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FOSHEE & TURNER COURT REPORTERS 1 IN THE UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF ALABAMA 3 EASTERN DIVISION 4 5 WALTER OWENS, et al., ) 6 Plaintiffs, ) 7 8 vs. 9 ) ) CIVIL ACTION NO. ) CV-P-440-E 10 MONSANTO COMPANY, ) 11 Defendant. ) 12 13 DEPOSITION OF: BILL HUGHES 14 15 In accordance with Rule 5 (d) of The 16 Alabama Rules of Civil Procedure, as Amended, 17 effective May 15,1988,1, TAMMY JENNINGS 18 GREGORY, am hereby delivering to MR. LARRY WRIGHT 19 the original transcript of the oral testimony 20 taken on the 21st day of October, 1999, along 21 with exhibits. 22 Please be advised that this is the same and 23 not retained by the court reporter, nor filed OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035970 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 2 FOSHEE & TURNER COURT REPORTERS 1 with the Court. 2 The deposition of Bill Hughes was taken 3 before Tammy R. Jennings Gregory, commencing at 4 1:30 P.M. on the 21st day of October, 1999, by 5 the Plaintiffs, at the law offices of Fite & 6 Miller, Anniston, Alabama pursuant to the 7 stipulations set forth herein. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035971 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 3 FOSHEE & TURNER COURT REPORTERS 1 APPEARANCES 2 3 Appearing For The Plaintiffs: 4 MITHOFF & JACKS, LLP 5 By: Larry Wright, Esquire 6 111 Congress Avenue, Suite 1010 7 Austin, Texas 78701 8 9 Appearing For The Defendant: 10 LIGHTFOOT, FRANKLIN & WHITE 11 By: Buddy Cox, Esquire 12 The Clark Building 13 400 20th Street North 14 Birmingham, Alabama 35203-3200 15 16 FITE & MILLER 17 By: Arthur Fite, Esquire 18 The SouthTrust Bank Building 19 Suite 400 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035972 20 Anniston, Alabama 36201 21 22 Court Reporter: 23 Tammy R. Jennings Gregory 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 4 FOSHEE & TURNER COURT REPORTERS 1 INDEX 2 3 Witness: Bill Hughes 4 Stipulations...........................page 5 5 Examination by Mr. Wright............. page 9 6 Reporter's Certificate................ page 136 7 8 9 10 11 12 EXHIBITS 13 14 Plaintiffs' No. 1......... ......... page 60 15 Plaintiffs' No. 2......... ......... page 60 16 Plaintiffs' No. 3......... ......... page 60 17 Plaintiffs' No. 4......... ......... page 62 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035973 18 Plaintiffs'No. 5.................... page 96 19 Plaintiffs'No. 6.................... page 97 20 Plaintiffs'No. 7.................... page 131 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 5 FOSHEE & TURNER COURT REPORTERS 1 STIPULATIONS 2 3 IT IS STIPULATED AND AGREED by and 4 between the parties through their respective 5 counsel that the deposition of Bill Hughes may be 6 taken before Tammy R. Jennings Gregory, at the 7 law offices of Fite & Miller, Anniston, Alabama 8 on the 21st day of October, 1999. 9 10 11 IT IS FURTHER STIPULATED AND AGREED that 12 the signature to and the reading of the 13 deposition by the witness is waived, the 14 deposition to have the same force and effect as 15 if full compliance had been had with all laws and OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035974 16 rules of court relating to the taking of 17 depositions. 18 19 20 IT IS FURTHER STIPULATED AND AGREED that 21 it shall not be necessary for any objections to 22 be made by counsel to any questions, except as to 23 form or leading questions, and that counsel for 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 6 FOSHEE & TURNER COURT REPORTERS 1 the parties may make objections and assign 2 grounds at the time of trial or at the time said 3 deposition is offered in evidence or prior 4 thereto. 5 6 7 IT IS FURTHER STIPULATED AND AGREED that 8 the notice of filing of the deposition is waived. 9 10 11 12 13 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035975 14 15 16 17 18 19 20 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 7 FOSHEE & TURNER COURT REPORTERS 1 STATE OF ALABAMA, CITY OF ANNISTON, 2 OCTOBER 21, 1999, 3 1:30 PM., 4 5 BILL HUGHES, 6 having been first duly sworn,was examined and 7 testified as follows: 8 9 COURT REPORTER: Usual stipulations 10 okay? 11 MR. WRIGHT: Yeah. Now, Buddy, one OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035976 12 thing I was just thinking about during lunch 13 -- are usual stipulations -- I don't 14 remember what all the requirements are in 15 Federal Court. 16 MR. COX: Same. 17 MR. WRIGHT: I don't remember all 18 the local rules, but can we agree that if 19 it's not read or signed that it can be used 20 at a hearing? 21 MR. COX: Yeah. We do. 22 MR. WRIGHT: Okay. 23 MR. COX: Other than, I mean, with 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 8 FOSHEE & TURNER COURT REPORTERS 1 possible -- just whatever the normal rule is 2 in terms of, you know, if he's within the 3 subpoena power of the Court -- 4 MR. WRIGHT: When you can use a 5 deposition, right. 6 MR. COX: We're not waiving any of 7 those requirements. 8 MR. WRIGHT: Yeah. In the old days 9 in Texas, you'd get up to trial and he signed OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035977 10 it twenty-two days after the deposition 11 instead of twenty days, and they can move to 12 exclude it, and there goes half your case. 13 You thought you had -- 14 MR. COX: No, if we waive 15 signature, then you can use it just for 16 whatever -- however purposes you can normally 17 use a deposition. 18 MR. WRIGHT: Okay. So with that 19 understanding, the usual stipulations. 20 MR. COX: Did you contact Burr 21 Forman people about these deposition too? 22 MR. WRIGHT: I don't know to be 23 honest. I don't know. I'm assuming they 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 9 FOSHEE & TURNER COURT REPORTERS 1 are. 2 MR. COX: They haven't given any 3 indication they intend to be here? 4 MR. WRIGHT: No. So I don't know. 5 All right. 6 7 EXAMINATION BY MR. WRIGHT: OWENS 05- 15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035978 8 Q. All right. Mr. Miller, have you ever given a 9 deposition before? 10 A. Hughes. 11 Q. I'm sorry. What did I say? I'm sorry, Mr. 12 Hughes. I'm confused. 13 A. No, sir, I haven't. 14 Q. Okay. I'm going to give you the long version 15 of the instructions then. If you'd given a 16 deposition before, I'd give you the short 17 version. 18 I think you understand this, but I 19 just need to make sure that this testimony -- 20 you understand that this testimony can be 21 used at a trial or hearing in the Court? 22 A. Yes, sir. 23 Q. And you understand that the oath you've taken 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 10 FOSHEE & TURNER COURT REPORTERS 1 is the same oath and has the same effect and 2 so forth as it would if you were right there 3 in front of the Judge and jury in the 4 courtroom? 5 A. Yes, sir. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035979 6 Q. Okay. I'd like to ask you if I ask you a 7 question that you don't understand, stop me, 8 and let me know, and just say I didn't 9 understand that question; could you ask it a 10 different way, and I'll do that. Okay? 11 A. Okay. 12 Q. And try to make sure that you understand my 13 question before you answer it because we 14 don't want you answering questions that you 15 don't understand. Okay? 16 A. I understand. 17 Q. And you're doing a good job of this, but let 18 me just remind you to speak out loud so our 19 court reporter can write down the answers. 20 A. Okay. I'm a little horse. I've had a cold. 21 Q. That's okay. We'll go nice and slow. And 22 we're close enough that I think that she'll 23 be able to hear you and I'll be able to hear 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 11 FOSHEE & TURNER COURT REPORTERS 1 you. 2 I assume you're retired now? 3 A. Yes, sir. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035980 4 Q. When did you retire? 5 A. 1st of August of'98. 6 Q. So you recently retired? 7 A. Little over a year. 8 Q. When did you start at Monsanto? 9 A. April of 1962. 10 Q. How old were you then? 11 A. Twenty-two. 12 Q. What had you been doing just generally before 13 you started with Monsanto? 14 A. I worked for a radio and television repair 15 shop. 16 Q. Okay. Are you from this area- 17 A. Yes, lam. 18 Q. -- orginally? 19 MR. COX: The only other admonition 20 is to make sure he finishes his question 21 before you answer. 22 You'll often anticipate where he's 23 going, but just so the record -- you aren't 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 12 FOSHEE & TURNER COURT REPORTERS 1 both talking at the same time and making her OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035981 2 mad, it's easier if you let him finish. 3 Q. (By Mr. Wright) What was your first job at 4 Monsanto? 5 A. I was an operator in the aroclor department. 6 Q. So you were hired straight in as an operator? 7 A. Yes, sir. 8 Q. Okay. Who was your supervisor then? 9 A. My foreman was Mark Williams. The supervisor 10 was Bums Severson. 11 Q. Are either of those people still alive? 12 A. Mr. Williams is, I'm pretty sure. 13 Q. Mr. Severson you think is deceased? 14 A. I think Mr. Severson is deceased. 15 Q. When do you think he died? Just your best 16 estimate. 17 A. Couple years maybe. 18 Q. Couple years ago? 19 A. Yes. 20 Q. Okay. Do you know what he died of? 21 A. No, sir. 22 Q. I imagine you probably worked the night 23 shift, didn't you? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 13 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035982 1 A. I worked all of them. 2 Q. Okay. Y'all rotated? 3 A. Yes, sir. 4 Q. Did you always work with the same 5 supervisors? In other words, did they rotate 6 with you, or did they stay at whatever shift 7 they were at? 8 A. I don't understand what you mean about the 9 supervisors. Are we talking about the 10 foremen? 11 Q. Well, you mentioned there was a foreman and a 12 supervisor, and I was just asking did they -- 13 A. No, sir, they were always on day shift. 14 Q. Okay. How many operators were there on a 15 shift when you first started? 16 A. Just in the aroclor department itself? 17 Q. Yes, sir. 18 A. The two departments were kind of combined 19 polyphenol, but just in the aroclor itself, 20 there was three. 21 Q. Three operators? 22 A. Yes, sir. 23 Q. And then one foreman; right? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 14 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035983 FOSHEE & TURNER COURT REPORTERS 1 A. Yes, sir. 2 Q. Okay. 3 A. Three to the shift. 4 Q. That's right. 5 A. Right. 6 Q. Three operators and one foreman per shift? 7 A. No, sir, the foremen was just on day shift. 8 Chief operator -- the chief operator was over 9 both departments. 10 Q. Okay. So there was -- for each shift, there 11 was one chief operator and three operators? 12 A. For the aroclor department? 13 Q. For the aroclor Department. 14 A. True. 15 Q. How many chlorinators were there at that 16 time? 17 A. Eight. 18 Q. How long did you stay in the aroclor 19 department? 20 A. About five years. 21 Q. Until '67 or thereabouts? 22 A. Thereabouts. 23 Q. Then where did you go? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035984 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 15 FOSHEE & TURNER COURT REPORTERS 1 A. I went to the chlorine plant. 2 Q. And what did you do at the chlorine plant? 3 A. Chief operator. 4 Q. Were you an operator that entire five years 5 at the aroclor department? 6 A. Yes, I was. 7 Q. And then in '67 -- and how long did you stay 8 at that job? 9 A. Now these times are -- 10 Q. I know. Just your best estimate? 11 A. About a year, maybe. Give or take a little. 12 Q. '67 to '68 you were at the chlorine 13 department thereabouts? 14 A. Yes, sir. 15 Q. As chief operator. And then where did you 16 go? 17 A. Back to the aroclor department. 18 Q. As what job? 19 A. Chief operator. 20 Q. And how long did you stay there? 21 A. Well,22 Q. My understanding is that they shut operations OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035985 23 down in May of '72? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 16 FOSHEE & TURNER COURT REPORTERS 1 A. But I left before then. I'm not just sure 2 when, but I left for some period of time 3 because they had a cutback. 4 Q. Okay. 5 A. And I left -- I left the aroclor department 6 and went to the aroclor packaging for some 7 few months. Then I left. After the layoff, 8 I was gone a couple weeks, and I came back 9 and went to the niran department. 10 Q. Was the aroclor department shut down when you 11 came back and went to the niran department? 12 A. No, sir. 13 Q. So it was still going for a little while 14 after that? 15 A. It was still going. 16 Q. So that had to have been -- well, sometime 17 between '68 and '72, you had chief operator, 18 and then you also had a job in the Aroclor 19 packaging department? 20 A. Right. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035986 21 Q. What was that j ob? 22 A. Chief operator. 23 Q. Okay. Okay. And then sometime in, what, 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 17 FOSHEE & TURNER COURT REPORTERS 1 '72, you think -- 2 A. I think it was before then. 3 Q. '71 then? 4 A. Maybe. Maybe '70 maybe. I don't know. It 5 was -- 6 Q. Somewhere along in there you went to the 7 niran department? 8 A. Yeah. 9 Q. As10 A. -- chief operator. 11 Q. Chief operator. And how long did you stay 12 with the niran department? 13 A. Less than six months. 14 Q. Then where did you go? 15 A. Back to Aroclor. 16 Q. Okay. As what job? 17 A. Chief operator. 18 Q. Then how long that time? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035987 19 A. I stayed there until it closed in 72. 20 Q. Do you remember how long it was that last 21 tour? 22 A. Probably a couple years. 23 Q. Okay. All right. Then where did you go? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 18 FOSHEE & TURNER COURT REPORTERS 1 A. I went back to niran. 2 Q. As chief operator again? 3 A. As an operator. 4 Q. As an operator. Okay. How long did you stay 5 in that job? 6 A. Probably two years. 7 Q. Okay. Then where did you go? 8 A. Shipping. 9 Q. And what was your job there? 10 A. An operator. 11 Q. And how long did you stay in that job? 12 A. I stayed in that job probably three, maybe 13 four year. 14 Q. Okay. I know if s hard to remember all this, 15 the dates anyway. What did you do after 16 that? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035988 17 A. I went to chief operator in the shipping 18 department. 19 Q. For how long? 20 A. It was until about '78 maybe. 21 Q. Okay. And then where did you go? 22 A. Maintenance. 23 Q. And how long did you stay in maintenance? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 19 FOSHEE & TURNER COURT REPORTERS 1 A. Until about '86 maybe. Somewhere along there 2 when they shut niran down. 3 Q. You were involved in shutting the niran 4 plant? 5 A. No, I stayed in maintenance until niran 6 closed, and they had a reduction. 7 Q. Okay. Then where did you go? 8 A. I went to waste treatment. 9 Q. And how long did you stay there? 10 A. About a year. 11 Q. Then where did you go? 12 A. Back to maintenance as an electrician. 13 Q. Okay. That was about '87, you think? 14 A. Maybe, or '88. I'm not sure. I'm not sure OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035989 15 just how it was. 16 Q. Back to maintenance as an electrician? 17 A. Uh-huh (indicating yes). 18 MR. COX: You need to say yes. 19 THE WITNESS: Yes. Excuse me. 20 Q. (By Mr. Wright) And how long did you stay in 21 that job? 22 A. About five years. 23 Q. Then where did you go? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 20 FOSHEE & TURNER COURT REPORTERS 1 A. I went back into operations as a chief 2 operator. 3 Q. For -- was that the last job you had until 4 you retired? 5 A. Yes, it was. 6 Q. So '88 to how long as the electrician? About 7 what year do you think you switched out? 8 A. Maybe'92,'93. 9 Q. Okay. And then '93 to '98 chief operator in 10 any particular department? 11 A. Well, for the first couple years, it was 12 probably split between the polyphenol and the OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035990 13 PNP department. The last three years was 14 shipping. 15 Q. I know it was hard to walk through that after 16 all the years and all the different jobs. 17 But I'm not going to ask you about all your 18 jobs, but I'm going to go back and ask you 19 about some specific ones. 20 A. Okay. 21 Q. I want to start in the aroclor department. 22 What did an operator do in the aroclor 23 department? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 21 FOSHEE & TURNER COURT REPORTERS 1 A. You had one operator that ran the 2 chlorinators, and you had one operator that 3 assisted him and also ran the acid 4 department. 5 Q. Okay. 6 A. And you had one operator that ran the aroclor 7 stills. 8 Q. Did you do any one particular jobs, or did 9 you do themall at various times? 10 A. I did them all at various times. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035991 11 Q. Did you do one more than another? 12 A. Probably chlorinators more than the others. 13 Q. Can you describe how the chlorinators worked? 14 A. Yes, sir. 15 Q. For somebody that was never there, kind of 16 paint us a picture. 17 A. Well, we had -- we started with two different 18 products, either started with santowax, which 19 was a terphenly base or biphenyl, and -- 20 whichever product you wanted to make. 21 And you'd put certain amounts of 22 this material into the chlorinator, then 23 you'd add chlorine to it. And you'd sample 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 22 FOSHEE & TURNER COURT REPORTERS 1 it at various times to make sure that it had 2 completed its range where it had a certain 3 range to finish within. 4 And you'd -- you had to keep check 5 on temperatures and so forth. Then when it 6 finished, you would set the valves manually, 7 pump the chlorinator to a blowing tank which 8 was for that particular product. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035992 9 Q. About how long would the process take? 10 A. It would depend on which product you were 11 running. 12 Q. Give me kind of a range. I assume the 1212 13 would have been the quickest? 14 A. Okay. On the chlorinators, it was 1121 would 15 have been the biphenyl that had the least 16 amount of chlorine in it, and it took about 17 an hour. 18 Q. I'm sorry. You mean 1221? 19 A. Well, the raw product was 1121. The finished 20 product was 1221. 21 Q. Okay. 22 A. After it went through the stills, it became 23 1221. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 23 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. 2 A. Took between an hour to hour and a half 3 probably. 4 Q. For the 1121? 5 A. Right. 6 Q. Okay. And then how much for the other OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035993 7 products? 8 A. Well, the 1142 was -- it was on a continuous 9 basis. 10 Q. Even in the early '60s? 11 A. Yes, sir. Fed in one end and just continued 12 on down through four chlorinators and came 13 out the other end. You had to sample these 14 and keep them within range for each 15 chlorinator. 16 Q. Okay. 17 A. Then you had 1148, 1154, 1160, 1162, and 18 1168. And each one just progressed on up the 19 line. It took a little longer for each one. 20 All these are biphenyl base products. 21 Q. Right. 22 A. It took a little longer for each one because 23 that last number was the percentage of 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 24 FOSHEE & TURNER COURT REPORTERS 1 chlorine. 2 Q. How long would it take for the 1168? 3 A. It would take -- sometimes it would take 4 twelve hours or more. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035994 5 Q. Okay. And then the 11 -- 6 A. The 5460 was terphenyl base, and it usually 7 took -- sometimes it would take eight to ten 8 hours. 9 Q. Okay. Now, once it left the chlorinator, 10 where did it go to? 11 A. To the blowing tanks. 12 Q. What happened at the blowing tanks? 13 A. You had air introduced in there to drive off 14 the HCL, the gas, off the product. 15 Q. Okay. Where did the HCL off gas go to? 16 A. It went to a scrubber or through a scrubber 17 onto -- they call a drowning tower that you 18 made acid. 19 Q. Muriatic acid? 20 A. Right. 21 Q. What happened in the scrubber? 22 A. Well, it would trap any organics or anything 23 or the aroclor that was in the product. It 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 25 FOSHEE & TURNER COURT REPORTERS 1 would drop it out into that -- into the -- 2 Q. By "scrubber," you mean they just ran water OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035995 3 through it, or what else? 4 A. No, it was -- I don't know just what the -- 5 it had different screens or filters or 6 something in there to catch the solids. 7 Q. What did it look like? What did the scrubber 8 look like? 9 A. It was -- it was -- it was just a big iron 10 pot. 11 Q. Okay. Was it covered? 12 A. Yes. 13 Q. So it was an enclosed iron pot? 14 A. Yes. 15 Q. What size? 16 A. Well, we're talking about in the early years. 17 Q. Right now, I want to focus on the early 18 years, your'62 to'67 time frame. And then 19 later on, we'll get to the later years. 20 A. Okay. Well, sometime in that period, things 21 were changed around too, '62 to '67, but when 22 I first -- the first -- when I first went -- 23 Q. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 26 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035996 1 A. -- they call it a Coke scrubber. I assume 2 there was Coke in there to help filter this 3 material out into the bottom of the tank. 4 And we would, in turn, drain this 5 material into drums and store it for reuse. 6 Q. By "this material," you mean the Coke 7 material? 8 A. The material that was trapped -- 9 Q. Okay. 10 A. -- in train with the HCL gas it went over. 11 Q. Okay. How did you reuse that? 12 A. We'd carry it back into the department and 13 pull it up. We had a pump that would suck it 14 up. Put a lance down in it and suck it down 15 into the charge tank. And we'd reuse that 16 material. 17 Q. To make aroclor? 18 A. Right. 19 Q. Okay. 20 A. That was mostly used to make 1148, the 21 reclaim material. 22 Q. Okay. Now, I stopped you at the scrubber 23 phase. What happened after -- I'm sorry. I 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 27 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035997 FOSHEE & TURNER COURT REPORTERS 1 stopped you at the -- I can't remember where 2 I stopped you. 3 MR. WRIGHT: Where did we get off 4 talking about the HCL off gas? 5 MR. COX: Scrubber into the 6 drowning tower. 7 Q. (By Mr. Wright) Okay. What happened in the 8 drowning tower? 9 A. It was water added to the HCL. 10 Q. To make the muriatic acid? 11 A. To make the muriatic acid. 12 Q. Where did -- I've seen indication in the 13 documents about water coming off the HCL off 14 gas process somehow and going into the sewer 15 system. What water would that have been? 16 MR. COX: Object to the form. 17 Q. (By Mr. Wright) You can answer. 18 A. Pardon? 19 MR. COX: That's just an objection 20 to the question. You can go ahead and 21 answer. 22 THE WITNESS: At times when you had 23 -- when you had your tanks full or no room 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035998 1-800-888-DEPO 28 FOSHEE & TURNER COURT REPORTERS 1 to put the acid, you would dilute the system 2 with water to drown all the fumes, and all 3 this would go out. 4 Q. (By Mr. Wright) Okay. Would you say that 5 again? I'm sorry. I was -- 6 A. When your tanks were full or for some reason 7 -- or if you had to work on a piece of 8 equipment or something that you couldn't go 9 to the tanks or couldn't make acid for 10 storage, then you would just put a larger 11 amount of water to kill all the acid fumes, 12 to kill all the HCL fumes. 13 Q. Okay. 14 A. And drown that, and that would go out. 15 Q. Okay. So what you're saying is: When you 16 didn't need to make acid or when for some 17 other reason you needed to do so, you'd run 18 more water than was necessary just to make 19 acid into the drowning tank? 20 A. Yes, sir. 21 Q. And then that would flow out and into the 22 sewer system? 23 A. Yes, sir. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0035999 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 29 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. Where did it flow out? Well, let me 2 ask you this: Can you describe the drowning 3 tank? 4 A. No, sir. As far as the internals, I 5 couldn't. 6 Q. What did it look like on the outside? 7 A. It was -- it was just a probably two foot 8 diameter cone shape or upright tank. 9 Q. How high was it? 10 A. Probably fifteen feet maybe. 11 Q. So it would have been a long, thin -- or 12 tall, thin column kind of thing? 13 A. Yes, sir. 14 Q. Where did the--when you would use enough 15 water to have the water come out, where would 16 it come out? 17 MR. COX: Object to the form. 18 MR. WRIGHT: What's wrong with 19 that? 20 MR. COX: I'm not sure you laid a 21 foundation that he would know that, but go OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036000 22 ahead. 23 Q. (By Mr. Wright) You can answer. Where did 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 30 FOSHEE & TURNER COURT REPORTERS 1 the water come out of this fifteen-foot 2 tower? 3 A. Well, you'd have to set the value -- open the 4 valves to go to the sewer. 5 Q. Was it a valve you could open in the bottom 6 of the tank? 7 A. Right. 8 Q. The water would go in and come out this valve 9 and on into the sewer? 10 A. Right. 11 Q. Okay. About how often did you do that? And 12 by "that," I mean, where you open the valve 13 and let the water run on through. 14 A. Well, it -- it would depend. There's no set 15 pattern. It would depend on sales or how 16 many cars or trucks or -- that we had to 17 load. 18 Q. Who would-- 19 A. In those years, it was -- we used most of it, OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036001 20 used most of the acid. 21 Q. How would you know whether or not you needed 22 any more acid? 23 A. Well, you had gauges on the tank. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 31 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. But no, I mean, would they just tell 2 you when you come in to work a shift we only 3 need two thousand gallons of muriatic acid or 4 whatever? 5 A. No, sir. You just -- you just ran to keep 6 the tanks full. 7 Q. Keep the muriatic acid tanks full? 8 A. Right. 9 Q. And when the muriatic acid tanks were full, 10 then that's when you'd open the valve and let 11 the water run on through? 12 A. Right. 13 Q. Where were the muriatic acid tanks? 14 A. They were south of the aroclor department. 15 Q. How many muriatic acid tanks were there? 16 A. Originally, there was three. 17 Q. How big were they to the best of your OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036002 18 recollection? 19 A. I couldn't say. I don't know what gallons. 20 I don't remember. 21 Q. Just ballpark dimensions, were they more than 22 six feet diameter? 23 A. Yes, sir. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 32 FOSHEE & TURNER COURT REPORTERS 1 Q. More than twelve feet? In other words, could 2 you lay -- if you were to lay down twice, 3 would you go all the way across? 4 A. Well, they were long. They were horizontal 5 tanks, not vertical tanks. 6 Q. I got you. 7 A. And they were probably maybe ten feet high. 8 Q. Okay. 9 A. And maybe thirty feet long. 10 Q. Okay. 11 A. So forth. 12 Q. And so muriatic acid would go straight from 13 the HCL drowning tower? It was piped 14 directly to those tanks? 15 A. We had a regular tank. I'm trying to think. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036003 16 We had twenty-two -- we had twenty degree and 17 also twenty-two degree. 18 Q. Oh, two different kind of muriatic acid? 19 A. One was stronger than the other. 20 Q. I got you. 21 A. Less water, it was stronger. We'd go to 22 those regular tanks first, and then you take 23 it out of the regular tanks and run it 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 33 FOSHEE & TURNER COURT REPORTERS 1 through a treatment tank, which had carbon 2 added, and through a filter and exchanger and 3 on back to whichever -- to the -- we called 4 it water white tank then. 5 Q. By "regular tanks," what do you mean when you 6 say there were regular tanks? 7 A. That was -- that was the material that came 8 directly off of the column. 9 Q. Right. That went into what you called a 10 regular tank? 11 A. Yes, sir. 12 Q. How big were those regular tanks? 13 A. Same size. They're all the same size. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036004 14 Q. As the -- 15 A. They were horizontal. 16 Q. Ten feet and thirty feet long? 17 A. Yes, sir. 18 Q. Okay. Let me get it straight. How many 19 regular tanks were there? 20 A. There was two. 21 Q. And then how many storage tanks were there? 22 A. There was two, but they were all -- I guess 23 just consider them all storage tanks. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 34 FOSHEE & TURNER COURT REPORTERS 1 Q. You just called them different things? 2 A. Right. 3 Q. Okay. Was it two tanks for the twenty-two 4 and two tanks for the twenty muriatic acid? 5 A. Yes, sir. 6 Q. Okay. Now, were you involved in changing the 7 filters on those lines that you were just 8 describing? Was that part of your job? 9 A. No, sir, you didn't change them. You 10 backwashed the filter. 11 Q. Where did you backwash it to? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036005 12 A. Backwashed into the ditch. 13 Q. Okay. About how often would have you to 14 backwash it out of the filter into the ditch? 15 A. I think it was every twenty runs for every -- 16 I told you we took it from the regular tank 17 and filled the treater tank up. 18 Q. Yes. 19 A. For every twenty times. I believe that's 20 what it was. 21 Q. Okay. Now, I'm not sure I remember the 22 treater tank. It came out of the tower into 23 the regular tank; is that right? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 35 FOSHEE & TURNER COURT REPORTERS 1 A. Right. 2 Q. And then it came out of the regular tank, and 3 then where did it go? 4 A. To the treater tank. 5 Q. Okay. How big was the treater tank? 6 A. It was probably eight feet across, maybe -- 7 maybe about same height. 8 Q. Eight feet across and about eight feet high? 9 A. Probably. It stood up kind of on legs. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036006 10 Q. Okay. Just one treater tank? 11 A. Yes, sir. 12 Q. So both regular tanks would feed into the 13 treater tank, and then where would it go? 14 A. It would go from there through the filter. 15 Q. Okay. Can you describe the filter? 16 A. No, sir. It was just -- the internals, I 17 couldn't describe it. 18 Q. No, no. I'm sorry. I didn't mean to try to 19 get you to do that. What did it look like on 20 the outside? 21 A. It was probably about three feet across. 22 Three by three. 23 Q. Was it circular or -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 36 FOSHEE & TURNER COURT REPORTERS 1 A. Circular. 2 Q. All right. And I guess it had a valve on the 3 bottom for when you backwashed it? 4 A. You had to change a series of valves there to 5 backwash it. 6 Q. What does that mean, change the series 7 valves? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036007 8 A. Well, I don't remember exactly how it did, 9 but it was a couple of valves you had to 10 change simultaneously -- 11 Q. Okay. 12 A. -- even when you started through the filter. 13 But I don't remember what sequence you'd have 14 to go through or anything like that, but you 15 had to change some valves to backwash the 16 filter. 17 Q. And then I guess there was just a pipe coming 18 out of the bottom of the tank? 19 A. Either the top or the bottom of the filter. 20 Q. Okay. 21 A. I'm not sure if it came in the bottom or out 22 the top or out -- which way. 23 Q. Okay. Now, which ditch was it that it went 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 37 FOSHEE & TURNER COURT REPORTERS 1 into? Is this the drainage ditch? 2 A. Yes, sir. 3 Q. It went on down to those, I guess, what y'all 4 called the limestone pits? 5 A. Yes, sir. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036008 6 Q. And then on out under Clydesdale and -- or on 7 out of the plant and under Clydesdale and on 8 down to Snow Creek? 9 A. Yes, sir. 10 Q. How long would it take you to do twenty runs? 11 I guess what I'm asking -- an easier way to 12 ask that is: Did you backwash once a day 13 or -- 14 A. No, sir. 15 Q. About how often would you have to backwash? 16 A. Probably about every -- maybe once a week 17 maybe. 18 Q. Okay. Once a week on your shift? 19 A. No, the whole thing. 20 Q. For everybody? 21 A. (Witness nods head.) 22 Q. Okay. 23 A. Maybe a little less. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 38 FOSHEE & TURNER COURT REPORTERS 1 Q. By "little less" 2 A. Little less time. I'm not sure. Let's see. 3 It took a while going through the manual OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036009 4 process that way to make a run. 5 Q. Okay. So once a week, maybe a little bit 6 less than one -- I mean maybe a little more 7 often than once a week? 8 A. Right. 9 Q. And then can you give any estimate at all of 10 how often on an average basis -- maybe that 11 would be the easiest way to do it -- the 12 water would run out the bottom of the 13 drowning tower? 14 A. No, sir. 15 Q. No estimate at allon that? 16 A. No. 17 Q. Okay. Was there any other escape of water 18 into either the sewers or the drainage ditch 19 from the aroclor operation other than those 20 two sources that we talked about? 21 Right now I'm not talking about 22 your washing when you wash the area down, but 23 I'm just talking about any other -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 39 FOSHEE & TURNER COURT REPORTERS 1 MR. COX: -- normal production OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036010 2 generation of water? 3 MR. WRIGHT: Yes, yes. 4 THE WITNESS: Inthearoclor 5 department itself? 6 Q. (By Mr. Wright) Yes. 7 A. You had cooling towers on -- cooling coils on 8 the chlorinator. 9 Q. Okay. 10 A. That temperature was controlled by water 11 manually, and that went into a ditch. 12 Q. Okay. Describe that system for me if you 13 would. 14 A. The ditch? 15 Q. No, no, no. 16 MR. COX: Cooling tower. 17 Q. (By Mr. Wright) Cooling coils on the 18 chlorinators. 19 A. The chlorinators were just -- they went from 20 a matter of two floors, two stories. Inside, 21 they had a circular coil from top to bottom, 22 and the water went in the bottom and came out 23 the top and came back down through like a 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 40 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036011 1 two-inch pipe, like a two-inch coil. 2 Q. Came down on the outside of the chlorinator? 3 A. Yes, sir. 4 Q. Okay. 5 A. Down into a concrete ditch that flowed -- on 6 four of the chlorinators, the ditch flowed 7 south, and then it went west and came back 8 north and back east, just came around the 9 pad. 10 Q. Let me try to draw it. Dicky Walker drew the 11 chlorinator area, and I'm trying to remember 12 -- there were eight chlorinators? 13 A. Four here. 14 MR. COX: Your spacing is a little 15 off. 16 Q. (By Mr. Wright) Yeah. Better yet, let me 17 let you draw it rather than me trying to draw 18 it based upon my understandingof his 19 thirty-year-old memory. Let me let you draw 20 it. 21 A. (Witness drawing.) 22 Q. Okay. Were these the actual numbers of them? 23 A. Yes, sir. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 41 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036012 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. Now, you've drawn -- what's this? 2 A. That's the ditch. 3 Q. Okay. Would you label that for me? 4 A. (Witness complies.) 5 Q. Was it a concrete trough? 6 A. It was concrete. 7 Q. Okay. When you first started, was the 8 chlorinator area concreted? 9 A. Yes, sir. 10 Q. With -- how--can you describe the ditch? 11 Like, how deep was it? 12 A. It was probably about a foot deep by maybe a 13 foot wide. 14 Q. Okay. So you walked across it easily? 15 A. Sure. 16 Q. Okay. And-- 17 A. It was more or lesskind of under the 18 chlorinators too. You weren't stepping right 19 over the ditch to get to the chlorinators. 20 This should have been even closer 21 than that, the wayI drew it. 22 Q. So the ditch should be closer to this line of 23 chlorinators? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036013 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 42 FOSHEE & TURNER COURT REPORTERS 1 A. Right. 2 Q. Almost under them, you said? 3 A. Right. 4 Q. Now, it only went under the one through four 5 chlorinators, or was there another one over 6 here that went under the five through eight 7 chlorinators? 8 A. I think these just came out -- there was a 9 sidewalk -- 10 Q. Okay. 11 A. -- came up through here, concreted sidewalk, 12 and I think it just came off into this ditch 13 here. 14 Q. So they drew water from the ditch that ran 15 around the perimeter of the -- all right. I 16 say, "drew water."They fed water into the 17 ditch that ran aroundthe perimeter? 18 A. Right. 19 Q. And then over here on the north side, what 20 did you draw? 21 A. That's where the drain was. 22 Q. Okay. And as far as you knew, it went into OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036014 23 the sewer system at this point? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 43 FOSHEE & TURNER COURT REPORTERS 1 A. Yes, sir. 2 Q. Okay. I'm just going to write sewer drain 3 there. And then so this is where it went, 4 the cooling water went out. It came in 5 through pipes, I assume? 6 A. Yes, sir. 7 Q. Each chlorinator had its own pipe? 8 A. Well, there was a common header, but each one 9 had a -- fed off that header. 10 Q. Okay. Where was the header located? Don't 11 remember? 12 A. I don't remember exactly, but I know that 13 where we turn the water on -- you had to 14 manually turn the water on each one of them 15 -- was about shoulder high to me. 16 Q. Okay. Was that one of the things that varied 17 depending on what product you were making, 18 how much cooling water you let in? I guess 19 what I'm asking: Is that how you regulated 20 the heat? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036015 21 A. That's how. And also by the chlorine, the 22 amount of chlorine you fed. 23 Q. Okay. So basically the way you cooked it, if 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 44 FOSHEE & TURNER COURT REPORTERS 1 you let me use that term, was you would vary 2 the amount of cooling water that it got, 3 which regulated the heat in the process, and 4 you would determine how much chlorine or how 5 long it was exposed to the chlorine to 6 determine it's chlorine content; is that 7 fair? 8 A. Say that again. 9 Q. Okay. Depending on which product you wanted 10 to make, you would vary the chlorine content 11 in order to make the different products; 12 right? You'd take the biphenyl, and you'd 13 add chlorine-- 14 A. Yes, sir. 15 Q. -- to make either 1121 or 1142 or so forth? 16 A. (Witness nods head.) 17 Q. Is that fair? 18 A. That's fair. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036016 19 Q. And the way you added chlorine was you ran 20 chlorine into the chlorinator, and you would 21 determine how much chlorine went into the 22 chlorinator; right? 23 A. Yes, sir. You had a rotormeter. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 45 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. And then you would also determine how 2 hot the process was, and you would do that by 3 letting in more or less cooling water; is 4 that true? 5 A. Yes, sir. 6 Q. Okay. Are those the two primary things that 7 the operator did to make a batch of aroclor 8 was regulate the heat and regulate the 9 chlorine? 10 A. We had to sample it. 11 Q. And then you sampled it to figure out when it 12 was done? 13 A. And charge it and pump it out. 14 Q. Okay. Now, when it came out of the 15 chlorinator, where did it go to? 16 A. To the blowing tanks. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036017 17 MR. COX: Product or work? 18 Q. (By Mr. Wright) Product. 19 MR. COX: He knew; I didn't. 20 MR. WRIGHT: No, he might not have 21 either. That was a good point. 22 Q. I changed the subject on you. When the 23 product came out of the chlorinator, where 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 46 FOSHEE & TURNER COURT REPORTERS 1 did it go to? 2 A. To the blowing tanks. 3 Q. Where were they located? 4 A. They were located north. 5 Q. So~ 6 A. It was on another level kind of in between. 7 This was two levels. 8 Q. Okay. 9 A. You had a bottom floor, concrete floor, and 10 you had steps going up and -- 11 Q. Catwalks up there? 12 A. Well, it was grated. 13 Q. Okay. 14 A. Solid grated up there. Solid floor, I mean. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036018 15 Not solid floor, but grating over the whole 16 floor. 17 And the blowing tanks were about 18 midway between. They were back to the north 19 this way. 20 You had a set of steps come up here 21 in this area, and this had a landing, and 22 then they went up tothis -- 23 Q. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 47 FOSHEE & TURNER COURT REPORTERS 1 A. -- to this step. 2 Q. Go ahead. 3 A. You had a tank here that the continuous 4 chlorinators came into. Then you had a 5 number three and number four. 6 Q. Tell you what. Let's do this. Take this 7 piece of paper off and set it like that, and 8 then go ahead and continue your drawing to 9 the north. 10 A. (Witness complies.) I'm trying -- they 11 changed all this up. And I'm trying to 12 remember how it was originally. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036019 13 Q. What you're drawing right now is the way it 14 was when you started; right? 15 A. Right. 16 Q. Okay. 17 A. This is the in between level where you came 18 down. There was also -- you came on the same 19 level upstairs. You kind of came across a 20 little catwalk and number two. 21 Number two blower tank was up 22 there. It would have been approximately in 23 this area, but it was a higher elevation. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 48 FOSHEE & TURNER COURT REPORTERS 1 Q. Let's do a kind of dotted, and then we'll 2 just make a note that would have been -- that 3 was higher? 4 A. Higher. 5 Q. Okay. Higher level. Okay. What was this 6 one? 7 A. I'm trying to think what we called it. But 8 that was really -- it was the catch tank for 9 the continuouschlorinator. 10 Q. Okay. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036020 11 A. They came in here continuously. 12 Q. Can you write that? Write catch tank for 13 continuous chlorinator. 14 A. (Witness complies.) 15 Q. And which were the continuous chiorinators? 16 A. Five, six, seven, and eight. 17 Q. Okay. And by continuous chlorinator, do you 18 mean that you'd start at five and then go 19 into six and go into seven and then go into 20 eight and then come out eight and go into the 21 catch tank? 22 A. Right. 23 Q. And you told me, but I forgot. Which 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 49 FOSHEE & TURNER COURT REPORTERS 1 products did you make generally through the 2 continuous chlorination process? 3 A. 1142. 4 Q. That's the only one? 5 A. That's the only one on the continuous. 6 Q. Okay. Was that the single most poplar 7 aroclor that y'all made? 8 MR. COX: Object to the form. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036021 9 Q. (By Mr. Wright) Was that the one you made 10 the most of? 11 A. I would say so, yes. 12 Q. What happened in the melting pot or the melt 13 pot? 14 A. That could be charge tank. We would draw a 15 charge for whatever product we were going to 16 charge the chlorinators. 17 Q. Yes. 18 A. We'll either draw biphenyl from the biphenyl 19 stills or santowax from the santowax stills 20 into this. 21 We would measure with a rod so many 22 inches for the charge and then close off -- 23 this is the same tank that we would pull the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 50 FOSHEE & TURNER COURT REPORTERS 1 trappings or that we got out of the Coke 2 scrubber we'd pull back into this tank. 3 Q. Pour it back into here? 4 A. We'd pull it back. 5 Q. By "pull it back" -- 6 A. Suction. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036022 7 Q. Okay. You'd put that in a drum and then take 8 the drum over here and suck it into the melt 9 pot? 10 A. Right. 11 Q. Is that right? 12 A. Right. 13 Q. Okay. 14 A. Or charge tank. 15 Q. Okay. 16 A. I'll call it a charge tank. 17 Q. Okay. And then as I understand it, you would 18 take it -- this is where you basically got 19 your raw material to put into the batch of 20 chlorinators? 21 A. From the charge tank, yes, sir. 22 Q. Okay. And you could pump it from the charge 23 tank into any chlorinator you wanted to? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 51 FOSHEE & TURNER COURT REPORTERS 1 A. Yes, sir. 2 Q. Through a system of valves, I guess, valves 3 and pipes? 4 A. Right. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036023 5 Q. Now, going back here one, two, three, and 6 four, what are they called again? 7 A. Blow tanks. 8 Q. Okay. And what would happen in the blow 9 tank? 10 A. Air would go into it, drive off the HCL 11 fumes. 12 Q. Okay. And is that where you captured the HCL 13 fumes from to go to the muriatic acid 14 production process? 15 A. From there and also from the chlorinators. 16 Q. Okay. 17 A. You reduced it also there. 18 Q. Okay. So you'd draw straight off of the 19 chlorinators and then some off of the blow 20 tanks? 21 A. Yes, sir. 22 Q. Okay. What happened after that had occurred? 23 MR. COX: To the product or to the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 52 FOSHEE & TURNER COURT REPORTERS 1 acid? 2 MR. WRIGHT: Well, we talked about OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036024 3 the acid process a minute ago. I'm going to 4 leave that for a second, so let's focus on 5 the product. 6 Q. After the product goes into the blow tanks, 7 the air comes in, blows the acid off, and 8 then what happens to the product? 9 A. It's then transferred to the stills. 10 Q. Where are the stills located? 11 A. They're located to the east, to the east of 12 the chlorinators. 13 Q. Okay. 14 A. East of the chlorinators. East of this area 15 (indicating). 16 Q. Okay. I'll just do an arrow and say to 17 stills. 18 A. Okay. 19 Q. How many stills were there? 20 A. Three. 21 Q. Were they circular tanks? 22 A. Yes, sir. 23 Q. Can we draw -- do we have enough room to draw 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 53 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036025 1 them here? 2 A. Well, not really. 3 Q. Okay. 4 A. They were -- you can draw them like this 5 (indicating). 6 Q. So they were a line going to the east? 7 A. Going to the east. 8 Q. Okay. 9 A. One, two, three. 10 Q. And what happened in the stills? 11 A. Again, you charge them to a certain level and 12 put a vacuum on them, put fire on the coil, 13 circulated them to the coil, heated the 14 material up, and distributed it over to a 15 column into a receiver. 16 Q. Let's do it on another sheet of paper. 17 That's a little more complicated than I 18 originally thought. 19 A. (Witness drawing.) 20 Q. Okay. And what happened in the stills now? 21 The product goes into it? 22 A. Product goes into it, vacuum and fire. 23 Q. By "fire," what do you mean? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 54 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036026 FOSHEE & TURNER COURT REPORTERS 1 A. Heat on the coil. You circulate it through a 2 column and -- 3 Q. Where is the coil? 4 A. The coil is in the column. 5 Q. Okay. 6 A. Well, actually there is a fire box right next 7 to the still, kind of in behind it and comes 8 out and goes through the spiral coil, and 9 you've got fire against the coil heating it 10 up. 11 Q. Okay. 12 A. And it comes off there and goes into the 13 column. 14 Q. Is the aroclor circulating through the coil, 15 or is there some kind of -- 16 A. Yes, sir. 17 Q. -- heat exchange. Okay. Okay. 18 A. And then vacuum is on it to lower the boiling 19 point as I understand it. 20 Q. Okay. 21 A. The lighter material comes off first, comes 22 over the column, down through a line into the 23 receiver, which would be just north. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036027 1-800-888-DEPO 55 FOSHEE & TURNER COURT REPORTERS 1 Q. East still had its own receiver? 2 A. Yes. 3 Q. Okay. And is that the final product now in 4 the receiver? 5 A. No, it's filtered then from there. 6 Q. Okay. 7 A. We added earth to these receivers. 8 Q. Okay. 9 A. And then came out the bottom through a 10 filter. 11 Q. Was the filter right there at the receiver? 12 A. The filter was -- there was just one filter 13 for all of them. 14 Q. Okay. 15 A. But mainly, it was for two and three still, 16 the filter was. Mainly number one still was 17 primarily for the solid, which that was 18 terphenyl base. No biphenyl in it at all. 19 It was not filtered. 20 Q. Okay. 21 A. Then from -- into a filtered receiver. 22 Q. Would you mind labeling those things? As 23 soon as you say it, I'm going to forget it if OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036028 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 56 FOSHEE & TURNER COURT REPORTERS 1 we don't. 2 And then this was your filter? 3 And what did you call that? 4 A. Filter receiver. 5 Q. Okay. And what happened after it got to the 6 filter receiver? 7 A. From here, pumped to storage tank. 8 Q. Okay. So at this point, it's basically done 9 and ready to go? 10 A. Right. 11 Q. What did the fire box use for fuel, do you 12 know? 13 A. Natural gas. 14 Q. Okay. Would you do the directions on there 15 so we know which way that should be oriented? 16 A. (Witness complies.) 17 Q. And this would be the-- 18 MR. COX: -- east side of the 19 chlorinator. 20 Q. (By Mr. Wright) Chlorinator department. 21 Okay. Okay. Good deal. Okay. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036029 22 Going back now to the chlorinator 23 area. When you wash this area down, my 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 57 FOSHEE & TURNER COURT REPORTERS 1 understanding is you washed this down every 2 shift? 3 A. Yes, sir. 4 Q. When you washed it down, would you wash it 5 into the ditch? 6 A. Yes, sir. 7 Q. Okay. So there weren't any -- necessarily 8 any drains here? The ditch was basically one 9 big drain? 10 A. Yes, sir. 11 Q. And then it all got routed over here to the 12 sewer drain? 13 A. (Witness nods head.) 14 Q. Were there any -- well, let me ask you this: 15 Was the still area concreted? 16 A. Yes, sir. 17 Q. Was it in a building? 18 A. Yes, sir, if s covered. 19 Q. So this was -- all of these three areas that OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036030 20 we've talked about: The chlorinator area, 21 the blow tank area, and the stills were all 22 in a building? 23 A. No, sir. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 58 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. Which was not in the building? 2 A. The chlorinator area was not in the building; 3 the still area was. 4 Q. Okay. 5 A. Under roof. 6 Q. The chlorinator area wasn't under roof at 7 all? 8 A. No, sir. 9 Q. Okay. I thought it was. Okay. 10 Okay. So did the building start-- 11 building started here with the blow tank 12 area? 13 A. No, sir. 14 Q. Okay. I'm confused because I thought we had 15 stairs going up? 16 A. You do. 17 Q. Okay. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036031 18 A. But that's outside still. 19 Q. Oh, the stairs are on the outside? 20 A. Uh-huh (indicating yes). 21 Q. Okay. I got you now. 22 A. The building started -- it was a walkway 23 between the chlorinator area. Come on down, 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 59 FOSHEE & TURNER COURT REPORTERS 1 and the control room was just east of the 2 blow tank area here. 3 Q. Okay. 4 A. Just a small area. 5 Q. Okay. 6 A. Under, you know, that's where the building 7 starts. 8 Q. So the stills -- this is wrong when I say two 9 stills here on the blow tank area? 10 A. It would be right, but it would be for the 11 upstairs. This would be going upstairs too 12 also. 13 Q. Okay. Oh, okay. So the control room was on 14 the ground floor, and directly above the 15 control room was the stills? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036032 16 A. No, because the control room -- it was--it 17 was kind of like under a shed, the control 18 room off the front of the building. Then the 19 building was two story or three story, 20 whatever. It would have been further behind 21 the control room. 22 Q. Okay. I'm going to go ahead and mark these 23 1,2, and 3. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 60 FOSHEE & TURNER COURT REPORTERS 1 (Plaintiffs'Exhibits Numbers 1,2 2 and 3 were marked for 3 identification, and copy of same is 4 attached hereto.) 5 Q. Number 1 we'll mark the one we talked about 6 first, which is the chlorinator area. 7 Number 2 will be the one we talked 8 about second, which is the blow tank area to 9 the north of the chlorinator area. I'm just 10 going to write to Exhibit Number 2. 11 And then I'll do another one 12 generally to Exhibit Number 3. Is that fair? 13 Is that about the way they would be situated? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036033 14 See what I've done? Start with 15 Exhibit Number 1, and Number 2 is drawn to 16 the north of it, and then Exhibit Number 3 17 would be over here somewhere about like that? 18 A. Right, and upstairs. 19 Q. Okay. 20 A. Now this -- well, actually, the stills 21 themselves, the top where they stuck through 22 the floor, part of them hung beneath the 23 floor. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 61 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. 2 A. And part was above the floor, and part was 3 beneath the floor. 4 Q. Okay. 5 A. All the rest was on -- except for the 6 filter. The filter was sitting up there. 7 Q. Okay. Can you draw the walls of the building 8 generally around the still area? 9 A. (Witness complies.) Steps down here. 10 Q. Okay. 11 A. Steps are down here. Control room's -- OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036034 12 Q. Okay. Would you write that in there, control 13 room? 14 A. (Witness complies.) 15 Q. Okay. Now, where did the -- where was the 16 acid production facility located, which 17 direction? 18 A. It was -- 19 Q. To the south of the chlorinator area? 20 A. To the south of the chlorinator area. 21 Q. Just write that in there. Let me ask you one 22 other favor. 23 A. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 62 FOSHEE & TURNER COURT REPORTERS 1 Q. Let's draw the acid production area, and I'm 2 going to label that Number 4. I'll say see 3 Exhibit Number 4. 4 5 (Plaintiffs' Exhibit Number 4 was 6 marked for identification and 7 copy of same is attached 8 hereto.) 9 A. (Witness complies.) OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036035 10 MR. WRIGHT: I'll take a break as 11 soon as he's done. 12 A. A little thing here called an ion exchange. 13 I never did know what it was, but it's 14 something -- 15 Q. Okay. Did those tanks have numbers? 16 A. Well, that's the reason I didn't put anything 17 down because I'm not for sure. I think this 18 was twenty-two regular. 19 Q. Okay. 20 A. Twenty regular, twenty-two water white, 21 twenty water white.Could be right backward. 22 Q. Let's write that down, and we'll just -- 23 A. Would that matter? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 63 FOSHEE & TURNER COURT REPORTERS 1 Q. I don't think it matters, but I do want to 2 show basicallyhow they related to each 3 other. 4 MR. COX: And WW stands for? 5 THE WITNESS: Water white. 6 MR. COX: Water white. 7 THE WITNESS: Do I need to write OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036036 8 that down? 9 MR. COX: No, that's fine. It will 10 be on the record. 11 Q. (By Mr. Wright) Okay. Now, was there a 12 drainage ditch in that area? 13 A. It came out of down this area. 14 Q. Did it go underground? I guess what I'm 15 asking is: You've drawn it kind of ending 16 here. 17 A. It was open here. It stopped somewhere in 18 this area. I'm not sure exactly where. 19 Q. Okay. 20 A. But it could have been further on out, but -- 21 Q. And then ran back that way towards the tower. 22 Did the tower kind of sit over it? 23 A. Yeah. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 64 FOSHEE & TURNER COURT REPORTERS 1 Q. Or right almost over it? 2 A. Yes, sir. 3 Q. And so when the water ran out of the tower, 4 that's where it would go is right into that 5 drainage ditch? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036037 6 A. Yes. 7 Q. Where did the drainage ditch go after the 8 tower? 9 A. It went underground here. 10 Q. Okay. It went into a drain right there at 11 the tower? 12 A. Yes. 13 Q. Okay. Now the filter, did you backwash this 14 filter also? 15 A. Yes, sir. That's the one we backwashed. 16 Q. And when you backwashed it, it just went 17 right into the ditch? 18 A. Right. 19 Q. Okay. The filter over here in the -- off the 20 batch receivers -- 21 A. Yes, sir. 22 Q. -- I can't remember, did you describe it? 23 A. I didn't describe it, no. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 65 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. Tell you what, let's take our break, 2 and when we come back, we'll start talking 3 about the filter so at least we'll know where OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036038 4 we left off. 5 (Short recess.) 6 Q. (By Mr. Wright) Let me just make sure that I 7 remember how -- well, would you do me a favor 8 -- and I know you've already done this -- 9 but would you just kind of summarize the flow 10 of the HCL off gas through the acid area 11 that's shown on Exhibit Number 4 just so that 12 I get it down in my mind one more time? 13 A. Just from this point forward? 14 Q. Yes, sir. 15 A. From the drowning tower forward? 16 Q. Is that the first place where the gas goes? 17 A. After it comes off scrubbers, chlorinated 18 scrubbers. 19 Q. Where is the scrubber? That's the step we're 20 missing. 21 A. It's just south of the tower. This is-- 22 Q. You've drawn it outside. 23 A. Right. It is outside. This was one long 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 66 FOSHEE & TURNER COURT REPORTERS 1 building from this area on up to here OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036039 2 (indicating). 3 From the aroclor department -- from 4 where you made the aroclor, you also made the 5 biphenyl in that same building. 6 Q. Right. 7 A. The building carried on up. At the end of 8 the building, south end of the long building, 9 was the scrubber for the HCL. 10 It was a railroad track and spur 11 loading docks and so forth. And the scrubber 12 was right there by the tracks. 13 Q. Okay. 14 A. But the HCL came down the building, all the 15 way down the building, and came onto the 16 scrubber. 17 Q. Okay. This was down here at this end; right? 18 A. This? Right. 19 Q. Yeah. Okay. And it sat like this? 20 A. Uh-huh (indicating yes). 21 MR. COX: You need to say yes or 22 no. 23 THE WITNESS: Yes. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 67 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036040 1 Q. (By Mr. Wright) Let me see your pen there 2 for a second. This is the edge of the 3 chlorinator area? 4 A. Well, actually from the edge of the 5 chlorinator area, you had a maintenance 6 shop. Then you had biphenyl still area and 7 biphenyl control room, hydrogen compressors 8 and all that in between before you got on up 9 to the end of the building. 10 Q. Okay. So this is just the end of the 11 building? 12 A. Right. 13 Q. Did you call it the aroclor building? 14 A. (Witness shakes head.) 15 Q. Do you remember what you called it? 16 A. (Witness shakes head.) 17 Q. All right. Okay. Now, I interrupted you. I 18 was going to ask you to walk me through the 19 processing of the HCL gas. And it came from 20 the chlorinators, and it was piped into 21 the -- 22 A. Came through the scrubber. 23 Q. Okay. Let's label that scrubber. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 68 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036041 FOSHEE & TURNER COURT REPORTERS 1 A. (Witness complies.) 2 Q. And let's label this HCL off gas. Is that 3 what y'all called it? 4 A. (Witness nods head.) (Witness complies.) 5 Q. Okay. And then after going to the scrubber, 6 where did it go? 7 A. Just came across theroad to the tower. 8 Q. Okay. And then from the tower, it went 9 where? 10 A. That's where the water was mixed. 11 Q. Right. 12 A. It went either-- 13 Q. Went to one of the tanks? 14 A. One or the other. 15 Q. One of the regular tanks? 16 A. One of the regular tanks. 17 Q. Okay. Then where did it go? 18 A. Came out of the regular tank to the treater 19 tank. 20 Q. Okay. Just for the record, we're looking at 21 Exhibit Number 4 now is what we're working 22 on. 23 So it came out of the regular tank OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036042 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 69 FOSHEE & TURNER COURT REPORTERS 1 to the treatment tank, treater tank? 2 A. Right. Yes, sir. 3 Q. And then out of the treater tank to the 4 filter; is that right? 5 A. Right. In this treater tank, we had carbon 6 that it was treated with. You agitated it 7 for a couple hours and then settled itand so 8 forth. 9 Then you went through the filter 10 through the ion exchange back to the treater 11 tank. 12 Q. Okay. 13 A. Circulated it for thirty minutes or so until 14 it cleared up, everything cleared up. 15 Q. Okay. Okay. 16 A. Then you'd switch those valves, closing off 17 coming back to here and opening up -- coming 18 back to the treater tank, and then you, in 19 turn, would open up to the water white tank. 20 Q. Okay. So the treater tank is actually the 21 process that you had to go through? 22 A. Yes. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036043 23Q. It wasn't just a step in the journey to the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 70 FOSHEE & TURNER COURT REPORTERS 1 water white tanks. Okay. 2 Now, going back to the aroclor 3 production area. You mentioned at one point 4 from time to time you had to clean out the 5 chlorinators, I think? 6 A. (Witness shakes head.) 7 Q. Did I misunderstand that? 8 A. You misunderstood. 9 Q. So that wasn't one of the things you 10 regularly did was clean out the chlorinators? 11 A. No, sir. 12 Q. Did you ever clean out the chlorinators? 13 A. I don't remember ever cleaning them out 14 myself. 15 Q. Now, when I say, "you," I don't necessarily 16 mean you, Mr. Hughes. I mean any-- 17 Monsanto. Did anybody have to clean out the 18 chlorinators? 19 A. Occasionally they might if they had to change 20 a coil or something like that in there if OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036044 21 they had a coil leaking or had to do some 22 repair inside the chlorinator. 23 Q. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 71 FOSHEE & TURNER COURT REPORTERS 1 A. Usually you could drain them. You could 2 drain the chlorinator, and it would pretty 3 well get everything out. Drain it out the 4 bottom. 5 Q. Okay. Did you ever -- and again, when I say, 6 "you," I'm not talking about you personally 7 necessarily -- did y'all ever have to change 8 or clean out the catch tank? 9 A. Not that I remember. 10 Q. What about theblow tanks? 11 A. No, sir. 12 Q. The stills? 13 A. The stills wereroutinely--they called it 14 drawing bottoms. The heavier material was 15 left after so many runs. 16 Q. Right. 17 A. And they would draw those in drums. 18 Q. Okay. And then what happened to the drums? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036045 19 A. Some of them were sold as products, and the 20 others, I don't know. I assume they were -- 21 I don't know. 22 Q. Okay. Did you ever work at the landfill or 23 do anything at the landfill? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 72 FOSHEE & TURNER COURT REPORTERS 1 A. I never worked up there. I've carried stuff 2 there. 3 Q. I'll ask you about that later then. 4 Did the receivers ever have to be 5 cleaned out? 6 A. No, sir. 7 Q. Now, I was going to ask you about this 8 filter, and the filter I'm talking about is 9 the filter on Exhibit 3 that was in the still 10 area. Could you describe it? 11 A. It was made up of plates. Probably plates 12 were probably an inch thick. You put paper 13 between plates. 14 The plates had holes, a hole in the 15 corners for the material to come through, 16 which forced the material through the OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036046 17 papers. And the plates wereprobably two 18 feet by two feet, maybe two and a half by two 19 and a half and square. 20 Q. Okay. So was it kind of box shaped on the 21 outside? 22 A. Right. 23 Q. Okay. Did y'all ever have to change those 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 73 FOSHEE & TURNER COURT REPORTERS 1 filters? 2 A. Always. 3 Q. Okay. How often would you have to change 4 those filters? 5 A. Well, some people changed them more often 6 than others. You changed them when you had 7 to or when the material slowed down and you 8 couldn't filter it through there. 9 Q. About how often would that -- 10 A. Probably ever couple of batches you put 11 through there. 12 Q. So you might have to change the filter a 13 couple times on a shift? 14 A. Could, or maybe more. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036047 15 Q. Okay. 16 A. Sometimes. Depending. 17 Q. Okay. At the very least, it was a daily 18 thing? 19 A. This was removing the earth that was added 20 into the filter -- I mean to the batch 21 receivers. 22 Q. Okay. What happened to the old filters? 23 A. They were put in the drums. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 74 FOSHEE & TURNER COURT REPORTERS 1 Q. Along with the collected earth, I assume? 2 A. Yes, sir. 3 Q. Okay. Was there -- was there a drainage 4 ditch in the stills area? 5 A. No, sir. 6 Q. Were there sewer drains? 7 A. No, sir. 8 Q. Did you ever wash -- well, was this 9 concreted, the still area? 10 A. Yes, sir. 11 Q. Did you ever wash it down? 12 A. No, sir, not that I -- I can't remember OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036048 13 washing the still area down. If you did, 14 you'd wet everything down below. 15 Q. Oh, that's right. 16 A. There were people working below you. 17 Q. All right. I forgot. Okay. I got you. 18 So anything -- for example, if 19 anything leaked, it would drip down to what 20 area of the plant? 21 A. Well, it wouldn't necessarily. We kept sand 22 boxes around. Any leaks or anything was 23 absorbed with sand and then -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 75 FOSHEE & TURNER COURT REPORTERS 1 Q. I may be confused. This is not the area 2 where you had grating -- 3 A. No, sir. 4 Q. -- all across? This was a solid floor? 5 A. Yes, sir. 6 Q. Okay. 7 A. Grating was in the chlorinator area. 8 Q. Okay. 9 A. In the blow tank area. 10 Q. Okay. So the floor to the stills area was, OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036049 11 you said, concrete? 12 A. Yes, sir. 13 Q. How did you get the drums -- for example, 14 when you emptied out your filter and put it 15 in a drum, how would you get the drums out of 16 the stills area? 17 A. We'd just take them down the stairs. 18 Q. Take them down the stairs? 19 A. Yes, sir. 20 Q. How did you take them down the stairs? 21 A. Just on -- with drum trucks or manually or 22 however. 23 Q. I may have a bad image. When you say, 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 76 FOSHEE & TURNER COURT REPORTERS 1 "drum," I'm thinking of, like, a fifty-five 2 gallon drum. Is that what you're talking 3 about? 4 A. Yes, sir. They weren't real heavy drums. 5 They were light weight drums. 6 Q. Could one man carry a drum downstairs? 7 A. Yes, sir. And also, we had -- we had 8 laborers that helped, that would help at OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036050 9 times, if you needed help. 10 Q. If you had a spill up there, how did you 11 clean it up? And by "up there," I'm talking 12 about in the stills area. 13 A. Usually with sand. 14 Q. Could you kind of describe that process for 15 me? 16 A. Well, you'd just put sand down on it, absorb 17 it, shovel it up, and put it in the drums. 18 Q. Is that the same process you would use in any 19 of these other areas that were concreted 20 where you'd have a spill or a leak? 21 A. Yes, sir. 22 Q. Was it someone's job to sweep that still area 23 out on a regular basis? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 77 FOSHEE & TURNER COURT REPORTERS 1 A. The operator. Every operator was responsible 2 for his own area. 3 Q. Every shift? 4 A. Yes, sir. 5 Q. So if you were working, at the end of your 6 shift, would you sweep up the whole area? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036051 7 A. Yes, sir. 8 Q. Where did you sweep it to? 9 A. Just sweep it into a pile. Shovel it up. 10 Q. Okay. What did you do with the pile after 11 you shoveled it up? 12 A. Put it in the trash drums. 13 Q. Was there any area that you washed down other 14 than the chlorinator area, on a regular 15 basis I mean? 16 A. No, sir. 17 Q. Was the blow tank area on the bottom floor? 18 A. It was -- the tank was suspended between 19 floors, the blow tanks were. 20 Q. Okay. So underneath the blow tanks was the 21 first floor? 22 A. Right. 23 Q. Was it concreted? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 78 FOSHEE & TURNER COURT REPORTERS 1 A. It was concreted. 2 Q. Did it have a drainage ditch through it? 3 A. No, sir. 4 Q. Did it have sewer drains? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036052 5 A. That one same drain that was at the comer of 6 the chlorinator area. 7 Q. This one here? 8 A. Yes, sir. 9 Q. Were you able to wash -- for example, if you 10 had a spill or leak or something, were you 11 able to wash this area, the blow tank area? 12 A. Yes, sir, you could wash it. 13 Q. Okay. And when you washed it, that would go 14 to the sewer drain as well? 15 A. Yes, sir. 16 Q. Okay. Dicky Walker mentioned steam cleaning 17 from time to time. 18 A. Yes, sir. 19 Q. How often would you steam clean? 20 A. You might -- you might have something like a 21 corporate inspection maybe once a year, 22 something like that, you know, wanted 23 everything to look real good and steam off 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 79 FOSHEE & TURNER COURT REPORTERS 1 handrails and grating and so forth and so on. 2 Q. Okay. And I guess if there was a big spill OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036053 3 or something, you might steam clean for final 4 clean up of that? 5 A. Usually if you had much of a spill, you'd put 6 sand down and get it up with sand. 7 Q. Right. 8 A. And it'd pretty well take care of it. 9 Q. Well, but there would still be a residue, 10 wouldn't there? 11 A. Well, you put sand down on top of it. That 12 would pretty well absorb it for the most 13 part. 14 Q. I'm sorry. What I'm saying is: For example, 15 I've spilled a can of motor oil before, and 16 I've done something similar to that where I 17 either put sand down or put down that -- what 18 do you call that stuff? 19 MR. COX: Oil dry? 20 Q. (By Mr. Wright) Yeah. And that gets most of 21 it up, but there's still a spot of oil on the 22 concrete. And I've never yet gotten every 23 grain of sand up or every grain of oil dry. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 80 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036054 1 Did you routinely wash those areas 2 off or -- 3 A. Yes, sir, we'd wash under the blow tanks. 4 Q. Okay. 5 A. Routinely. 6 Q. Okay. Now, Dicky mentioned something that 7 you might be able to explain a little bit 8 better. He said sometimes, I guess when 9 things would get caked or something, that 10 they would take a hose with natural gas and 11 run it under a drum lid and bum that stuff 12 or heat it, I guess, with that flame? 13 A. (Witness nods head.) 14 Q. You're nodding your head. Do you remember 15 that? 16 A. I sure do. 17 Q. Can you describe that better? I didn't quite 18 understand it. 19 A. That was more on the bottom level of the 20 still area -- 21 Q. Okay. 22 A. -- where this took place. 23 Q. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 81 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036055 FOSHEE & TURNER COURT REPORTERS 1 A. And the laborers did that occasionally. 2 Q. Okay. 3 A. Where it would kind of get packed down. 4 Q. Where what would get packed down? Stuff 5 falling out of -- 6 A. Different materials and sand and so forth. 7 Q. All right. 8 A. And that area, the bottom floor, that was 9 where your drums were that you drew the 10 bottoms, and you might get some splash or 11 whatever. 12 Q. Okay. 13 A. And they would take a drum lid or a piece of 14 tin, something like that, and they would put 15 sand down also. 16 Q. Okay. 17 A. And put the hose under there and let it heat 18 it up and melt it. And then they had a 19 scraper just like a hoe flattened out -- 20 Q. Okay. 21 A. -- where they scraped it up. 22 Q. So after they put the flame on it, it would 23 sometimes melt, yousay? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036056 1-800-888-DEPO 82 FOSHEE & TURNER COURT REPORTERS 1 A. Right. 2 Q. Okay. 3 A. Or mix with the sand. 4 Q. And how long would they have to leave the 5 flame on it -- any ballpark idea -- before it 6 got loose enough to where they could hoe it 7 up? 8 A. Usually wouldn't leave it long. If it did, 9 the concrete would start popping and bust or 10 flake off. 11 Q. Okay. Any feel for how often they would do 12 that? 13 A. No, sir, I couldn't say. I'd just see them 14 doing it occasionally. 15 Q. Okay. And you say that the laborers were 16 mostly responsible for that? 17 A. Yes, sir. 18 Q. How many laborers were there generally on 19 duty? 20 MR. COX: In the aroclor unit? 21 Q. (By Mr. Wright) In the aroclor department. 22 A. Well, it was all kind of combined. The 23 laborers -- it was all one department, OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036057 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 83 FOSHEE & TURNER COURT REPORTERS 1 aroclor, biphenyl together, and they worked 2 for -- you had one chief over it, and the 3 labors worked, you know, just one for the 4 other. 5 But there's always two, and 6 sometimes there's three to a shift. 7 Q. Okay. Now, that stuff we were talking about 8 where they'd burn it off the floor or heat it 9 up under the stills area, that would be 10 aroclor material that had accumulated over a 11 period of time? 12 A. Yes, sir. 13 Q. Okay. 14 A. As well as sand or whatever. 15 Q. Sand, dust, whatever else fell on the floor 16 there? 17 A. Right. 18 Q. And it would just get all packed together? 19 A. Right. 20 Q. Okay. Now, the -- you mentioned that things 21 changed over time in the aroclor department. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036058 22 I don't want to walk through in great detail, 23 but can you kind of give me some of the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 84 FOSHEE & TURNER COURT REPORTERS 1 different changes over time? 2 A. Well, over time, there was a new control room 3 added upstairs adjacent to the still room. 4 There was a big -- two big solid chlorinators 5 added. 6 Q. Do you remember when they were added? 7 A. I couldn't tell you the year. 8 Q. Okay. Was that the expansion that was not 9 too long before the production shut down? 10 A. Probably. 11 Q. Okay. Where were they added, by the way? 12 A. Where were they added? 13 Q. Where were they added? 14 A. In relation to -- 15 Q. Yes, sir, to Exhibit Number 1. We've got the 16 old chlorinators. Where were the new ones 17 added? 18 A. They were added kindly to the blowing tanks. 19 More in relation to them. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036059 20 Q. Here's the blow tanks here. 21 A. They were more east of the blow tanks. 22 Q. Okay. Okay. 23 A. And then the building was extended on the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 85 FOSHEE & TURNER COURT REPORTERS 1 north end, and there was an elevator put in 2 for bringing up lime and drums and carrying 3 stuff down and so forth. 4 Q. So that helped y'all. Y'all didn't have to 5 haul those drums down the stairs anymore. 6 A. Also, there was a large still and receiver 7 added for the solids. 8 Q. Okay. What did those new chlorinators make? 9 Do you remember was it any particular 10 product? 11 A. It was 5060 and 5032. That's mainly what 12 they were used for. 13 Q. Are those the solid aroclor? 14 A. Right. 15 Q. Now, I also understand there was a flaking 16 and drumming area added; is that right? 17 A. It was -- there was a new one added down to OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036060 18 the end of the chemical warehouse. That was 19 called -- they named that aroclor packaging. 20 Q. Okay. And you actually worked there for a 21 little while? 22 A. Yes, sir. But they also did away with this 23 filter when they did this expansion. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 86 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. That filter we were talking about, the 2 box shaped one? 3 A. Yes, sir. 4 Q. Let's see. Yeah, here. 5 A. Here. 6 Q. Okay. 7 A. And added -- they call them porocell columns. 8 They were added north of the building. 9 Q. What did they do? They took the place of the 10 filters? 11 A. They took the place of the filters. And -- 12 Q. How did they work? 13 A. Well, you didn't have to change the material 14 in those but just very seldom. It was some 15 kind of pellets or something in there. And OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036061 16 they also added a tank farm, a new tank farm. 17 Q. To hold the liquid aroclors? 18 A. Right. And the solid. 19 Q. Okay. Was all of that part of the same 20 expansion? 21 A. All part of the same expansion. 22 Q. Between the time when you started and that 23 big expansion, were there any significant 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 87 FOSHEE & TURNER COURT REPORTERS 1 changes? 2 A. You mean in the way we operated or-- 3 Q. Well, yeah. I made that a broad question, 4 and I kind of intended it to be. 5 You walked me through the process 6 as it existed when you started. 7 A. Yes. 8 Q. And then we just now talked about the big 9 expansion -- 10 A. Right. 11 Q. -- in the later years. 12 A. (Witness nods head.) 13 Q. In between when you started and this big OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036062 14 expansion, were there any significant changes 15 in either the way you did things or new 16 equipment or new processes or anything like 17 that? 18 MR. COX: Solely in the aroclor 19 department? 20 MR. WRIGHT: Yeah. All I'm talking 21 about right now is the arocl or department, 22 which would include the muriatic acid 23 process. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 88 FOSHEE & TURNER COURT REPORTERS 1 MR. COX: Object to the form to the 2 extent that part of the time, I don't think 3 he was in that department. 4 MR. WRIGHT: I know. 5 Q. You can add to my question that you know 6 about. 7 A. The acid department was changed up probably 8 along the same period of time this new 9 expansion was added. It was completely 10 revamped. 11 Q. Okay. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036063 12 A. New storage tanks, new column. 13 Q. Okay. I'll ask you about that in just a 14 second. Other than that, which was about the 15 same time as the big expansion, any other 16 changes? 17 A. At some point, we started charging our 18 chlorinators from cars, from chlorine cars, 19 instead of the chlorine plant. 20 Q. Okay. Did that make any difference to you as 21 the operator? I mean, I assume the chlorine 22 came through the same pipes and everything? 23 A. (Witness nods head.) 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 89 FOSHEE & TURNER COURT REPORTERS 1 Q. It's just that now it's being hauled in, and 2 before it came from the chlorine plant; is 3 that fair? 4 A. That's fair. 5 Q. Any other changes? 6 A. Not that I can remember. 7 Q. Okay. Any equipment changes? For example, 8 did y'all ever get new pumps or new pipes or 9 any upgrade like that? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036064 10 A. Well, you know, it was an ongoing thing, 11 change pumps and pipe and so forth. 12 Q. I guess what I mean is: Did you get any new 13 style? 14 MR. COX: Other than routine 15 maintenance? 16 Q. (By Mr. Wright) Yeah. Other than routine 17 maintenance of what you already had, did you 18 ever get any new style of equipment,or was 19 it just new equipment of the same old style? 20 A. At some point, we got a new type seal on the 21 chiorinator pumps. 22 Q. Do you remember when that was? 23 A. No, sir, I don't. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 90 FOSHEE & TURNER COURT REPORTERS 1 Q. Would it have been in conjunction with the 2 big expansion we talked about? 3 A. Might have been before that. I couldn't say 4 for sure, but I think it was maybe. Had a 5 mechanical seal to put on the pumps. 6 Q. Okay. Rather than the old packing gland 7 stuff? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036065 8 A. Yes. 9 Q. Did that cut down on the leaking? 10 A. Yes, sir. 11 Q. A whole lot? 12 A. Well, yes, sir. The packing glands, they 13 were designed to leak. 14 Q. Right. 15 A. The others weren't. 16 Q. Okay. 17 A. But we had pans to catch the leaks. Of 18 course we still had the pans with the other 19 ones, but it cut down quite a bit, sure. 20 Q. Okay. From time to time, did aroclor either 21 get spilled or get poured into the ditch or 22 into the other sewers? 23 A. I'm sure it spilled from time to time. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 91 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. What were some of the sources of 2 larger spills? 3 MR. COX: Object to the form. 4 Q. (By Mr. Wright) The reason I ask you that, I 5 mean, I know the pumps dripped, and probably OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036066 6 from time to time the pipes dripped and 7 things like that. But did you have things 8 happen that caused larger spills than just 9 drips here and there, like a pipe breaking or 10 barrels spilling over, getting turned over or 11 something like that? 12 MR. COX: Same objection. 13 Q. (By Mr. Wright) You can answer. 14 A. Yes, sir, we did have occasional spills. 15 Q. What are some of the ones you remember? 16 A. I don't remember any specific incidents, but 17 I know from time to time you might run over a 18 blow tank. 19 There weren't any -- still talking 20 about the early years -- there weren't any 21 gages on them for level purposes.You had to 22 measure. 23 Q. So you might fill it too fill is what you're 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 92 FOSHEE & TURNER COURT REPORTERS 1 saying? 2 A. You might fill it too full, or with the air 3 blowing in there, it would -- had the OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036067 4 material rolling in there pretty good, and 5 sometimes it's hard to measure with a ruler 6 at night and so forth. 7 But anyway, occasionally you'd have 8 something like that, or occasionally they 9 might run a drum over, drumming out valve 10 stems. You'd have leaks around those from 11 time to time. 12 Q. Just more things like that? 13 A. Yes, sir. 14 Q. Okay. This may not be a good question, but 15 did you ever have bad batches for one reason 16 or another, batches that couldn't be used as 17 Monsanto product? 18 A. I don't remember any. 19 Q. Okay. 20 A. Usually you could blend it. 21 Q. That's what I was going to say. You can 22 always put it back into the process one place 23 or another, couldn't you? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 93 FOSHEE & TURNER COURT REPORTERS 1 A. Yes. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036068 2 Q. Did the chlorinators ever -- I mean other 3 than the pumps leaking that we've talked 4 about, did the chlorinators ever leak or 5 overrun or blow a pipe or things like that to 6 cause aroclor to spill out? 7 A. I can't say that it never happened, but it 8 didn't happen routinely. 9 Q. Okay. What kind of things like that do you 10 remember -- 11 MR. COX: Object to the form. 12 Q. (By Mr. Wright) -- in the chlorinator area? 13 Let me just ask it again. What 14 kind of larger spills in the chlorinator area 15 do you recall? 16 A. I don't really recall any large spills in the 17 chlorinator area. 18 Q. Now, you spent a little bit of time in the 19 chlorine plant? 20 A. Yes, sir. 21 Q. Let me go back. About a year or two as a 22 chief operator over there? 23 A. Yes, sir. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 94 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036069 1 Q. What -- I'm going to do the short version. 2 I'm not going to walk you through it like we 3 did the aroclor operation, but my 4 understanding is that there was a series of 5 long cells? 6 A. Yes, sir. 7 Q. Kind of like this? 8 A. Yes, sir. 9 Q. And my understanding there were about twenty 10 of them? 11 A. There was thirty-six. 12 Q. Thirty-six. Okay. And mercury ran through 13 the bottom, and the brine ran over the 14 mercury, and an electric charge was passed 15 down through it to create the chlorine gas? 16 A. DC currents. 17 Q. Okay. I'm sorry. Yeah, made chlorine gas. 18 A. Uh-huh (indicating yes). 19 Q. What water -- what waste water was generated 20 by that process, and what happened to it? 21 A. I can't say that there was. 22 Q. You don't remember a stream of waste water 23 coming off of that process? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 95 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036070 FOSHEE & TURNER COURT REPORTERS 1 A. No, sir. Most of that water went back to the 2 culminator. 3 Q. Okay. 4 A. I know there was water continuously covering 5 the mercury in the pump tanks and the ditches 6 on the ground floor, whatever, and all this 7 water -- 8 Q. I'm sorry? 9 A. All this water just went to the waste stream. 10 Q. To the sewers? 11 A. Uh-huh (indicating yes). 12 Q. Okay. Maybe I need to get you to draw that. 13 I didn't think I would, but we won't go into 14 great detail. But can you just draw the 15 general layout of the chlorine -- was it all 16 in the building? 17 A. Right. 18 Q. Draw the general layout of the chlorine 19 building. You don't have to draw the 20 individual cells. 21 A. It's just a cell room where all the cells 22 were. There's alot of equipment outside. 23 Q. Okay. Let's just draw some lines showing how OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036071 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 96 FOSHEE & TURNER COURT REPORTERS 1 the cells were situated. 2 A. (Witness complies.) 3 4 (Plaintiffs' Exhibit Number 5 was 5 marked for identification and 6 copy of same is attached 7 hereto.) 8 Q. Okay. We'll just know there were thirty-six 9 of them. Were they in two rows? 10 A. Right. 11 Q. Two rows of eighteen. And then you mentioned 12 some ditches in here? 13 A. This was on a wooden floor on this level-- 14 Q. Okay. 15 A. -- where the cells sit. 16 Q. Okay. 17 A. Underneath wasa concrete floor. 18 Q. So the cell sat on the second floor? 19 A. Right. 20 Q. Underneath the cells, there was a first level 21 that had a concrete floor. Let's do that. 22 Let's just write cell room in there. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036072 23 A. (Witness complies.) 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 97 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. And then here's the first floor. Well 2 go ahead, and I'll let you do that. 3 A. (Witness complies.) I don't remember exactly 4 where all the ditches were in relation to the 5 building, but I know there was one came down 6 the center. 7 8 (Plaintiffs' Exhibit Number 6 was 9 marked for identification and 10 copy of same is attached 11 hereto.) 12 Q. Okay. Did it run the whole length or just 13 part of it? 14 A. Yeah, pretty much the whole length. 15 Q. Okay. 16 A. And there was some came in from the side, but 17 I don't remember. 18 Q. So there were other ditches that came -- 19 A. The floors all sloped toward the center. 20 Q. Okay. What went into that? What went into OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036073 21 those ditches? 22 A. Well, it would be water, and there would be 23 some mercury carried over. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 98 FOSHEE & TURNER COURT REPORTERS 1 Q. Where did that mercury come from? 2 A. From the cells or from -- 3 Q. Leaking or dripping? 4 A. Well, yeah. Sometimes you'd have leaks or 5 drips or might just carry over with the water 6 sometimes. I don't know. 7 Q. By "carry over with the water," what do you 8 mean? 9 A. Well, you had water on the pump tanks that 10 pumped the mercury into the cells. 11 Q. Yeah. 12 A. Kept water on that. 13 Q. By "kept water on it," you mean just -- 14 A. Constant level- 15 Q. Mercury is heavier than water, so it's on the 16 bottom, and you kept water on top of it? 17 A. Right. And there was an overflow pipe off of 18 that. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036074 19 Q. Okay. So if that-- 20 A. Into this ditch. 21 Q. -- got too full for some reason -- or was 22 water continuously going into the tank? 23 A. Water was continuously going into the -- 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 99 FOSHEE & TURNER COURT REPORTERS 1 Q. And then flowing out? 2 A. Right. 3 Q. Why did you have to circulate the water? Did 4 the mercury get hot or something? I'm just 5 curious. 6 A. No, just to keep the mercury covered for 7 health purposes, I suppose. 8 Q. What I'm saying though is: Why couldn't you 9 just pour water in there and let it sit? 10 Where did the water have to go in and come 11 out is what I'm wondering? 12 A. Well, you'd pump some water off with the 13 mercury. As you pumped the mercury up into 14 the cells, some would go with it, so you had 15 to keep water going in there to keep it 16 covered. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036075 17 Q. Okay. And I guess so somebody didn't have to 18 stand there and add water all the time, it 19 was just a continuous -- you continually 20 pumped water in there, and then if the water 21 -- the water would come off the top? 22 A. Yeah. 23 Q. And into the drain system on the floor of the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 100 FOSHEE & TURNER COURT REPORTERS 1 building? 2 A. Yes, sir. 3 Q. Okay. And so sometimes mercury would spill 4 out of the top of the pump tank in the water 5 is what you're saying? 6 A. Through the overflow pipe. 7 Q. Okay. And then other times, mercury would 8 drip out of the cells which were above this 9 area? 10 A. Yes, sir. 11 Q. Okay. How else did the mercury get into the 12 drain system? 13 A. That would pretty well be it. Just from 14 leaks and carry over, over fill. If you over OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036076 15 fill it, put too much in the pump tank. 16 Q. Okay. How many pump tanks for the mercury 17 were there? 18 A. One for each. 19 Q. One for each cell? 20 A. For each cell. 21 Q. How big were the pump tanks for the mercury? 22 A. Probably about three, four feet in diameter, 23 but they weren't that deep. Maybe couple 2001 PARK PLACE,SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 101 FOSHEE & TURNER COURT REPORTERS 1 feet deep. 2 Q. Okay. By "deep," you mean from the bottom to 3 the top -- 4 A. Right. 5 Q. -- couple feet and three or four feet in 6 diameter? 7 A. Right. 8 Q. How much mercury would there be in the tanks? 9 A. I don't remember. I don't remember how many 10 flasks it would take to fill one up. I can't 11 say. I don't remember. 12 Q. Were they open with -- I mean, was it like a OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036077 13 pot that you sit on the top of your stove? 14 A. It had a lid on it. 15 Q. Had a lid. Okay. A metal lid? 16 A. Yes, sir. 17 Q. Did you ever have to add mercury? 18 A. Yes, sir. 19 Q. How did you add the mercury if you had to add 20 it? 21 A. We got it either from a flask and poured it 22 into there or transferred it from one pump 23 tank to another, if we didn't have that cell 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 102 FOSHEE & TURNER COURT REPORTERS 1 working at the time. 2 Q. Okay. How did you know -- since it was 3 covered, how did you know if it needed 4 mercury or not? 5 A. Well, you could tell if the cell was 6 surging. It had an end plate at the end 7 where the mercury came in, and you could see 8 before it went in under the cover to the 9 cell. You could tell if it had a good flow 10 or if it didn't have a good flow. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036078 11 Q. Okay. Are there any pictures that you're 12 aware of of either the mercury -- I mean the 13 chlorine operation or the aroclor operation? 14 A. Any pictures? 15 Q. Yeah. Photographs or movies or videos or 16 anything like that? 17 A. No, sir, I don't know of any. 18 Q. Okay. Let me write--was there a drain hole 19 here? 20 A. No, sir. 21 Q. Okay. Where did the ditch empty, down at the 22 end? 23 A. Came on out of the building. You had traps 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 103 FOSHEE & TURNER COURT REPORTERS 1 along too at various places. 2 Q. Yeah. 3 A. You had mercury traps. That sole purpose -- 4 stuff was expensive. 5 Q. Right. 6 A. And we tried to recover every bit of it we 7 could. 8 Q. Well -- OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036079 9 A. And we'd rob these traps occasionally to get 10 the mercury out of them. 11 Q. Okay. Did it go into a drain, or did it just 12 go on in a surface pit on down to the exit 13 from the plant? 14 MR. COX: Object to the form. You 15 can answer. 16 THE WITNESS: I don't remember. I 17 don't know j ust where -- 18 Q. (By Mr. Wright) Okay. I'm just going to 19 put- 20 A. I don't know where it went from here outside 21 the building. We had the traps in here, but 22 I don't know. Outside the building, I don't 23 know what part of sewer system it went into. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 104 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. I'm just going to put concrete 2 ditches. 3 A. These ditches were fiberglass. I think they 4 were fiberglass. 5 Q. Okay. Fiberglass ditches. 6 A. It was some material like that. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036080 7 Q. Okay. And then I'll just put to sewers. You 8 don't remember whether there were -- there 9 was only one cross ditch, or were there more 10 than one? 11 A. I think there was more than one. 12 Q. Okay. Any feel for how many? 13 A. I know there was one. 14 Q. Okay. 15 A. And possibly more. Quite sure there were 16 more, but I don't know how many. 17 Q. Okay. Now, is down here where all the 18 mercury vats and pumps were? 19 A. Yes, sir. 20 Q. Okay. So there would be thirty-six -- 21 A. There were more in here. 22 Q. Okay. Closer to the ditches? 23 A. Uh-huh (indicating yes). 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 105 FOSHEE & TURNER COURT REPORTERS 1 Q. So there would be thirty-six of these circles 2 that I'm drawing here? 3 A. Yes, sir. 4 Q. Okay. I'm just going to put "M" in there to OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036081 5 stand for mercury. And then thirty-six 6 cells. Were there normally thirty-six cells 7 working? 8 A. No, sir, never. I don't remember ever having 9 all thirty-six going at the same time the 10 same time. 11 Q. Was there an average number that you would 12 have going when you were in full operation? 13 A. There was not--there was not an average 14 that we were required to keep going because 15 you constantly had repairs on them. 16 We had a crew on day shift that did 17 nothing but work on cells. They were always 18 some of the cells down. 19 Q. Okay. By the way, was there a continuous 20 flow of water in these ditches? 21 A. Pretty much. 22 Q. Okay. Now, you went to the landfill a couple 23 times, you said? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 106 FOSHEE & TURNER COURT REPORTERS 1 A. Not in early years, I didn't. 2 MR. COX: You said you'd carried OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036082 3 material up to the landfill, I think, was the 4 answer to the question. 5 MR. WRIGHT: Yeah, that's what I 6 thought. 7 THE WITNESS: I did after I went to 8 the shipping. 9 Q. (By Mr. Wright) Okay. And didn't go to 10 shipping until '74 or thereabouts? 11 A. Yes, sir. 12 Q. Okay. Tell me about taking stuff up to the 13 landfill. First of all, how often did you do 14 it? 15 A. Well, we had somebody that did it every day, 16 carried paper, just, you know,general type 17 trash. Of course usually the same man was 18 assigned to that. Might go once a month. 19 Q. You personally? 20 A. Yes, sir. 21 Q. Okay. When you went to the landfill --1 22 guess what I'm asking is: Just describe the 23 process to me if you would. I mean, did you 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 107 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036083 1 have a big truck, or did you have a 2 hand cart, or how did it -- 3 A. It was a big truck. It was a flat stake 4 truck, stake bed truck. We would load drums 5 on and carry to the landfill. 6 Q. How did the drums get loaded on the truck? 7 A. We'd load them with a forklift. One man 8 would put them up to the back of the truck 9 with a forklift, and we'd roll them off then, 10 just roll them off by hand over into the 11 truck, to the bed of the truck. 12 Q. Okay. How many trucks did the shipping 13 department have that carried stuff to the 14 landfill? 15 A. To start with, they only had the two. One 16 carried the dumpsters, paper skips and so 17 forth, and they had the stake truck. 18 Maintenance also had a tractor and 19 trailer. They would carry pipe and so forth. 20 Q. To the landfill? 21 A. To the landfill. 22 Q. Was the TP incinerator there when you were 23 going to the landfill? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 108 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036084 FOSHEE & TURNER COURT REPORTERS 1 A. Yes, sir. 2 Q. Did you take stuff to the TP incinerator? 3 A. It wasn't in use when I -- it was still 4 there, but it wasn't in use. 5 Q. Do you know when it was used? Let me ask it 6 this way: How long had it been out of use to 7 the best of your knowledge when you started 8 going up there in '74? 9 A. Not long. 10 Q. Okay. Was it old? 11 A. I'm not sure just what the age was of it. It 12 wasn't very -- real old. 13 Q. Let me ask it this way, and you may not know 14 the answer, but was it there when you came in 15 '62? 16 A. No, sir. 17 Q. That TP incinerator was not there? 18 A. No, sir. 19 Q. About when did it get put in? 20 A. I'm not sure. 21 Q. Let me ask it this way and it might stimulate 22 your memory: Was it while you were still an 23 aroclor operator? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036085 1-800-888-DEPO 109 FOSHEE & TURNER COURT REPORTERS 1 A. Well, I didn't really know when it was put 2 in. 3 Q. Okay. 4 A. Because I didn't, you know, I didn't go up 5 there during that period of time. 6 Q. How do you know it wasn't there in '62, or 7 why do you think it wasn't there in '62? 8 A. Well, just from, you know, from what people 9 said. I'd hear them talk about the TP, but I 10 never did -- 11 Q. Who did you hear talk about the TP? 12 A. Just different operators or different -- 13 Q. What kind of operators? 14 A. Shipping, folks from shipping. 15 Q. Okay. So even when you were not in the 16 shipping department, you'd talk to the 17 shipping guys from time to time? 18 A. Yes, sir. 19 Q. And they'd talk about the TP incinerator? 20 A. (Witness nods head.) 21 MR. COX: You need to answer out 22 loud. 23 THE WITNESS: Yes, sir. I'm sorry. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036086 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 110 FOSHEE & TURNER COURT REPORTERS 1 Q. (By Mr. Wright) What kind of things did you 2 hear about the TP? 3 A. Well, I know they put the fiber drums or 4 paper drums and wood pallets and stuff like 5 that in there and burned them. And I don't 6 know. That's about it. 7 That's all I ever heard about it. 8 You know, just carried a load and put in the 9 TP and burn whatever. 10 Q. What things did you hear them talk about 11 putting in the TP? 12 A. Just what I said, the pallets, wooden pallets 13 or fiber drums, paper drums. 14 Q. What do you mean by fiber drums? 15 A. Well, they were paper. That's what they 16 called them, fiber drums, but they were 17 actually cardboard drums. 18 Q. Heavy cardboard? 19 A. Right. 20 Q. Well, what was in the fiber drums? 21 A. For the most part, it would probably have OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036087 22 been drums PNP had been in. 23 Q. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 111 FOSHEE & TURNER COURT REPORTERS 1 A. They used -- before the PNP department was 2 constructed, they used it strictly from drums 3 from another plant. 4 Q. So that's how it came to Anniston was in 5 these cardboard drums or fiber drums? 6 A. Right. 7 Q. Okay. What else would be in the fiber drums 8 or would have been in the fiber drums? 9 A. I don't know of anything else. 10 Q. Did they use the fiber drums for trash cans 11 or waste cans or things like that? 12 A. No, sir, I don't think so. I can't say that 13 nobody ever did,but it wasn't a practice to 14 use them. 15 Q. Were those fiber drums the drums that you 16 were talking about that you'd carry down the 17 stairs? 18 A. No, sir. 19 Q. What kind of drums were those? I'm still OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036088 20 unclear about that. 21 A. They were a light weight metal drum, a thin 22 metal. The term that was always used is the 23 caustic drums. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 112 FOSHEE & TURNER COURT REPORTERS 1 I don't know where that came from 2 or how they arrived at that name, but that 3 was what -- they were just a very thin gauge 4 drum. 5 Q. What else did you hear about the TP or do you 6 remember hearing about the TP? 7 A. Well, the only thing that I heard was the 8 reason they quit using it was because they 9 got it too hot. They got -- damaged the TP. 10 That's the only thing I ever heard. 11 Q. Do you remember specifically who you heard 12 talking about the TP? 13 A. No, sir, I don't remember any names 14 specifically, just some of the people that 15 worked in shipping. 16 Q. That would have been shipping's operation; 17 right? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036089 18 A. Right. 19 Q. I interrupted you. You were telling me about 20 how the landfill operation worked when you 21 were doing it. You would load up either the 22 stake truck, or you said there was another 23 truck that hauled dumpsters? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 113 FOSHEE & TURNER COURT REPORTERS 1 A. Yes, sir. 2 Q. How many dumpsters -- did it actually -- I 3 mean, did you lift the dumpster up onto the 4 truck -- 5 A. Yes, sir. 6 Q. -- and then drive the dumpster over there to 7 the landfill? And how did you empty the 8 dumpster? 9 A. It had chains on it. The bottom chain would 10 catch. When you let it down, the bottom 11 would open up and drop it out the bottom. 12 Q. Okay. How many pits were there when you were 13 going up there? Was there just one in 14 operation at any one time? 15 MR. COX: Talking cells? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036090 16 MR. WRIGHT: Pits, yeah. 17 THE WITNESS: Well, we had a 18 different place for paper, to put the skips 19 in, a different place than that and -- 20 Q. (By Mr. Wright) What's a skip? I'm sorry. 21 A. The paper. The ones we carried with the 22 dumpster. 23 Q. Okay. So anything that went into the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 114 FOSHEE & TURNER COURT REPORTERS 1 dumpster went to one place? 2 A. And also the cardboard drums would go to that 3 same place. 4 Q. Okay. 5 A. You'd take those on the stake truck, but they 6 would go to the same place you put the paper. 7 Q. Okay. What went some place else then? 8 A. Well, you'd have different -- from the rest 9 of the plant, if you had something from niran 10 or something, it would go ina different 11 area. 12 Q. Were there only two areas during those years? 13 A. No, it would change from time to time, you OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036091 14 know. Place where you dump would change. It 15 was always in the same general area, but, you 16 know, they'd close that one and open another 17 one. 18 Q. Who ran that? 19 A. Who actually did the work? Is that what 20 you're asking me? 21 Q. Well, who was in charge of it? Let me start 22 there. Who was in charge of the landfill 23 operations? I mean who was making the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 115 FOSHEE & TURNER COURT REPORTERS 1 decisions about dump here or don't dump 2 there? 3 A. Well, I know at one time Mr. Taffee was. 4 Q. Okay. Anybody else you can think of? 5 A. That -- he's the main one that I know. 6 Q. Okay. Is there anybody else that worked over 7 there full time? 8 A. No, sir, not that I know of. None of our 9 people. 10 Q. If you were me and you wanted to talk to 11 somebody who knew the most about the landfill OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036092 12 operations in the '60s and '70s, who would 13 you talk to? 14 A. Mr. Taffee. 15 Q. If I couldn't talk to him, who should I talk 16 to? 17 A. Well, the man, Mr. McGinnis, was the 18 contractor that did the work. 19 Q. Okay. He was not a Monsanto employee? 20 A. No, sir. 21 Q. Is he still around? 22 A. I don't know. 23 Q. Do you know his first name? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 116 FOSHEE & TURNER COURT REPORTERS 1 A. No, sir, I can't think of it offhand. 2 Q. What did he do? 3 A. He ran a company just down the road from the 4 plant. I think it was Anniston Concrete and 5 Asphalt or something like that. Had heavy 6 machinery. 7 Q. And so he had his people up there running the 8 bulldozers, I guess? 9 A. Yes. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036093 10 Q. Did he do that for a long time? 11 A. Yes, sir. 12 Q. The whole time you were there? 13 A. The whole time -- as far as I know, the whole 14 time that the landfill was in operation. 15 Q. Okay. 16 A. There's some other people worked on it in 17 recent years, but -- 18 Q. Right. Right. I'm talking about -- 19 A. To my knowledge, he was. 20 Q. Okay. Is there anybody from his company that 21 you knew or you know their names that were up 22 there a lot? 23 A. No, sir. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 117 FOSHEE & TURNER COURT REPORTERS 1 Q. Okay. When did you first hear of PCB 2 contamination off of plant property? 3 A. I couldn't say for sure. It was later on, 4 much later. 5 Q. Like'80s or'90s? 6 A. No, sir. It was in -- not long before we 7 ceased operation of liquid aroclor. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036094 8 Q. What did you hear about PCB contamination 9 being off of plant property? 10 A. The main thing that I remember was the-11 environmental concern was that it was -- made 12 egg shells soft, the birds or something to 13 that nature. 14 Q. I guess what I'm asking is: When did you 15 hear -- or not when because we talked about 16 that -- but what did you hear about PCBs 17 being found outside of the Anniston plant 18 boundaries? 19 A. Well, I suppose it was in that same time 20 frame because it was all tied together, you 21 know. About what theeffects were. 22 Q. Okay. I was asking you about what you heard 23 about the PCBs beingoff the Anniston plant 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 118 FOSHEE & TURNER COURT REPORTERS 1 property. For example, did you hear where 2 they were finding PCBs off of the plant 3 property? 4 A. No, sir. The -- I guess the first thing I 5 heard about was maybe Choccolocco Creek or OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036095 6 something. That was first talk that I heard 7 of it. 8 Q. Do you remember when that was that you heard 9 about PCBs being in Choccolocco Creek? 10 A. No, sir, I don't. 11 Q. Was it after the plant shut down? 12 A. Probably. 13 Q. Okay. Before the plant shut down, did you 14 hear about PCBs being found any place 15 downstream of the Monsanto plant or outside 16 of the Monsanto plant boundaries? 17 A. I can't say. I can't say if I did or not. 18 Q. Okay. For example, one thing -- one of the 19 things that makes me ask this question is: 20 I've seen memos where some people were sent 21 out to walk the drainage ditch and see how 22 far they could see aroclors in the drainage 23 ditch downstream from the plant. Did you 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 119 FOSHEE & TURNER COURT REPORTERS 1 ever hear about that? 2 A. No, sir. We weren't advised on a lot of that 3 kind of stuff. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036096 4 Q. Okay. 5 A. The only thing we did was we sampled the 6 stream down to the fence, but we always did 7 that. 8 Q. How did you sample the -- by "the stream," 9 you mean the drainage ditch that went on out? 10 A. Limestone bed. At different points, various 11 points. 12 Q. How did you sample that? 13 A. In glass bottles. 14 Q. That was part of the operator's 15 responsibility? 16 A. Yes, sir. 17 Q. When did that start? 18 A. On the day shift. It was that way when I 19 started work there. 20 Q. In'62? 21 A. Yes, sir. 22 Q. What were you -- what did you do with the 23 samples when you collected them? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 120 FOSHEE & TURNER COURT REPORTERS 1 A. Carried them to the lab. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036097 2 Q. Do you know what they tested for? 3 A. No, sir. 4 Q. Did you ever get any results back from the 5 lab? 6 A. No, sir. 7 Q. Did the process stay the same? By "the 8 process," I mean the sample collecting 9 process stay the same from when you got there 10 to when the plant shut down? 11 Do you understand what I'm 12 asking? That's kind of a bad question. 13 Basically, I'm just asking you - 14 you described -- you said when you started 15 there, it was the operator's responsible to 16 collect samples every day? 17 A. Yes, sir. 18 Q. Did that stay the same until the plant shut 19 down, or did it change in some way over the 20 years? 21 A. We caught the samples on up until we shut the 22 plant down. 23 Q. Okay. Did you do it with the same frequency 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 121 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036098 1 and in the same places generally, or did that 2 change? 3 A. Things were always changing. But to say that 4 we caught the samples in the exact same spot 5 every day, I couldn't say that. 6 But the limestone pit might change. 7 They may change and put an extra one in or 8 might catch an extra sample. 9 At some point, we started taking 10 samples to a trailer. It was situated behind 11 the lab. 12 Q. Do you remember when that was? 13 A. No, sir, I don't. 14 Q. Was it before the plant shut down? 15 A. Yes, sir. 16 Q. Do you remember how long before? 17 A. No, sir, I don't. 18 Q. Any other way the sampling procedure changed 19 over the years? 20 A. No, sir. 21 Q. Did you sample one time per shift or one time 22 per day? 23 A. This was -- pretty sure it was just on the 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 122 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036099 FOSHEE & TURNER COURT REPORTERS 1 day shift. 2 Q. One time though? 3 A. Yes, sir. 4 Q. Okay. 5 A. Now, the lab did some sampling too, but now I 6 couldn't -- I don't know what their routine 7 was. They would do sampling at times. 8 Q. But your sampling at least always stopped at 9 the fence? 10 A. Yes, sir. 11 Q. Did you ever talk to any of the people in the 12 neighborhood there around the plant? 13 A. No, sir. 14 Q. Where did you live back in those days? 15 A. Pretty much where I live now, which is about 16 eight miles north of the plant. 17 Q. We kind of fell off into the sampling 18 business when I was asking you about what you 19 heard about PCBs being located off of the 20 plant property. And you mentioned you heard 21 something about them being in Choccolocco 22 Creek, but you think that was probably after 23 the plant shut down? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036100 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 123 FOSHEE & TURNER COURT REPORTERS 1 A. I think it was probably before. 2 Q Oh, okay. 3 A. I'm not sure. 4 Q. Okay. Who did you hear that from, do you 5 remember? 6 A. I don't remember. It was just -- 7 Q. -- talk around the plant? 8 A. Talking around the plant, I suppose. 9 Q. What else did you hear other than that one 10 particular thing? 11 MR. COX: Object to the form. 12 Q (By Mr. Wright) About PCBs being off the 13 plant property? 14 A. That's about it. 15 Q . When did you hear the plant was going to shut 16 down? 17 A. They was always rumors. That went on from 18 the time I went there till I left. 19 MR. COX: He's talking specifically 20 about the aroclor plant. 21 Q . (By Mr. Wright) Yeah, the aroclor plant is 22 what I mean. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036101 23 A. It was about the time that it shut down. Not 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 124 FOSHEE & TURNER COURT REPORTERS 1 long before. 2 Q. Who did you hear it from? 3 A. I don't remember if it was a plant meeting or 4 what. Could have been -- could have been a 5 plant meeting informed. 6 Q. What did you hear about the reasons for why 7 it was shutting down? 8 MR. COX: I don't mean to 9 interject, but -- 10 MR. WRIGHT: Oh yes, you do, Buddy. 11 MR. COX: I do mean to interject, 12 but I don't mean to interrupt. I don't mean 13 to be intrusive. 14 Are you talking about the shutdown 15 of the liquid aroclors or the solid aroclors 16 or both because there's a timing sequence in 17 there? I just want to make sure. I just 18 want to make sure that he's talking about -- 19 MR. WRIGHT: I understand. 20 MR. COX: -- the same thing you're OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036102 21 talking about. 22 MR. WRIGHT: I'm talking about the 23 shutdown of all aroclor operations. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 125 FOSHEE & TURNER COURT REPORTERS 1 Q. But if you heard about them at different 2 times and if you heard different reasons, 3 then go ahead and tell me that, but -- 4 A. It was at different times we heard about it. 5 Q. Okay. What did you hear first then and when? 6 A. I don't remember when, and I don't remember 7 specifically what it was, but it was just 8 something to the effect, you know, that there 9 was an environmental concern. 10 Q. Okay. Was that in relation to-- 11 A. -- to the liquid aroclor. 12 Q. How long did the liquid aroclors shut down 13 before the solid aroclors shut down? 14 A. Maybe a year. 15 Q. Now, when you heard the plant was going to be 16 shutdown completely, what did you hear about 17 the reasons for that occurring? 18 A. I don't remember -- recall anything other OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036103 19 than they said they were going to shut it 20 down. If it was cost or what. Just the one 21 product line there. 22 Q. When the liquid shut down, did any of the 23 chlorinators go out of use? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 126 FOSHEE & TURNER COURT REPORTERS 1 A. Yes, sir. 2 Q. Which ones? 3 A. One through eight. 4 Q. And what was left operating? 5 A. Nine and ten. 6 Q. The big new ones? 7 A. Right. 8 Q. Did the process change any other way? 9 A. Well, there was a different process for the 10 liquid and for the solid. 11 Q. Yeah, I -- that was a bad question. Did the 12 process for the solids change any way before 13 they -- before the plant was shut down? 14 A. I don't remember. I know one time they tried 15 making a different product with it, with the 16 caustic soda, but as far as the process, I OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036104 17 mean, that was a process change, but it 18 didn't work out, didn't sell the product or 19 whatever. 20 Q. Was that the 1016? 21 A. I don't remember what they called it. 22 Q. Okay. After the aroclor plant shut down, did 23 they continue sampling the drainage ditch? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 127 FOSHEE & TURNER COURT REPORTERS 1 A. Yes, sir. 2 Q. Again, on an everydaybasis? 3 A. Yes, sir. 4 Q. Who was responsiblefor it? 5 A. The lab. 6 Q. So the lab -- after the aroclor plant shut 7 down, the lab would send its own person out 8 there every day to sample? 9 A. Yes, sir. 10 Q. As far as you know, did they sample in 11 basically the same places you'd been sampling 12 before? 13 A. I couldn't say. 14 Q. Okay. All right. Here's the last stage. I OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036105 15 want to walk through the other people that 16 worked in the aroclor department-- 17 A. Okay. 18 Q. -- and get you to give me their name and 19 whether they're still alive or not to the 20 best of your knowledge -- you may not -- if 21 you don't know, say I don't know if he's 22 still alive or not -- whether they're still 23 in the area, and if they've died, if you know 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 128 FOSHEE & TURNER COURT REPORTERS 1 what they died from, for example, a heart 2 attack or got run over by a truck or cancer 3 or whatever, let me know. Okay? 4 A. Okay. 5 Q. So let's walk through them. And you 6 mentioned a couple of guys. 7 A. There were a lot of them over the years. 8 Q. I know. 9 A. And all these were intertwined between the 10 two departments. Some would work sometimes 11 here and, you know -- 12 Q. By "the two departments," you mean the OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036106 13 biphenyl? 14 A. Biphenyl/Aroclor. 15 Q. Okay. 16 A. It was just Biphenyl slash Aroclor at the 17 time. 18 Q. Yeah. 19 A. But you want the ones mainly that worked in 20 the aroclor; is that what you want? 21 Q. Yeah, and if there's somebody that worked in 22 both places, just tell me. 23 A. Okay. Dicky Walker, you mentioned him. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 129 FOSHEE & TURNER COURT REPORTERS 1 Q. Right. 2 A. He primarily worked in the still room. 3 Willie Key, he's deceased. 4 Q. How do you spell his name? 5 A. K-e-y was his last name. 6 Q. Okay. Do you know about when he died? 7 A. He's been dead several years. I don't know. 8 Q. Any idea what he died from? 9 A. No, sir. I know he had a heart bypass at one 10 time. OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036107 11 Q. Okay. 12 A. These--I'm trying to remember the ones that 13 were there when I first went there, and then 14 I'll come forward. 15 Q. Yeah. Any way that's convenient for you. 16 A. And then a man by the name of Don Wilson. 17 Q. Okay. 18 A. He worked in the still room. I have no idea 19 if he's still alive or not. I haven't seen 20 him in years. 21 Q. Okay. 22 A. And then a man by the name of Ed Adams. 23 Q. Do you know anything about him? 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 130 FOSHEE & TURNER COURT REPORTERS 1 A. He's dead. I don't know the cause of death. 2 Q. Dead a long time ago? 3 A. Most of these people were pretty elderly when 4 I went to work there. 5 Q. I understand. 6 A. Or I thought they were, but I don't think so 7 anymore. 8 Q. I understand. I understand that phenomena OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036108 9 too. 10 A. Those were your main four still operators 11 when I went there. 12 Q. Okay. 13 A. Then you had Bill Lloyd that ran 14 chlorinators. Dutch Amos -- Bill Lloyd is 15 still alive. Dutch Amos; he's deceased. 16 Dutch retired first year I was 17 there, so that tells you about how -- Bill 18 Cambron; he's still alive. 19 Q. Okay. I'll tell you what. Let me let you do 20 this. Why don't we go off the record -- 21 A. Okay. 22 Q. -- and let you just continue that list there, 23 and then after you've got your list, then 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 131 FOSHEE & TURNER COURT REPORTERS 1 we'll go back on the record and just read the 2 names, and that will -- I think that -- 3 MR. COX: -- might speed things up. 4 Q. (By Mr. Wright) Might speed things up and 5 might be easier to you. 6 (Short recess.) OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036109 7 8 (Plaintiffs' Exhibit Number 7 was 9 marked for identification and 10 copy of same is attached 11 hereto.) 12 Q. (By Mr. Wright) Okay. I'm going to label 13 this "Former Aroclor Department Workers" with 14 the understanding that some or maybe even all 15 of these people worked in the biphenyl 16 department as wellas the aroclor department; 17 is that true? 18 A. Well, these were mainly -- they were mainly 19 aroclor workers. 20 Q. Okay. 21 A. The chiefs -- some of chiefs I've got down, 22 and the laborers they worked, and I've got an 23 "L" by their names, the ones I remembered on 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 132 FOSHEE & TURNER COURT REPORTERS 1 the laborers. 2 Q. Right. Are the only ones that are dead the 3 ones that you put "Ds" by thatyou know to be 4 dead? OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036110 5 A. So far as I know. 6 Q. Would you put question marks by the ones that 7 you don't know whether they're still alive or 8 not? 9 A. Well, I think they pretty well -- 10 Q. Are you pretty sure about everybody else? 11 A. I'm pretty sure about the rest of them. 12 Q. Okay. 13 A. Unless they've just died lately. 14 Q. Would you -- let's put a star or something by 15 the ones that don't live in this area. And 16 by "this area," I don't mean just Anniston, 17 but I mean somewhere in the nearby area. 18 MR. COX: Are you aware of any guys 19 that are still living on that list living out 20 of the state? 21 THE WITNESS: No. I think most of 22 them are fairly well local. 23 Q. (By Mr. Wright) Still in the area. Okay. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 133 FOSHEE & TURNER COURT REPORTERS 1 Let me ask you this then: Are there any that 2 aren't in Calhoun County that you can think OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036111 3 of? 4 A. I don't think Nolen Sims is. 5 Q. Okay. I've already deposed him, so I'm not 6 going to worry about him. Dicky Walker I 7 know lives about thirty miles away. 8 A. Yeah, he does. Charles Chatman lives in 9 Talladega County, but he's still working. 10 He's still working at the plant. 11 Q. Okay. 12 A. Jim Price is not in Calhoun County. I think 13 he's in Talladega County. 14 Q. Is he near a certain town? 15 A. I'm not sure, but he was working with 16 contractors out there. 17 Q. On the cleanup? 18 A. Maintenance contractors in the plant. He was 19 working with -- I can't think of his name 20 now -- McCloud. 21 Q. What are they doing? 22 A. They do projects and so forth. They're 23 contracting. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 134 FOSHEE & TURNER COURT REPORTERS OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036112 1 Q. He's still with them? 2 A. He was. 3 Q. Okay. 4 MR. COX: Is that the electrical 5 contractor? 6 THE WITNESS: (Witness nods head.) 7 MR. COX: McCloud's the electrical 8 contractor for the plant. 9 THE WITNESS: They do electrical 10 and also mechanical. 11 Q. (By Mr. Wright) I've got another question 12 that I just forgot. 13 A. Okay. 14 Q. Which ones -- let's mark which ones are still 15 working at the plant, and let's just put a 16 "W" over here on this other side. Here, I'm 17 going to circle all these and just put a "W" 18 next to the number if they're still working 19 at the plant. 20 A. (Witness complies.) 21 Q. No, I'm sorry. Oh, you're fixing the name. 22 Let me give you that pen because I think it 23 will show up better. 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO 135 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036113 FOSHEE & TURNER COURT REPORTERS 1 A. (Witness complies.) 2 Q. Okay. Mr. Hughes, thank you very much. 3 A. You're welcome. 4 Q. I'm amazed at your memory after all these 5 years, and I really appreciate the time. 6 A. Don't talk to my wife. She says I forget 7 things. 8 9 (Deposition concluded at 4:50 p.m.) 10 FURTHER THE DEPONENT SAITH NOT. 11 12 13 14 15 16 17 18 19 20 21 22 23 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036114 1-800-888-DEPO 136 FOSHEE & TURNER COURT REPORTERS 1 CERTIFICATE 2 3 STATE OF ALABAMA ) 4 CALHOUN COUNTY ) 5 6 I HEREBY CERTIFY that the above and 7 foregoing transcript was taken down by me in 8 stenotype, and the questions and answers thereto 9 were transcribed by means of computer-aided 10 transcription, and that the foregoing represents 11 a true and correct transcript of the testimony 12 given by said witness. 13 I FURTHER CERTIFY that I am neither 14 of counsel, nor of any relation to the parties to 15 the action, nor am I anywise interested in the 16 result of said cause. 17 18 19 20 21 TAMMY R. JENNINGS GREGORY Notary Public, State of Alabama 22 MY COMMISSION EXPIRES: 9-12-2001 23 OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036115 2001 PARK PLACE, SUITE 220 BIRMINGHAM, ALABAMA 35203 1-800-888-DEPO OWENS 05-15-1988 Hughes, Bill.Vl.txt[8/22/2017 3:49:38 PM] HARTOLDMON0036116