7,9
punishing 23:16
punishment 15:2
purpose 40:8
pursuant 1:18
put 13:7 17:6 44:12 47:4 55:21 56:1 58:1,2,3,4,22 67:4
putting 33:14 43:23 44:19_______
q
question 7:15 18:23 25:22 26:10 34:14 35:3 42:11,16 47:22 53:1,9 55:17 59:6 60:16 64:1 67:16
questions 3:17,18 12:21 40:20
r
rags 44:11
raw 13:6,7,14 38:10,14 39:3 43:17
read 5:11,13,15 35:1942:15,18 45:20 48:21 49:3 50:14 51:1,11,17,23 52:5,6,8,12 52:14,18,20 53:4,5 54:18 55:1
reading 3:10 46:2,5
really 34:15 38:13 46:4
reason 23:4
reasonable 41:19
reasonably 41:21
recall 67:18
receive
rephrase
retire
19:13
7:16
12:11
receiving
report
retired
11:8
24:7 26:6,8,12
6:18 37:10
record
reported
retirement
4:14 7:11 42:17 55:4,18
25:14
6:8 10:11 12:10
reduced
reporter
revealed
68:6
1:13,14 7:8 68:22,22
50:7
referencing
reporter's
review
51:4 2:14 6:1
referring
reporting
right
57:16
1:20
20:14,22 21:8 22:13 24:14
reflected
reprimand
24:17 37:5 38:17 44:2
35:20
23:21,23
57:13,22 65:18 66:3 67:19
regard
reprimanded
risks
50:4,12 55:5 67:3
15:6,9
34:7
regarding
reprimands
river
22:8 15:4 49:1
regardless
request
role
16:16
5:9
13:11,22 26:15 55:11
regards
requested
room
55:12
42:17
15:21 17:20,23 18:2,6,21
regional
requests
19:8,11,13,20 27:6 28:22
1:20
5:18,22
28:23 29:5
registered
required
roughly
1:13 68:22
14:22 15:1 31:13 37:17
37:8
relate
41:17,23
rpr
6:22
requiring
3:5
related
5:2 rule
31:7 37:16
respect
22:7,10
relates
38:8 rules
53:2,10
respective
3:13 7:5 32:3
relating 3:3 run
3:14
respirator
15:21 18:4,10 19:22
relation
33:4 38:1,3,6 40:5,13,14,18 rupture
8:6 9:9 28:4
respirators
61:22
remain
32:23 33:2,7
ruptures
51:20
responsibilities
60:22 62:2
remember
10:17 12:22 13:2 22:17
s
13:16,19 15:19 16:4,14 22:7 24:10 29:14 31:8,10 31:17,18,21 32:1,21 33:1,7 33:12 34:6,9,10 35:10,12 35:22 36:5,11,12 37:2,3 43:11 44:8,8,15 45:1,2 46:5 46:16,19 47:3,18,23 48:16 50:6 52:18 57:3,19 58:14 58:19 59:1,11,22 60:22 61:4,7,9,17,18 62:6 63:8 remind 24:2 renate 53:17 repeated 50:21 51:12
25:7,10 39:15 57:9 responsibility
16:15 17:1023:1,15,19 24:18,22 25:3 26:5 28:16 28:19 39:13 40:21 42:5 43:23 44:19 49:6 50:11 66:9 67:7 responsible 22:21 23:11,22 33:14 38:17 59:18 responsive 5:8,18,21 result 51:19 52:2 results 46:3,4 47:1,5
sabrina 1:3
safety 6:14 13:21 14:8,1721:18 23:2,12,17 30:13 31:3,10 32:14 33:12,21 35:9 37:14 48:14,15
saks 8:21
salers 1:12 3:5 68:21
sample 19:2,6,6 20:3
samples 15:21 17:21 18:3,4,10,21 19:9,14,16,18,23 20:1,4
29:7,12,15 45:8,17 46:3,6
HARTOLDMONO019066
[samples - test]
samples (cont.) 46:15
sampling 24:19
sand 16:20
sands 16:21
santowax 13:17 38:15,19 39:5
saw 24:1
saying 35:17 58:12 60:2 65:19
scan 5:9
scrubber 67:17
seal 68:18
secretary 35:16
seen 5:1 48:22
sense 39:7
sent 55:8
separate 21:4 42:19
serous 51:18
service 1:20
set 1:18 19:21 68:17
sewer 48:9
shield 32:13
shields 14:6 23:6
shift 20:23 22:18,20
shipping 11:8 17:9,13 43:21 49:9
shoes 14:6
short 42:13
shorthand 1:13 68:22
shown 36:12
shows 50:19
signature
spill
supplied
3:10 16:15,18 25:12,14,16 26:11 40:17
sink
spills
sure
18:9 19:21 29:4,5,8,9
16:4,8 25:5 26:8
16:1021:1823:11 27:20
sink's
spot
28:18 35:4 37:1 47:23 50:2
29:17
42:9 sweep
sir
springs
43:5
67:19
9:15 sweeping
site start
27:1 43:11
62:14
10:6,12,15,18 12:23 15:23 swept
six
21:5 43:8,9
43:18 57:23
40:19
started
sworn
sixties
59:19,20
4:4 68:3
62:13 63:5
starting
system
skin 8:15 18:5
51:14,20
state
systemic
small
1:1 4:1,13 8:2
50:22___________________
16:17 26:12 33:3
statement
t
smith 2:10
snow 47:8,11 48:3
soil 45:8,17 46:3,6
solid 61:23
somebody 62:22,23
soon 25:16 61:23
sorry 9:6 22:3 31:2,17 34:16 58:17 59:1 63:3,8
sort 22:19
sound 53:18
sources 45:21
southtrust 1:17
speak 7:21 65:1
speaking 6:4 7:5
special 32:4,16 37:22
specific 20:6,11 34:10 36:6,17 42:3
52:21 53:6 54:15,19 steam
57:15 steel
14:6 32:13 stenography
68:7 stick
16:12 stipulated
3:2,9,15,22 stipulations
1:182:13 storeroom
11:6,1020:15,1721:1,2,10 21:16,1923:10 storm 27:14,18,21 48:9 street 1:21 2:6,11 strike 30:11 33:9 38:18 50:12 52:7 56:3 structure 39:7 studies 49:19 50:3 study 54:10,16 subject 6:1731:1848:12
taken 1:12 3:5 17:21 19:7,9,11 42:14 45:8,17 46:15 58:7 68:2
talk 4:18 7:17 37:14 47:17 48:3 48:4,8 54:5,8 65:5
talked 29:4 31:3 33:20 39:2 46:20 48:13 58:15 67:16
talking 6:21 27:16 28:7 32:18 55:6 56:21,22 59:2 60:9 62:22 63:1,21 66:15
tank 40:1,9,11,16,20 42:23 57:23
tanks 38:21 39:8,16,19,22 41:2 42:7 43:6 44:6
taylor 1:9,11 2:16 3:4 4:3,9,15 5:127:2 41:16
tell 16:11 18:5 28:1 31:22 36:3 41:1950:1759:1065:9 68:4
temperature 19:22
temperatures 50:21
47:17 56:2
sucking
tenure
specifically
18:12
34:12 36:19 45:12 53:23
6:22 24:7 31:6,18 37:11 suite
55:11 58:6 59:9 66:10
39:5 56:10 59:11 speculate
41:17,23
1:162:6,11 supervisor
24:4
term 39:2
test
63:7
HARTOLDMONO019067
[tested - york]
tested
tough
20:12 62:8 63:11
26:10
testified
toxic
4:5 15:12 57:22
50:22
testifying
transcribed
65:10
68:8
testimony
transcript
68:5,11
68:10
tests
transcription
45:4 46:10,16,19,23 47:6
68:9
48:18 49:12,15,16,17 50:2 transferred
50:6 1:2
thank
trash
63:3 27:4
thanks
travel
42:2 60:7
21:21
thereto
treated
3:21 18:1528:13
thing
trial
61:18
3:20
things
true
6:9 23:7 50:15,17 52:19
68:9
think
truth
9:5 15:12 24:14,15 37:6
68:4
49:5 56:18 57:2,7 62:13,19 try
62:21 67:15
7:21 56:2
thought
trying
18:1965:9
7:9 19:17 39:6 44:8 45:2
thrasher
57:7
64:18
twelve
three
16:1
5:13 33:20 43:8 56:9
twenty
time 21:9
3:20,20 5:12 25:15 30:22 type
30:23 31:16 33:1,8 37:3
16:20 29:9 40:13 42:8
39:1 41:7 43:12 45:16 46:9 55:22 58:12
51:5 59:2,4,12 60:3,20,21 types
61:10,1466:14
6:20 33:20____________
timeout 7:17
times 42:3 44:22
title 10:13 11:9,23 12:8 19:14
toe 14:6
toed 32:13
told 27:21 29:23 30:3 33:9 34:17,21 35:4 47:3,15,16 48:1 50:16 51:23 52:21 53:5 54:19 65:7
torres
u
uh 7:7,7,7
ultimate 28:15
ultimately 27:19
understand 7:14 18:23 34:14
understood 21:13
use 27:7 29:1 33:4 38:2,5
usually 19:21 39:19 49:9
2:3
v west
value
2:6 8:23 9:10,11
63:1 whereof
vapors
68:17
50:20
wife
ventilation
63:21
18:5 williams
verbally
24:13
7:6 windows
versus
18:8
1:5 wintertime
vessel
61:19
19:5 witness
vessels
2:16 3:11 8:1 42:10 55:16
13:8,9
66:1968:1,11,17
vicinity
witnesses
9:14 11:20
68:7
visited
word
54:3____________________ 55:15 60:4,6
words
w 7:6 27:7 36:2
waived
wore
3:11,23
40:12
walnut
work
1:21 4:11 6:23 10:15 12:6 14:10
want
14:11 16:1 20:23,23 32:14
7:17 10:9,16 12:20 19:3
49:7 50:18
25:19 60:7
worked
wanted
36:13,19 40:1 56:12 60:11
58:5 65:6
worker
wash
31:7 34:1
29:3 workers
washed
30:8
29:15 43:7 44:5
working
washing
10:7 30:1,4 37:10 46:10
26:23 40:21 44:16
64:11,15,20
waste
wrist
25:12 44:15,23 56:8,16
14:4 32:12
57:5,17 58:3,5,9,12
write
wastes
35:17
49:7 writing
water
68:6
27:7,11 29:1,1341:3 44:7 wrong
44:10,15,23 46:11,15 58:3 67:1
wear
13:21 14:22 21:19 23:16,20 _____________ y_________
37:17
y'all
wearing
4:17
15:3 32:2
yeah
wellborn
13:7 16:9 42:12 43:15
9:1,2
year
went
11:12 12:11 16:1 21:10
13:14 18:17 22:12 24:23 years
27:19,22 29:18 37:21 38:15 10:14 14:1921:9 28:11
38:16 43:14,20 62:15 65:22 37:15 62:12
66:6 67:13
york
2:4,4
HARTOLDMONO019068