Document x1NeKyL9Gad9LKDDnRaRnX36

Page 1 Page 3 1 In The Superior Court 2 Of The State Of Delaware 3 In And For New Castle County 1 2 Witness CONTENTS Examination 4 ---------------------------------- -x 5 Monsanto Company, 6 Plaintiff, : : 7 : Civil Action Number 3 James R. Savage 4 by Mr. Brock 5 4 4 8 v. : 88c-ja-118-1-cv 9 Aetna Casualty & Surety Company, : Non-arbitration 10 et al. , : Case 6 EXHIBITS 7 Savage Deposition Number Identified 11 Defendants. : 8 Exhibit 1 - Aroclor document 49 12 ----------------------------------x 13 Deposition Of James R. Savage 14 Wilmington, Delaware 9 Exhibit 2 - Standard manufacturing process 10 Exhibit 3 - Map 87 50 15 Tuesday, May 18, 1993 16 Deposition of James R. Savage, called for examination 17 pursuant to notice of deposition, at the law offices of 18 Smith, Katzenstein and Furlow, 1220 Market Street, Fifth 11 Exhibits 4 through 29 - Group of documents 117 12 Exhibits 30 through 33 - Correspondence 187 13 Exhibit 34 - Memorandum 194 19 Floor, at 10: 00 a. m. before Kristine A. O'connor, a Notary 20 Public within and for the District of Columbia, when were 21 present on behalf of the respective parties: 14 Exhibit35-April 1971 memorandum 15 Exhibit 36 - June 1971 memorandum 196 197 22 -- continued -- 16 Exhibits 37 and 38 - 9/1/71 and 9/9/71 memoranda 198 Page 2 Page 4 1 Appearances: James F. Burnett, Esq. 1 PROCEEDINGS 2 Whereupon, 2 Potter, Anderson & Corroon 3 James R. Savage 3 350 Delaware Trust Building 4 was called as a witness and, having first been duly sworn, 5 was examined and testified as follows: 4 902 Market Street 5 Wilmington, Delaware 19801 6 Examination 7 By Mr. Brock: 8 Q Good morning, Mr. Savage. My name is Stephen 6 On behalf of Plaintiff Monsanto Company. 7 Stephen F. Brock, Esq. 9 Brock. I represent Liberty Mutual Insurance Company in 10 this lawsuit between Monsanto and a number of its insurance 11 companies relating to the claim of pollution at some of 8 Manta and Welge 12 Monsanto's plants. 13 The deposition here today is going to relate to 9 One Commerce Square 14 primarily three of Monsanto's plants: Krummrich, the plant 10 Thirty-seventh Floor 15 in Illinois, the plant in Anniston, Alabama and the plant 16 in Nitro, West Virginia. 11 2005 Market Street 17 Have you ever testified in a deposition before? 18 A Yes. 12 Philadelphia, Pennsylvania 19103 19 Q How many times? 13 On behalf of Liberty Mutual 14 Insurance Company. 20 A I think three times. 21 Q How long ago was the first time? 22 A Probably four or five years, maybe longer. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 1 - 4 FIARTOLDMONO010071 Page 5 Page 7 1 Q Can you tell me the context of that deposition? 1 A 1 don't know. 2 A It was in connection with lawsuits related to Pcb 2 Q You've never been called to testify in court, 1 3 problems. 3 take it? 4 Q Was that a lawsuit or lawsuits? I'm sorry, the 4 A That's right. 5 first one -- 5 Q When was the next time that you were deposed? 6 A 1 think the first one was a single lawsuit, but 1 6 A There was another one shortly after that, and 1 7 don't remember much about it. 7 don't remember anything about it at all. 8 Q Did that relate to the operations at a particular 8 Q Was that in connection with your employment with 9 Monsanto plant? 9 Monsanto? 10 A No, it was connected to customers. 10 A Yes. 11 Q What was the nature of the complaint in that 11 Q Did it relate to Pcbs? 12 case? 12 A Yes. 13 A If 1 remember correctly, the first one was a case 13 Q Do you recall who the claimant was? 14 generally known as Johnson Motors which related to some 14 A No, but the subject matter was similar to the one 15 pollution problems at their plant. 15 at Johnson Motors, so they kind of run together. 1 don't 16 Q Where was Johnson Motors located? 16 remember. 17 A Either in southern Wisconsin or northern 17 Q Do you know what court that case was pending in? 18 Illinois, someplace between Chicago and Milwaukee. 18 A No. 19 Q How were they claiming that Monsanto was 19 Q When was the third time that you were deposed? 20 responsible for the pollution at their plant, to your 20 A The third time was within the last year or two 21 understanding? 21 and that was another hydraulic fluid case. 22 A 1 don't remember that. We sold them products 22 Q Do you know who the claimant was in that case? Page 6 Page 8 1 which contained Pcbs. 1 A The claimant was a pipeline company and that 2 Q Do you know what the products were? 2 case - 1 don't remember the name of the pipeline company. 3 A They were hydraulic fluids. 3 Q Do you know where they were located? 4 Q Do you know what plants, plant or plants those 4 A Somewhere in the west. 5 products came from? 5 Q Do you know what the nature of the claims were in 6 A Possibly any of three. These hydraulic fluids 6 that case? 7 were blended at Anniston, a small amount at Krummrich and 7 A Some fluid had entered the pipeline system and 8 at the Queeny plant at St. Louis. 8 when it was discovered, it was expensive to clean it out. 9 Q What was the nature of your involvement in that 9 Q When you say that company was a pipeline company, 10 lawsuit? 10 what did that company do? 11 A 1 was involved in the manufacturing. 11 A They were involved in the transportation of 12 Q Did your deposition relate to -- when you say you 12 natural gas. 13 were involved in manufacturing, was that at a particular 13 Q What was your involvement in that lawsuit? 14 plant? 14 A Well, the questions were related to my time as 15 A 1 was in manufacturing at each of those plants, 15 manufacturing manager when they were our customer. 16 but 1 was also manufacturing manager at the general office 16 Q When you say" a customer," a customer of 17 for the business group that sold those products. 17 hydraulic fluids? 18 Q Do you recall what that business group was? 18 A Yeah, the product was a part of our hydraulic 19 A That was called the specialty products business 19 fluid family but was actually a lubricant. It was called 20 group. It had some other names, but most of the time it 20 Turbinol. 21 was called specialty products business group. 21 Q Do you know how to spell that? 22 Q Has that lawsuit been resolved to your knowledge? 22 A T-u-r-b-i-n-o-l. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 5 - 8 HARTOLDMONO010072 Page 9 Page 11 1 Q And that was the part of what family, I'm sorry? 1 A No. 2 A Part of the hydraulic fluid family. 2 Q Have you ever taken any courses relating to 3 Q Was that pipeline company claiming some sort of 3 insurance matters? 4 fault on the part of Monsanto by virtue of the fact that 4 A No. 5 the fluid had entered the pipeline system? 5 Q Have you ever taken any courses relating to the 6 A The fact that it entered the pipeline system was 6 toxicity or harmful nature of any chemicals, a course that 7 related to some mechanical failure that had nothing to do 7 addressed that in whole or in part? 8 with us. They simply claimed that the fluid was a bigger 8 A No. 9 problem than they had known. 9 Q For example, did any of the courses that you took 10 Q Do you recall why they were claiming the fluid 10 at Wisconsin address that? 11 was a bigger problem? 11 A Some of the courses included content on process 12 A Well, the fluid contained Pcbs which of course 12 safety considerations which might relate to toxicity, but 13 turned out to be an environmental issue. 13 this specific information about toxicity was not covered. 14 Q Do you know whether that case has been resolved? 14 Q For example, when you were at the University of 15 A No, 1 don't. 15 Wisconsin, did you have occasion to read the Sax book, the 16 Q Have you ever testified in court in that case? 16 handbook on dangerous chemicals? 17 A No. 17 A No. 18 Q Have you ever testified in court in any context? 18 Q Have you ever had a chance to -- strike that. 19 A No. 19 Are you familiar with that book? 20 Q Have you ever been a plaintiff or defendant in a 20 A 1 know what it is, yes. 21 lawsuit? 21 Q Have you ever had a chance to consult it or look 22 A No. 22 at it for any reason? Page 10 Page 12 1 Q Having been deposed that often before, I'm sure 1 A Not personally. 2 you're familiar with the general guidelines, but just let 2 Q Did you have a copy of it during your time with 3 me for the sake of the record give them to you again. I'll 3 Monsanto? 4 be asking you questions. The court reporter is going to be 4 A No. 5 taking down your answers. She needs a verbal response. If 5 Q Have you ever taken any courses that addressed 6 at any time you don't understand one of my questions, just 6 the migration of chemicals in soil or water or the fate of 7 let me know and I'll try to make it as clear as possible. 7 chemicals in soil and water? 8 If at any time you need a break, we can accommodate you. 8 A Courses, no. 9 Can you give me your educational background 9 Q Have you ever received any instruction or 10 starting with high school, sir? 10 training or seminars or materials addressing that subject? 11 A Graduated from high school in Wauwatosa, 11 A Specifically what subject? 12 Wisconsin, W-a-u-w-a-t-o-s-a. Bachelor's degree in 12 Q The migration of chemicals in soil or water. 13 chemical engineering from the University of Wisconsin, 13 A No. 14 graduated in January 1957. Since then I've taken some 14 Q Or the fate of chemicals in soil or water. 15 graduate courses, but no further degrees. 15 A No. 16 Q What would have been the nature of the graduate 16 Q After you graduated in January of 1957 did you 17 courses that you've taken? 17 become employed? 18 A Just some higher math, business law, some 18 A Yes. 19 statistics, computer science. 19 Q By whom? 20 Q After your undergraduate degree in chemical 20 A By Monsanto. 21 engineering, have you taken any courses relating to 21 Q What was your position at that time? 22 chemistry or engineering? 22 A 1 was a - the title was assistant chemical Savage, James (Aroclor Dept employee) in AETNA (1) Pages 9-12 HARTOLDMONO010073 Page 13 Page 15 1 engineer at the John F. Queeny plant in St. Louis. 1 Q How long did you hold that position? 2 Q How long did you hold that position? 2 A About three years, until 1970. 3 A 1 think for the duration of my stay at the Queeny 3 Q What position did you take on in 1970? 4 plant, which was only a year. 4 A 1 transferred to the general offices of 5 Q What was your next position? 5 manufacturing manager. 6 A 1 was transferred to the Anniston plant sometime 6 Q Was that in Creve Couer? 7 in the first quarter of 1958. 7 A Right. 8 Q How long were you at the Anniston plant? 8 Q If 1 pronounced it correctly. And how long did 9 A Five years. 9 you hold that position? 10 Q What was your position there? 10 A Five years. 11 A 1 went to the Anniston plant with the same 11 Q So that would be up until about 1975? 12 title. Later on that was changed to chemical engineer, the 12 A Right. 13 word " assistant" taken out, and later during my stay at 13 Q What position did you take on in 1975? 14 Anniston 1 was production supervisor. 14 A In 1975 there was a reorganization and 1 was just 15 Mr. Brock: Off the record. 15 on some special assignments in personnel and so forth for a 16 ( Discussion off the record. ) 16 period of a couple of years. 17 By Mr. Brock: 17 Q And that would take us up to about 1977 or so? 18 Q I'm going to come back to these in more detail 18 A ' 78 actually. 19 later. Right now I'm just going to run through to try to 19 Q What position did you move to in 1978? 20 get the entire chronology of your positions. 20 A In 1978 1 moved out of manufacturing into an 21 What was your next position after production 21 altogether different line of work, became licensing 22 supervisor at the Anniston plant? 22 manager. Page 14 Page 16 1 A 1 was transferred to the Krummrich plant in 1963 1 Q Where was your office at that time? 2 as supervising engineer. 2 A Same place, the general office in Creve Couer. 3 Q How long did you hold that position? 3 Q How long did you hold that position? 4 A 1 guess about a year and a half. 4 A Essentially until my retirement about six weeks 5 Q What was your next position? 5 ago. 1 was promoted position director of licensing in 6 A 1 was promoted to superintendent in technical 6 about 1982, but the content of the job was still the same. 7 services at the Krummrich plant. 7 Q I'm sorry. Sometimes I'm a slow writer. In 1982 8 Q Was that the Tsd department? 8 you were transferred to what position? 9 A Right. 9 A 1 was promoted to the position of director of 10 Q How long did you hold that position? 10 licensing, but the content of the job didn't change. 11 A Until sometime in 1967 when 1 transferred to the 11 Q So you went from licensing manager to director of 12 Queeny plant. 12 licensing? 13 Q What was your position when you moved to the 13 A Right. 14 Queeny plant? 14 Q And you retired six weeks ago? 15 A 1 was the head of Tsd. The title was general 15 A At the end of March. 16 superintendent of technical services and laboratory. 16 Q 1 hope it didn't have anything to do with this 17 Q Could you repeat that for me? 17 case. Are you receiving a pension from Monsanto? 18 A General superintendent of technical services and 18 A No. 1 had the option of rolling out a lump sum 19 laboratory. 19 equivalent, which 1 did. 20 Q Was that for the whole Monsanto entity or was 20 Q Are you presently employed? 21 that for the-- 21 A I'm self-employed. 1 suppose, I'm developing a 22 A For the Queeny plant. 22 business as a consultant in technology transfer. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 13-16 HARTOLDMONO010074 Page 17 Page 19 1 Q When you use the term " technology transfer," what 1 plant besides Jim Knox? 2 does that mean? 2 A At some point 1 was also reporting to Bill Kuhn, 3 A That refers to the business of licensing 3 K-u-h-n, while Jim Knox was on some other assignment. 4 technology from one company to another, transferring the 4 Q Did any employees report to you? 5 information. 5 A No. 6 Q Do you presently specialize in the transfer of a 6 Q What were the nature of your job duties as 7 particular type of technology? 7 assistant chemical engineer? 8 A No. 8 A 1 was given specific assignments in various 9 Q Is Monsanto one of your clients? 9 production departments to correct operating problems or 10 A No. 10 improve the process. 11 Q As assistant chemical engineer at the Queeny 11 Q Were the problems, the operating problems in the 12 plant and I'm starting in the 1957 - or the ' 58 time 12 processes that you addressed at the Queeny plant? 13 frame, who did you report to? 13 A Yes. 14 A My first boss was Jim Knox. 14 Q During that time did you address any problems or 15 Q What was his position? 15 processes at any other Monsanto plants? 16 A He was technical services superintendent. 16 A No. 17 Q Was that at the Queeny plant? 17 Q What were the nature of the operating problems 18 A Yes. 18 that you had occasion to address during that time? 19 Q Did each plant have its own Tsd department? 19 A Well, perhaps better describe them as 20 A Yes. 20 opportunities than problems because in general they were 21 Q And was there a coordination among those 21 projects related to improving productivity or yield. 22 departments at the corporate level? 22 Q Do you recall what the processes were that were Page 18 Page 20 1 A To some degree. 1 involved? 2 Q How did that work? 2 A 1 worked on salicylic acid, s-a-l-i-c-y-l-i-c, 3 A Well, the technical services department formally 3 aspirin, paranitrophenetole. 4 reported to the plant managers, which was at that time a 4 Q You said paranitrophenetole? 5 functional manufacturing organization, plant managers 5 A Phenetole, yes. 6 reported to a director of manufacturing. Under the 6 Q Does that have an abbreviation? 7 director of manufacturing, there were some kind of 7 A Probably called Pnpt. 1 think a couple of 8 technical managers. 1 don't remember what their titles 8 others, but 1 don't remember. 9 were but their job was to do whatever coordination was 9 Q Did any of your projects relate to improving 10 needed between the plants and the general office and the 10 productivity or yield by reducing the amount of residues or 11 plants on a technical level. 11 wastes or by-products? 12 Q How long did that structure exist for the 12 A Typically the improvement of yield and the 13 coordination of the Tsd departments at the various plants? 13 reduction of waste go together. 14 A It survived up until the formation of a strong 14 Q Did any of your projects specifically focus on 15 business group organization in the ' 70s. 15 the reduction of waste as a means to improve the 16 Q Was that the name of that business group, the 16 productivity or yield? 17 Strong Business Group? 17 A Well, as 1 said those were the same thing. But 18 A Oh, no. Business groups were formed, business 18 in the paranitrophenetole department, for instance, 1 19 directors were named sometime 1 think in the late ' 60s. 19 worked on the start-up of a project which significantly 20 But the organization was formalized between around 1972 or 20 improved the yield and on raw material and reduced the 21 1973. 21 waste stream by exactly the same amount. 22 Q Did you have a subsequent boss at the Queeny 22 Q Was Pnpt manufactured at the Krummrich plant to Savage, James (Aroclor Dept employee) in AETNA (1) Pages 17-20 HARTOLDMONO010075 Page 21 Page 23 1 your knowledge at any time? 1 What were the nature of your job duties as 2 A No. It was a raw material for the Krummrich 2 assistant chemical engineer at the Anniston plant? 3 plant. The Krummrich plant converted it to paraphenitidine 3 A It was a different process but again solving 4 which might have been known by the same set of initials, 1 4 various problems, improving the process. 5 don't know. 5 Q Do you recall what processes you worked on during 6 Q Did the Anniston or Nitro plants use that 6 that time? 7 chemical? 7 A That was the Niran department, products were 8 A No, not to my knowledge. 8 ethyl parathion and methyl parathion. 9 Q Do you recall any other processes that you worked 9 Q Were you an employee in the Niran department 10 on or that you had projects related to during that time 10 during that time? 11 besides the Pnpt and the salicylic acid? 11 A 1 was part of the small technical service 12 A 1 did one small projects in the old caffeine 12 department, but my duties were entirely in the Niran 13 department, but it was not very directly related to 13 department. 14 process. 14 Q When you say the " small technical service 15 Q What did your work consist of on a day-to-day 15 department," what does that refer to? 16 basis on these projects? 16 A The Anniston plant being a small plant had a 17 A Well, generally the problem was defined in some 17 small Tsd group. There were just three or four of us in 18 general way, usually by a work order written by the 18 those days. 19 production supervisor. And then my job was to go and study 19 Q You're not separating it from another Tsd group 20 the problem, collect whatever data was necessary, propose 20 at the plant, 1 take it? 21 solutions. If my proposal was accepted, then the engineer, 21 A No, my duties were in the parathion department 22 changed what was needed to implement the proposal. 22 and other Tsd engineers worked in other departments. Page 22 Page 24 1 Q Do you recall addressing any -- strike that. 1 Q Did you learn the processes of the Niran 2 Do you recall being involved in any projects 2 department at that time? 3 during the time you were assistant chemical engineer at 3 A Yes. 4 Queeny addressing the methods by which Monsanto would 4 Q How did you go about doing that? 5 dispose of wastes from that plant? 5 A Well, when 1 arrived in 1958 the operation was 6 A No. 6 still in start-up and we had research people on the site, 7 Q From the 1958 to the 1963 time frame -- strike 7 and 1 started out working a shift as a shift supervisor as 8 that. 8 part of the start-up group. And it would be impossible to 9 When you moved to the Anniston plant, do you 9 be effective in that job without learning the process. 10 recall how long you were assistant chemical engineer? 10 Q Do you recall the nature of the projects that you 11 A No. The only distinction between being called an 11 worked on relating to the Niran department during that 12 assistant chemical engineer and a chemical engineer was a 12 time? 13 matter of salary progression. 13 A In the course of three years 1 probably worked on 14 Q Do you recall how long a time of the five-year 14 50 projects. 15 total that you were at Anniston that you held the positions 15 Q Do you recall their nature? 16 of assistant chemical engineer and chemical engineer? 16 A Well, all kinds. Yield improvement projects, 17 A Three years. 17 production capacity improvement projects, air pollution 18 Q 1 take it the job duties were the same, 18 projects, water pollution projects, projects to improve the 19 essentially the same? 19 reliability of the equipment. 20 A Similar, yes. 20 Q What were the air pollution projects that you 21 Q Did your job duties change -- let me strike 21 worked on? 22 that. 22 A Well, the biggest one related to an incinerator Savage, James (Aroclor Dept employee) in AETNA (1) Pages 21 - 24 HARTOLDMONO010076 Page 25 Page 27 1 that we had at the site which was used to dispose of still 1 incineration. The major component of the still residue 2 residue from a distillation. And as originally designed 2 actually was sulfur, which was a by-product of the 3 there was a white plume of phosphorus pentoxide that was 3 reaction. But there was some phosphorus in the still 4 quite unacceptable in the community and 1 worked with what 4 residue and when phosphorus is burned, the product is 5 was then the organic engineering department in St. Louis to 5 phosphorus pentoxide, which is normally a very small 6 run a pilot plant for a solution to that problem. And then 6 particle which creates a white plume even in very small 7 1 worked again with organic engineering in the installation 7 concentrations. 8 and start-up of a full-sized system to correct that 8 Q Do you recall what else was in the plume other 9 problem. 9 than the sulfur, and 1 take it that would be phosphorus? 10 Q When you use the term " still residue," what did 10 A Sulfur dioxide would have been the other major 11 that consist of? 11 part. 12 A In a distillation there's very often a material 12 Q How often would that take place? 13 left behind that does not boil over as part of the 13 A That was a continuous operation. 14 product. And that's usually called still residue. 14 Q So that would be every day? 15 Sometimes it has other names. 15 A Yes. 16 Q Right. Do you recall -- strike that. 16 Q Why was that not acceptable? 17 And 1 take it this was from the Niran department, 17 A It was partly an aesthetic issue. The Anniston 18 the Niran operation? 18 plant is in a valley and this white cloud depending on 19 A Yes. 19 weather conditions might put a kind of layer over the whole 20 Q Do you recall what the still residue consisted of 20 valley. 21 chemically? 21 Q Do you recall any times or any time during which 22 A Part of it was intermediate that we had failed to 22 that still residue was disposed of in some way other than Page 26 Page 28 1 recover from the still residue. This intermediate is a 1 incineration? 2 fairly complicated molecule which 1 can name if you want me 2 A No. 3 to. 3 Q So it was incinerated when you got there and it 4 Q Sure. And if there's an abbreviation, 1 would 4 was incinerated continuously until the time you left? 5 appreciate that. 5 A Right. 6 A Okay, when we were making ethyl parathion, we 6 Q Had there been any complaints by others in the 7 called it ethyl Pet. If we were making methyl parathion 7 Anniston area about the plume? 8 then that intermediate was called methyl Pet. And the 8 A Not that 1 know of. 1 wasn't the direct 9 still residue was what was left after we had distilled off 9 recipient of a complaint. 1 was simply informed that that 10 as much of the Pet as we could. 10 was a reason why we would resolve the problem. 11 Q The Pet, that was the final product; is that 11 Q Who informed you of that? 12 right? 12 A 1 think the plant manager. 13 A No, it was an intermediate which was further 13 Q Do you recall who that was at the time? 14 processed to make parathion. The plant people called it 14 A It was Dez Hosmer. 15 just intermediate for obvious reasons. 15 Q Were you informed what the impetus was for that 16 Q You said this resulted in a white plume of a 16 project, why that project was being undertaken at that 17 chemical that 1 thought you called phosphorus pentoxide? 17 time? 18 A Right. 18 A No, it was just a very obvious problem. 19 Q Can you tell me how that came about? 19 Q 1 thought you mentioned that you had worked on 20 A Well, the still residue had to be disposed of. 20 air pollution projects. Do you recall any other projects 21 It was a material that had some toxic components in it, it 21 of that type that you worked on at the Anniston plant? 22 smelled bad and the best way to destroy it was by 22 A 1 can think of only one other that - there was a Savage, James (Aroclor Dept employee) in AETNA (1) Pages 25 - 28 HARTOLDMONO010077 Page 29 Page 31 1 storage tank for an intermediate which had a vent, and 1 A They were the designers. 2 fumes from that vent were severe eye irritants which 2 Q When you say" they were the designers," what 3 bothered the workers, so 1 engineered a small device to 3 would they do as the designers? 4 stop that. 4 A They literally designed the pilot plant unit that 5 Q I'm sorry. Let me go back to the previous air 5 was put in Anniston, and then after 1 had collected the 6 pollution project that you worked on. Was that process 6 data from the pilot plant, they used that data to design 7 ceased during the time that you were at the Anniston plant? 7 the full-sized system. 8 A The process? 8 Q The second air pollution project that you 9 Q 1 thought you had talked about building a pilot 9 mentioned, the one with the storage tank that had a vent, 10 plant. Let me clarify my question. What was the nature, 10 what chemicals -- 1 think you referred to it as 11 if any, of the process change that was instituted to 11 intermediate? 12 address the phosphorus pentoxide plume situation during the 12 A Yes. 13 time that you were there? 13 Q That was going through the vent? 14 A We installed a device which was called a Brink 14 A Yes. Ethyl Pet. 15 demister which collected the P2o5 particles as phosphoric 15 Q Can you describe for me the processes involved 16 acid and essentially eliminated the plume. 16 that led up to the ethyl Pet being vented from the storage 17 Q What was done with the P2o5 particles that were 17 tank? 18 collected in the demister? 18 A It was very simple. The storage tank was used to 19 A It was collected as phosphoric acid and we were 19 accumulate batches from upstream and then batches for 20 able to sell that. 20 further processing downstream would be drawn from it. So 21 Q What exactly is a Brink demister? 21 it was essentially just buffer storage during the time it 22 A That was a trade name we had adopted at the time 22 was being filled, the vapor inside would breathe out and Page 30 Page 32 1 for a device that had been invented by Joe Brink, who was a 1 that vapor was an eye irritant. 2 Monsanto scientist in which in another part of the company 2 Q How big was the tank? 3 was being developed for commercialization, consisted of a 3 A 1 don't remember. A couple thousand gallons, 1 4 packed bed of very fine glass fiber. 4 suppose. 5 Q Do you recall who you worked on that project 5 Q How often would it be filled? 6 with? 6 A Every time a batch was finished, which might be 7 A The project engineer was Fritz Rosenberg, 7 five to 10 times a day. 8 F. E. Rosenberg, and Bill Garlette, G-a-r-l-e-t-t-e. They 8 Q Had there been complaints by Monsanto workers 9 were both in organic engineering in St. Louis. 9 that it was irritating their eyes? 10 Q During that time did you coordinate the projects 10 A Yes. 11 that you were working on with the people in Monsanto's 11 Q Do you recall any particular Monsanto workers who 12 St. Louis offices? 12 made such a complaint? 13 A Yes. 13 A No. 14 Q Was there a system set up to provide for that 14 Q How did it come to your attention that there had 15 type of coordination between the people at the plant level 15 been such complaints? 16 and the people at the corporate level in engineering 16 A In the usual way. A work order from the 17 personnel? 17 department supervisor asking for a solution to the problem. 18 A Yes, 1 was the contact at the plant and normally 18 Q Do you recall who the department supervisor was 19 Bill Garlette was the contact in St. Louis. Communication 19 from whom you received such work orders? 20 generally by telex. 20 A It was probably John Mullendore. 21 Q What was the nature of their involvement in that 21 Q Was he your boss at the time? 22 project, if you recall? 22 A No. He was the department production supervisor. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 29 - 32 HARTOLDMONO010078 Page 33 Page 35 1 Q Who was your boss at the time? 1 1 worked again operating a pilot plant that had been 2 A Well, when 1 first arrived at the Anniston plant 2 designed by people in St. Louis to collect design data and 3 under the start-up condition as part of the start-up team, 3 then worked with organic engineering on the installation of 4 1 was reporting to John Mullendore but then when the 4 the waste treatment plant. 5 start-up phase was completed, then 1 became a regular 5 Q Do you recall what the liquid wastes were from 6 member of Tsd, 1 reported to Bob Hedworth, who was the 6 the Niran department at that time? 7 supervisor of Tsd. 7 A Mostly water, of course. 8 Q Did he report to the plant manager? 8 Q And what if anything in addition to water? 9 A Yes. 9 A Well, the visible component was sodium 10 Q Did he also report to somebody in St. Louis? 10 paranitrophenate, which is soluble in water and has an 11 A It was kind of a dotted-line relationship to 11 intense color at fairly low concentration. It was kind of 12 somebody in St. Louis, yes. 12 a marker for the rest of what was there. 13 Q Who would that have been in St. Louis? 13 Q Does that have a chemical abbreviation? 14 A 1 don't remember. 14 A Sodium Pnp or Napnp perhaps. 15 Q What was the nature of the device that you 15 Q When you say that was a marker for other 16 engineered to address that venting situation? 16 chemicals that may have been there, what were those other 17 A It turned out to be a very simple solution. It 17 chemicals? 18 was a cannister of activated carbon. 18 A 1 don't know. They would have been by-products 19 Q I've talked to other Monsanto employees who got 19 of the parathion reaction. 20 patents for some of their work. Was a patent issued for 20 Q You don't know what those by-products were? 21 that? 21 A Well, a chemist might speculate about it, but 1 22 A No. 22 don't know. Page 34 Page 36 1 Q Do you recall working on any other air pollution 1 Q When you came on board, had the Anniston waste 2 projects during the time you were at the Anniston plant? 2 treatment plant been built? 3 A No. 3 A Yes. 4 Q You mentioned that you had worked on some water 4 Q Do you know what, if anything, was done with the 5 pollution projects during the time that you were at the 5 liquid wastes from the Niran department before the Anniston 6 Anniston plant. What were those? 6 waste treatment plant was built? 7 A Again, this was connected with the Niran 7 A The Anniston municipal waste treatment plant was 8 department. The original design of the Niran department 8 completed before the Niran department was started up so it 9 for handling the liquid waste had been, 1 understood, based 9 never went anywhere else. 10 on an agreement with the city, the city of Anniston had 10 Q How did the wastes from the Niran department 11 just built a new municipal waste treatment plant. And the 11 reach the Anniston waste treatment plant when you first 12 original intention was that the waste from the Niran 12 came on board at Anniston? 13 department would simply go directly to the city waste 13 A Through city sewers. 14 treatment plant and Monsanto would pay an appropriate 14 Q So they would go through the Monsanto sewers at 15 amount of money to cover the cost of treatment. 15 the Anniston plant and into the city sewer system? 16 Early in the start-up phase, it appeared that the 16 A That's right. 17 Anniston municipal plant was not going to be able to handle 17 Q Do you recall ever hearing or learning of any 18 the combination of domestic waste from the city and the 18 leaks or leakage from the Monsanto sewers leading from the 19 waste from the parathion department. So at some high 19 Niran department to the city sewers? 20 level -- 1 don't know where -- it was decided that we 20 A No. 21 should pursue the possibility of our own waste treatment 21 Q Do you recall hearing or learning of any leakage 22 plant and to pretreat before it was sent to the city. And 22 from sewers leading from other departments at the Anniston Savage, James (Aroclor Dept employee) in AETNA (1) Pages 33 - 36 HARTOLDMONO010079 Page 37 Page 39 1 plant to the city sewers? 1 Q Do you recall what the nature of the treatment 2 A The Anniston plant has a ridge through the center 2 was that the liquid waste from the Niran department 3 and the waste from the parathion department went to the 3 received at the city of Anniston waste treatment plant? 4 city sewers from one side of the ridge. The operations on 4 A There was a conventional activated sludge waste 5 the other side did not go to the city sewers. 5 treatment plant, a primary settler, secondary settler and 6 Q Where did those go? 6 an anaerobic digester for the sludge. 7 A They went into what would otherwise be an 7 Q When you say a " settler," is that something that 8 intermittent stream called Snow's Creek or Snow Creek 8 settles particles down to the bottom? 9 perhaps. 9 A Yeah, it's very conventional design for municipal 10 Q Was that the case even after the Anniston waste 10 waste treatment plant. 11 treatment plant was constructed? 11 Q What did the Monsanto waste treatment plant 12 A Yes. 12 consist of? 13 Q During the time that you were at the Anniston 13 A Quite similar except that we didn't have a 14 plant, did you ever work on any projects relating to any 14 primary settler because there was very little solid in the 15 operations on the other side of the ridge? 15 waste to be settled and we had no anaerobic digester 16 A Well, when 1 became a production supervisor, 1 16 because we had no sludge to get rid of. So essentially it 17 was in charge of some operations on the other side. 17 consisted of a limestone bed for neutralization of any acid 18 Q The sewers on the other side of the ridge at the 18 material present. Then aeration basins, which is where the 19 Anniston plant, did those go directly to Snow Creek? 19 natural treatment took place, biological oxidation and then 20 A There was a limestone bed in the front yard 20 after that a secondary settler, which was used to recycle a 21 through which the water flowed before it went to Snow 21 small amount of sludge that was present. 22 Creek. 22 Q And this is a separate limestone bed - the waste Page 38 Page 40 1 Q Did you ever hear or learn of any leakage from 1 treatment limestone bed is a separate limestone bed than 2 the pipes or sewers leading from those operations to the 2 the limestone bed that was on the other side of the plant? 3 limestone pit? 3 A That's right. 4 Mr. Burnett: Pit or bed? Did you say pit or 4 Q Did you ever hear or learn of any leaching or 5 bed? 5 migration of chemicals from the waste treatment plant 6 The Witness: 1 said bed. It might equally well 6 limestone bed into the adjacent soil or water? 7 be called a pit. 7 A 1 don't remember anything like that. 8 By Mr. Brock: 8 Q Was the limestone bed lined? 9 Q From the past, I've referred to it as the 9 A Yes. 10 limestone pit but 1 don't have a problem using limestone 10 Q With what was it lined? 11 bed. 11 A 1 don't remember. The limestone bed was actually 12 A 1 don't remember specifically problems with 12 in place when 1 arrived at Anniston because it was part of 13 faulty sewers, but that is not something that 1 would have 13 the original design. 14 necessarily known about anyway. 14 Q And now you're referring to the waste treatment 15 Q That was going to be my next question. Did you 15 plant limestone bed? 16 ever work on any projects relating to any pipes or sewers? 16 A Yes, the original design was that the waste would 17 A No, the sewers were the responsibility of the 17 go through the limestone bed before it went to the city 18 maintenance department. 18 sewer. 19 Q Do you recall sewer repair projects or sewer 19 Q What did the aeration basins consist of? 20 replacement projects going on during the time you were at 20 A Quite large rectangular basins about 15 feet 21 the Anniston plant? 21 deep. There were two of them side by side. Each one of 22 A No. 22 them about 30 feet wide, perhaps 80 feet long. There were Savage, James (Aroclor Dept employee) in AETNA (1) Pages 37 - 40 HARTOLDMONO010080 Page 41 Page 43 1 pipes submerged in the waste and very large compressors 1 wastes from the Niran department? 2 which blew air down into the pipes, went through 2 A Again, 1 had a number of cost improvement 3 distribution nozzles to bubble air up through to the 3 projects related to improving yield and we did improve the 4 basins. 4 yield on raw materials significantly during that time, and 5 Q Did that limestone bed and those aeration basins, 5 that again resulted in a proportionate reduction in the 6 did they receive liquid wastes from departments other than 6 amount of waste. 7 the Niran department? 7 Q Were there solid wastes that were produced in the 8 A No. 8 Niran department during that time? 9 Q Did you ever hear or learn of any claims that 9 A Very little. The main wastes were the aqueous 10 chemicals had migrated or leaked from the aeration basins 10 wastes that were handled in the waste treatment plant and 11 into the adjacent soil or water? 11 the heavy liquid that was incinerated. The only solid 12 A No, they were concrete. 12 waste that 1 can recall was a small amount of filter cake. 13 Q So you're not aware of any time in which they 13 The final product was filtered before it was drummed and we 14 were cracked and materials leaked through? 14 used some kind of clay as a filter aid. And when it was 15 A No. 15 time to clean the filter, there would be a small amount of 16 Mr. Burnett: Whenever youreacha convenient 16 filter cake, which would consist of that clay plus whatever 17 spot, why don't we take a short break.We've been going 17 had collected in the clay, and that was placed in some kind 18 about an hour. 18 of containers and hauled away. But 1 don't know where it 19 Mr. Brock: Okay. 19 went. 20 By Mr. Brock: 20 Q Do you know who it was that hauled it away? 21 Q Did you work on any other water pollution 21 A It would have been the shipping department in the 22 projects during the time you were at the Anniston plant? 22 plant. Page 42 Page 44 1 A You mean during my time as an engineer? 1 Q Do you know what that material, the material that 2 Q Right. 2 was collected, do you know what that consisted of? 3 A 1 had a number of small projects related to 3 A There was some kind of tar that formed as part of 4 improving the operation of the waste treatment plant 4 the manufacturing process, 1 don't know what its chemical 5 itself. But since that was the entire liquid effluent from 5 composition was. 6 the Niran department, there was no other waste treatment 6 Q Do you recall there being any other solid wastes 7 problem to work on. 7 produced in the Niran department during that time? 8 Mr. Brock: Now is probably a convenient time for 8 A No, 1 don't remember any. 9 a break. 9 Q You said you worked on a project that improved 10 ( Recess. ) 10 the yield on raw materials and that resulted in a 11 By Mr. Brock: 11 proportionate reduction in the amount of waste. Can you 12 Q Mr. Savage, before we broke, you had mentioned a 12 describe for me what that project was? 13 number of small projects that you had worked on relating to 13 A There were quite a few such projects. In general 14 improving the waste treatment plant itself. What were the 14 it related to changing operating conditions to try to 15 nature of those projects? 15 optimize the operation, small improvements in equipment 16 A Well, it's a long time ago. The only one that 16 that would allow operation, more desirable conditions. 17 comes to mind is we eventually expanded production in the 17 Q Do you recall what if any equipment changes were 18 the parathion department and needed to expand our waste 18 instituted during that time? 19 treatment capacity proportionately, so 1 installed another 19 A No. They were usually small things that allowed 20 compressor to increase the air flow rate. 20 process changes. The change in equipment was kind of 21 Q Did you work on any projects as an assistant 21 incidental to the process change. 22 chemical engineer that related to reducing the amount of 22 Q Do you recall any specific process changes that Savage, James (Aroclor Dept employee) in AETNA (1) Pages 41 - 44 HARTOLDMONO010081 Page 45 Page 47 1 were instituted during that time? 1 A That was Tom Lackey, L-a-c-k-e-y. 2 A The only one that comes to mind is that we 2 Q Do you recall any of the operators who were there 3 improved the vacuum system with several steps relating to 3 during that time? 1 recognize it goes back aways. 4 the distillation. And by improving the vacuum system we 4 A 1 can remember some of them as colorful 5 were able to distill more effectively and therefore recover 5 characters, but 1 don't think 1 can remember names right 6 more intermediate from the batch. 6 now. 7 Q What happened to the intermediate that was not 7 Q Who was the foreman in the Aroclor department who 8 distilled? 8 reported to you? 9 A That was part of the distill residue. It was 9 A Mark Williams. 10 incinerated. 10 Q And 1 take it he was there during the entire 11 Q As production supervisor at the Anniston plant, 11 time? 12 what were the nature of your job duties? 12 A Yes. 13 A My first assignment was the chlorine plant and as 13 Q Was he the foreman responsible for the muriatic 14 a production supervisor 1 was responsible for the 14 acid operations as well? 15 day-to-day operation of the chlorine plant, which included 15 A I'm not sure. It was a large department, a large 16 supervision of a foreman and a number of operators. 16 workforce. The other foreman was Barker Curry and he 17 Q Who did you report to during that time? 17 reported to Burns Severson and so we shared management of 18 A My first boss in production was Karl 18 this large work force. And muriatic acid was operated by 19 E-d-e-l-b-l-u-t, and later on he was replaced by Bob Moody. 19 that work force, but 1 don't remember which of the foremen 20 Q How long were you production supervisor of the 20 it was. 21 chlorine plant? 21 Q During the time you were production supervisor at 22 A Three years. 22 the Anniston plant, were there any departments, any Page 46 Page 48 1 Q Were you production supervisor of other 1 additional departments that were ever under your purview? 2 operations there as well? 2 A Oh, yes. A department we called Hb-40. 3 A Yes. After one year, responsibility for the 3 Q Was that a subset of the Aroclor department? 4 Aroclor department was added, but 1 kept the chlorine 4 A No, it was another product made from the same raw 5 department. 5 material. 6 Q Did you report to Mr. Edelblut and Mr. Moody 6 Q Do you recall who the foreman was who reported to 7 concerning the operations of the Aroclor department as 7 you from that? 8 well? 8 A That was also Mark Williams. Hb-40 was a small, 9 A Yes. 9 separate operation. 10 Q As production supervisor at the Anniston plant 10 Q Was that manned by the same employees as the 11 were there any other operations that were under your 11 Aroclor department? 12 purview? 12 A 1 don't remember. It may have been a separate 13 A One of the by-products or the by-product of the 13 group. 14 Aroclor department was muriatic acid, and during the time 14 Q When you say you were responsible for the 15 that 1 supervised the Aroclor department, 1 also had 15 day-to-day operations of those departments, what did you do 16 responsibility for that operation. That was the same work 16 on a day-to-day basis as production supervisor? 17 force. 17 A Well, as the title implies, the first 18 Q When you say it was " the same work force," was 18 responsibility is to get the production out. So this would 19 that in the same department? 19 have to do with setting production schedules according to a 20 A Yes, the Aroclor department. 20 production plan received from St. Louis, setting up the 21 Q Do you recall who the foremen were who reported 21 workers ' shift schedules, although that was usually 22 to you regarding the chlorine plant operation? 22 delegated to the foremen, checking on the condition of the Savage, James (Aroclor Dept employee) in AETNA (1) Pages 45 - 48 HARTOLDMONO010082 Page 49 Page 51 1 department, writing maintenance work orders if they were 1 identify what that is for us. 2 needed, and when there was time, studying the operation to 2 ( Witness reviewed the document. ) 3 see where there were opportunities for improvement and 3 A Yes, this is just a couple of the many 4 perhaps writing work orders to Tsd to implement any of 4 amendments. 5 those. 5 Q Do you recall -- strike that. 6 Q How would you go about checking the condition of 6 As production supervisor in the Aroclor 7 the operations? 7 department, did you have any role in the amendments to the 8 A The normal routine in the morning, since this was 8 standard manufacturing process in place in that department? 9 a round-the-clock operation, our normal routine would be, 9 A Yes. 10 upon arrival, to take a look at the log sheets from the 10 Q What was the nature of your role along those 11 previous evening's operations and see whether production 11 lines? 12 was proceeding according to schedule, taking whatever 12 A As you can see, 1 was the first approval line. 13 action was indicated by that. 13 Q You're referring to Exhibit 2? 14 ( Savage Exhibit 1 identified. ) 14 A Yes. Normally the production supervisor would be 15 Mr. Brock: I've marked as Savage Exhibit 1 a 15 the first to approve and then there was some other people 16 multipage document with Bates numbers Mco 1792817 through 16 who approved. But 1 might have also been the initiator. 17 855. Mr. Savage, rather than have you read through the 17 Q Do you recall any specific amendments that you 18 document word for word, which could take a very long time, 18 initiated? 19 could you just glance through the document to the extent 19 A The only one 1 can recall without referring to 20 you feel comfortable and identify what it is for us. 20 these documents is changing one of the batch operations to 21 ( Witness reviewed the document. ) 21 continuous. 22 Mr. Brock: While you're doing that, I'll mark 22 Q What was the impetus for that? Was that in the Page 50 Page 52 1 another exhibit for the record. This will be Exhibit 2, 1 Aroclor department? 2 which is a Tentative Amendment Number J to the standard 2 A Yes, just to get more production. 3 manufacturing process for Aroclor at the Anniston plant. 3 Q Let me ask you to turn to the second page of 4 And the Bates numbers of this are Mco 1792839 through 855. 4 Exhibit 2. There are some names there. W. D. Robinson, who 5 And I'll note that Exhibit 1 ends at Bates number 938. And 5 was that? 6 the reason 1 note that is because the Bates numbers are 6 A Dean Robinson, he was a research person at 7 sequential. 7 St. Louis. 8 The Witness: This is a standard manufacturing 8 Q What, if any, was his role in the operations of 9 process for Aroclor, a standard document that Monsanto had 9 the Aroclor department at that time? 10 for all its operations. 10 A Well, for each operation there was some research 11 By Mr. Brock: 11 person who was responsible for maintaining the process and 12 Q This was the one that was in effect, or was this 12 in this case it was Dean. 13 the one that was in effect during the time that you were 13 Q Who was H. L. Hubbard? 14 production supervisor? 14 A That's Harold Hubbard. 15 A It's dated October 1957, so 1 presume it was. 15 Q What was the nature of his role in the Aroclor 16 It also includes quite a long series of 16 process? 17 amendments, various states. 17 A He was a higher level person, research. 1 don't 18 ( Savage Exhibit 2 identified. ) 18 know what his title was. 19 By Mr. Brock: 19 Q Let me ask you to turn to the table of contents 20 Q Let me ask you to take a look at Exhibit 2 and 1 20 in Exhibit 1, which is on the Bates number that ends in 21 believe your name is in the top right-hand corner of that. 21 862. If you look on the side of the page, there's a 22 Once you've had a chance to look through that, could you 22 microfilm number there, which is 0048. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 49 - 52 HARTOLDMONO010083 Page 53 Page 55 1 A Yes. 1 Q Do you know whether that was taken to a landfill? 2 Q On some of these table of contents, for some of 2 A 1 think it was but 1 don't know where. 3 these, I've seen categories for environmental or 3 Q When you say you think it was, why do you believe 4 atmospheric discharges and waste disposal, and 1 note that 4 that? 5 there's not such a category here. Do you know when the 5 A Well, because 1 can't think of any other place 6 categories concerning environmental and waste disposal were 6 you'd go with it. 7 added to the standard manufacturing processes? 7 Q Do you know who from the shipping department -- 8 A No, 1 don't. The format for the standard 8 when you say the shipping department took that away, do you 9 manufacturing process has evolved over the years, and 1 9 have any names in mind of who actually handled that? 10 don't know when that change was made. 10 A The guy who ran the shipping department in those 11 Q Do you know whether such a change was made in the 11 days was called Pap Gray, H. L. Gray. 1 don't know what his 12 Aroclor department during the time that you were there? 12 real name was. 13 A In the standard manufacturing process? 13 Q Do you know whether he's still alive? 14 Q Correct. At the Anniston plant. 14 A No, 1 don't. He would be at least 80 by now, 1 15 A Not that 1 recall. 15 think. 16 Q Let me ask you to turn to the page that has a 16 Q Do you know how many Aroclor stills there were in 17 Bates number of-- that ends in 849. Again, those are the 17 operation at the Anniston plant during that time frame? 18 numbers down at the bottom. 18 A 1 think there probably were about five, but 1 19 A Okay. 19 don't remember for sure. 20 Q There's a reference up at the top to something 20 Q But were those for the various grades of Aroclor? 21 called an Aroclor still. Do you see that? 21 A The stills were all about the same but typically 22 A Yes. 22 each one would be dedicated to a certain grade. Page 54 Page 56 1 Q What were the Aroclor stills? 1 Q Right. For example, if you look at the page 2 A One of the steps of the Aroclor process was to 2 we've been looking at that ends in Bates number 849, you 3 distill the finished product, and a piece of equipment for 3 can see it references different grades of Aroclor 1221, 4 doing that was called a still. 4 1242,1248. Do you see that? 5 Q When the finished product was distilled, would 5 A That's right. 6 there be a residue? 6 Q Would there be one still for 1221 and another for 7 A Yes. 7 1242 and another for 1248, that type of thing? 8 Q What would that residue consist of? 8 A Not really. There were only two or three grades 9 A Materials that have been more highly chlorinated 9 that were made in large volume and the others were made in 10 than the desired product. 10 small. For instance, 1221 which was only made once in a 11 Q So they would be Pcbs, but that were chlorinated 11 while borrow some from other stills. 12 too much or too high? 12 Q What were the two that were made in large 13 A That's right. 13 volumes? 14 Q What was done with those materials? 14 A 1242, 1254 and perhaps after that 1248 or 1260. 15 A That material was drawn off from the bottom of 15 1221 was a small volume, 1262, very small volume. 16 the stills into drums and taken away by the shipping 16 Q When you say" after that," you just mean the next 17 department. 17 in order? 18 Q Do you know where it was taken to? 18 A Yes. 19 A No, 1 don't. 19 Q You don't mean sequentially in time? 20 Q Do you know how that process was decided upon? 20 A That's right. 21 A No. It had been going on for many years, I'm 21 Q How often would the distill operations take place 22 sure. 22 such that a residue was created that would need to be taken Savage, James (Aroclor Dept employee) in AETNA (1) Pages 53 - 56 HARTOLDMONO010084 Page 57 Page 59 1 away? 1 Q Do you know what that filter cake consisted of? 2 A Well, the stills were running pretty much all the 2 A It consisted primarily of the clay. There would 3 time and usually operated chain-fed, meaning that 3 be Aroclor in it, of course, and perhaps small amounts of 4 additional batches would be added to the still until the 4 tarry material, very, very little. 5 amount of residue reached a certain point and then that 5 Q And that again was handled by the shipping 6 would be drawn off. 6 department? 7 Q Do you recall how frequently it would be drawn 7 A Right. 8 off? 8 Q Do you recall there being any aqueous wastes from 9 A No, 1 don't remember. 9 the Aroclor department at that time? 10 Q When it was drawn off, what would the general 10 A 1 think there was a water scrubber that handled 11 volume be? 11 the discharge air from the blowing step and the water from 12 A 1 don't remember. 12 that scrubber went to the sewer. 13 Q Let me ask you to turn to the Bates number that 13 Q Was that water scrubber there the entire time 14 ends in 875 and again I'll refer just to the very bottom 14 that you were at the Anniston plant? 15 sentence of that page where it talks about still residue 15 A 1 don't remember that. It was there for at least 16 being removed from the still pot when changing from one 16 part of that time, probably all of the time. 17 Aroclorto another; do you see that? 17 Q When you say that was from the blowing step, can 18 A Yes. 18 you just briefly run through the steps involved in the 19 Q Is the still residue that's referenced there the 19 Aroclor processes for me? 20 same type of still residue that you and 1 have been talking 20 A Yes, that is fairly simple. The starting raw 21 about? 21 material was either biphenyl orterphenyl, depending on 22 A Yes. 22 what kind of Aroclor was required. That material was first Page 58 Page 60 1 Q What was the still pot? 1 put in a feed tank where it was mixed with a small amount 2 A That's just another word for the still. 1 2 of catalyst - it was ferric chloride - and then that 3 suppose when one would refer to the still, one would be 3 material went to a chlorinator. Some of the chlorinators 4 referring to the entire system with the furnace and so 4 ran continuously and others were run batchwise. What came 5 forth whereas the still pot was the main piece, the tank. 5 from the chlorinator was called crude Aroclor. 6 Q Do you recall whether that distillation process 6 The next step -- the next step that 1 remember 7 was changed at all during the time that you were production 7 anyway was blowing and that consisted simply of blowing air 8 supervisor at the Anniston plant? 8 through the crude Aroclor to remove small amounts of Hcl, a 9 A Not in any significant way that 1 can remember. 9 by-product from the reaction which was dissolved in the 10 Q Do you recall anybody expressing the thought that 10 crude Aroclor. Then after that the crude was put into the 11 the still residue shouldn't be taken away for disposal 11 still, distilled, then the distilled product was, again 12 during that time? 12 what was called a clay treatment, which was the beginning 13 A No. 13 of the filtration step and after filtration the product was 14 Q Do you recall any other wastes or residues being 14 finished. 15 created in the Aroclor department during those years? 15 Q From time to time, would there be leaks or spills 16 A There was a filter cake. The final step of the 16 in those processes? 17 process was to filter the Aroclor -- again, a clay was 17 A Occasionally there would be failures of pump 18 added to the product as a filter aid - and the product was 18 packing or piping which would lead to leaks or spills. 19 then filtered through platen frame filter presses with 19 Q And what would it be that spilled? 20 filter paper. And at the end of the filtration cycle, the 20 A Crude Aroclor or Aroclor. 21 press would be opened and the filter cake and the paper 21 Q What happened to the crude Aroclor in those 22 dropped into drums to be hauled away. 22 instances? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 57 - 60 HARTOLDMONO010085 Page 61 Page 63 1 A These materials are under ambient conditions 1 A 1 don't know that there was a special amount of 2 either very viscous liquids or solids, so any material that 2 Aroclor to be cleaned up at that time. Whatever there was 3 leaked tended to pool on the floor and perhaps solidify and 3 would be disposed of in the same way. There would be a 4 with arduous effort would be scraped up and put into 4 dumpster brought over by shipping. We would put in that 5 dumpsters to be disposed of. Because it was so difficult 5 whatever we had, or typically what was cleaned up for 6 to clean it up, everybody was enthusiastic about preventing 6 housekeeping inspection was just junk. 7 leaks and spills. 7 Q Do you recall there being any claims or 8 Q Did the floor of the Aroclor department have a 8 complaints during that time that Aroclor from the Aroclor 9 sheen or a coat or a layer of the Aroclor on it typically? 9 department had leaked into the soil or water? 10 A No. It was a concrete floor and there would be 10 A 1 don't remember anything like that. 11 places where the remains of previous spills might still be 11 Q You mentioned some aqueous wastes that were 12 evident and there were places where it was black and shiny. 12 handled through a water scrubber. What did those wastes 13 Q Would there be -- aside from efforts to clean up 13 consist of other than water? 14 individual spills where Aroclor would be, were there larger 14 A Hcl, which when dissolved in water is known as 15 efforts to clean up residual Aroclor in the Aroclor 15 muriatic acid. As far as we knew at that time, that's all 16 department, meaning, for example, a once-a-year cleanup or 16 it was. 17 that type of thing? 17 Q And what was done with that? 18 A Well, all departments went through an annual 18 A It went into the department sewers which led out 19 housekeeping inspection. It was a tradition all over 19 to the limestone bed in the front yard, from there to Snow 20 Monsanto at that time. And there would always be a special 20 Creek. 21 cleanup effort before that or before some big wheel came to 21 Q Just to get a frequency of the times when that 22 visit. 22 would happen, would that happen every time that the blowing Page 62 Page 64 1 Q What did the annual housekeeping inspections 1 step took place? 2 entail? 2 A Yes. The scrubber ran all the time. 3 A It was usually a team of production people from 3 Q Do you know of any other aqueous wastes from that 4 other plants who would come in and perhaps spend two or 4 department? 5 three days going over the plant very carefully and making 5 A No. 6 recommendations for improving housekeeping or safety. And 6 Q Were there air emissions from that department? 7 by the same token Anniston people would go out on similar 7 A Not that 1 remember. The vacuum jets had a steam 8 teams to other plants. 8 discharge but as far as we knew that was just steam. 9 Q Do you recall any housekeeping or safety 9 Q I'm not sure that 1 have one of the big documents 10 recommendations that were made with regard to the Aroclor 10 for the chlorine department that would both guide us and 1 11 department in connection with those inspections? 11 guess delay us. Can you describe for me briefly the nature 12 A No, nothing specific. 12 of the operations of the chlorine department at that time? 13 Q Did you personally go visit other plants on 13 A Chlorine is made from salt, sodium chloride. We 14 housekeeping inspections? 14 called it the chlorine department because that was the 15 A 1 don't think -- no, 1 don't think 1 ever did. 15 product that we needed. In fact, in making chlorine from 16 Q You said there would be a big cleanup in 16 salt, it was a coproduction of caustic soda, sodium 17 connection with the annual housekeeping inspections? 17 hydroxide. And in fact that particular plant was unusual 18 A Yes. Usually work overtime for a couple days and 18 in that we used both sodium chloride and potassium chloride 19 try to make the place look particularly good. 19 as starting materials so that we could produce either 20 Q When the residual Aroclor that was cleaned up in 20 caustic soda or potassium hydroxide, caustic potash. 21 the big housekeeping inspections, what would be done with 21 So we had two separate brine systems. In one 22 that? 22 brine system salt was dissolved in water. In the other Savage, James (Aroclor Dept employee) in AETNA (1) Pages 61 - 64 HARTOLDMONO010086 Page 65 Page 67 1 brine system, potassium chloride was dissolved. The main 1 surface of the mercury primarily to prevent mercury vapor 2 part of the chlorine plant was a number of cells, 2 from entering the atmosphere. And that wash water went to 3 electrolytic cells. Ours were a proprietary system 3 the sewer. 4 licensed from Denora in Italy, mercury cells in which 4 Q Is that the sewer that went to the limestone bed 5 there's a flowing mercury cathode and at that time carbon 5 and then Snow Creek? 6 anodes suspended in the brine above the mercury cathode. A 6 A Yes. 7 very large electric current passed through the cells and 7 Q Would there be mercury in the wash water? 8 the salt was electrolyzed into chlorine which came out of 8 A Probably, a small amount. 9 the brine as a gas and metallic sodium or potassium which 9 Q Would there be anything else in the wash water 10 became dissolved in the mercury. 10 besides water? 11 The mercury would flow out of the cell into a 11 A Yes. There would, be typically there was some 12 separate little tank called a decomposer in which the 12 brine entrained out of the back end of the cell. So there 13 sodium or potassium in the mercury amalgam would react with 13 would be sodium chloride or potassium chloride in the 14 the water to form either sodium or potassium hydroxide and 14 water. 15 separate handling systems for sodium hydroxide and 15 Q Do you recall there being any complaints or 16 potassium hydroxide, and mercury leaving the bottom. The 16 concerns expressed in connection with the fact that there 17 decomposer tank would be pumped back up into the cell. We 17 would be mercury in the wash water? 18 had 36 cells and a complicated system of changeover piping 18 A No, 1 don't remember any complaints. Mercury is 19 so that it, more or less, any number of cells could be 19 very expensive and we did our best to minimize that. 20 placed on either sodium or potassium depending on what the 20 Let me correct something 1 said before, there was 21 market required. 21 no solid waste, that's not quite true. Because we used 22 Q If 1 understood your answer correctly, the raw 22 graphite anodes in the cells and they would be consumed Page 66 Page 68 1 materials were sodium chloride and potassium chloride? 1 over the course of a year or so and what was left of the 2 A That's right. 2 anode was a waste that had to be discarded. 3 Q Were there others? 3 Q What did that consist of, graphite? 4 ATrivial amounts of others that were used to treat 4 A Just a chunk of graphite. 5 the brine. 5 Q How was that discarded? 6 Q Were there wastes or residues that were created 6 A 1 don't know. 7 in that process? 7 Q Do you know how frequently it would be discarded? 8 A 1 don't remember any solid waste. There was a 8 A Oh, yes, that was an important part of the 9 by-product, hydrogen which came out of the decomposers. 9 management of the cells. The anodes would last something 10 And when 1 first became supervisor of that, hydrogen was 10 over a year and it was important to manage all the cells in 11 simply a waste product that was put up into the air; of 11 such a way that we could be rebuilding one or two cells 12 course it just rises and disperses in the atmosphere. 12 with new anodes while the rest of them ran. So it was 13 Later on we began recovering that hydrogen and compressing 13 important to properly stagger that operation so that we 14 it to use in the Hb-40 department, so it became a valuable 14 would normally have 32 to 34 cells available. 15 by-product. 15 Q Sol take it they would be replaced a little bit 16 Q Do you recall any aqueous wastes from that 16 less than once a year? 17 department? 17 A That's about right. 18 A Yes, there was wash water that was used at the 18 Q Do you recall there being leaks or spills in 19 cells. The cells were about three feet long -- or three 19 those, in the chlorine operations during that time? 20 feet wide and about 40 feet long. Long, flat tanks. And 20 A Sometimes we had brine leaks, brine is quite 21 at the entrance and exit of the cell on each end where the 21 corrosive. And even though we had special corrosion 22 mercury went in and came out, wash water was run over the 22 resistant piping, we would get some brine leaks sometimes Savage, James (Aroclor Dept employee) in AETNA (1) Pages 65 - 68 HARTOLDMONO010087 Page 69 Page 71 1 and brine would be spilled. As to chlorine, chlorine 1 Q How long would it take for the brine to corrode 2 itself, chlorine gas is dangerous enough that a leak 2 the pipes? 3 couldn't be tolerated. 3 A There were a number of different corrosion 4 Q Did you recall there being any emissions of 4 environments in various places in the system. In some 5 chlorine gas during that time? 5 places the material would last many years. Some of the 6 A Yes. If we had a piping failure, but we would 6 piping was the original piping from when the plant was 7 immediately shut down. 7 built in the early ' 50s. But there were other environments 8 Q Did that happen from time to time, a piping 8 that were more corrosive and it was important to find just 9 failure? 9 the right material. 10 A Not very often, but it did happen. 10 Q When you say" other environments that were more 11 Q Approximately how frequently? 11 corrosive," what do you mean by that? 12 A Oh, 1 don't know. 1 only remember one incident 12 A The brine that was originally made up by 13 during my time. 13 dissolving the salt or the potassium chloride was at a 14 Q When was that? 14 neutral ph, it was neither acid nor alkaline and was not 15 A 1 don't know. 15 particularly hard to handle. When the brine passed through 16 Q What do you recall about the incident? Do you 16 the cell, the concentration fell by 30 or 40 percent. That 17 recall what happened generally? 17 is, only part of the salt or potassium chloride was 18 A A valve at the bottom of a tank had failed due to 18 consumed on each pass. With the brine leaving, the cell 19 corrosion and there was enough chlorine in the atmosphere 19 was saturated with the chlorine, had a very acidic ph, and 20 to be visible, so people had to put on emergency breathing 20 therefore it was very corrosive until it went back out into 21 apparatus and of course shut down. It was -- because it 21 the brine treatment area and had to be cleaned up. 22 was an electrolytic operation, it was easy to shut down 22 Q What was the brine treatment area? Page 70 Page 72 1 very quickly. It was just a matter of interrupting the 1 A Actually that was the largest part of the 2 current and the production was stopped. 2 operation because that was the area where salt was 3 Q Where would the brine leaks, where would they go? 3 dissolved. The brine system was an enclosed loop and spenl 4 A Onto the ground. The brine area had crushed rock 4 brine would be brought from the cells, ph adjusted and 5 on top of the ground. 5 treated and then passed back through tanks where more salt 6 Q Do you know what was under the crushed rock? 6 or Kcl was dissolved, excuse me, potassium chloride. And 7 A Just dirt. 7 then that was fresh brine, it could be sent back to the 8 Q How often would there be -- was that a frequent 8 cells. They're two separate closed loops, one for 9 thing, the brine leaks? 9 potassium chloride brine and the other for the sodium 10 A It's something that would happen every couple of 10 chloride brine. 11 months, 1 suppose. If it was considered an economic 11 Q Let's see if we can do the same thing for the 12 problem and as production supervisor, 1 was responsible for 12 Hb-40 operations at the Anniston plant during that time. 13 getting good raw materials. It was not something that 1 13 Can you describe those operations for me? 14 wanted to tolerate. 14 A The raw material for Hb-40 was terphenyl. The 15 Q Do you recall any steps being taken, during your 15 product we called Santowax R which means refined 16 tenure as production supervisor, to reduce the frequency of 16 terphenyl. The terphenyl was brought into the department 17 the brine leaks? 17 into the feed tank, catalyst was added to it, in this case 18 A Yes. The main thing that we did was 1 worked 18 the catalyst was something called Raney nickel, which is a 19 with the maintenance supervisor on some preventive 19 term for a special form of chemically active nickel. 20 maintenance to try to organize periodic shutdowns to 20 Q Is that R-a-n-n-e-y? 21 replace major parts of the piping that were kind of old 21 A R-a-n-e-y, named after somebody, but it's not 22 with new material. 22 really a trade name. A number of companies sell Raney Savage, James (Aroclor Dept employee) in AETNA (1) Pages 69 - 72 HARTOLDMONO010088 Page 73 Page 75 1 nickel. The nickel would be disbursed in the terphenyl. 1 the product was very noncorrosive and it was a relatively 2 It didn't dissolve. It was just metallic granules mixed up 2 trouble-free operation. 3 with the terphenyl. That material would be -- and some 3 Q When there were piping failures, what would come 4 recycled catalyst was added because the catalyst was good 4 out of the pipes? 5 for several uses. That was placed in an autoclave, 5 A 1 don't even remember any specific piping 6 hydrogen was introduced into the autoclave through a feed 6 failures. 7 pipe, the pressure was brought up to about 300 pounds in a 7 Q Let's see if we can do this for the muriatic acid 8 very short cycle. 8 operations. Do you recall what those operations consisted 9 It was brought to a hydrogenation level of 40 9 of? 10 percent. That was the reason for the 40 in Hb-40, which we 10 A That was a package absorber. The trade name was 11 would determine by a little measurement that the operators 11 K-a-r-b-a-t-e, Karbate, and it was a package unit sold by 12 could do in the department. And then that was the 12 one of the equipment vendors. 1 don't remember who it was 13 product. It would be taken out of the autoclave and pumped 13 anymore but the process was very simple. The by-product 14 through a filter to recover the catalyst and that was the 14 Hcl gas from Aroclor chlorination came into the department, 15 product. The recovered catalyst would be sent back around 15 went in at one point on the absorber. Water was introduced 16 with the next batch. From time to time spent catalyst, 16 in another place in the absorber. What came out was 17 when it became inactive, would be drawn out of the system 17 muriatic acid. 18 and sent back to the supplier who would recover the metal 18 The crude acid went to a carbon treatment step to 19 values for us. 19 remove any organic material which may have come over in the 20 Q Do you recall there being wastes or residues in 20 Hcl gas from the Aroclor department, and filtered, and that 21 those processes? 21 was the finished product, shipped. 22 A No. 22 Q 1 take it the only raw material was the Hcl? Page 74 Page 76 1 Q There were no liquid, solid -- 1 A Yes, and water. 2 A What we made was sold. There was no by-product. 2 Q Were there any residues created during those 3 Mr. Burnett: Just as a caution, make sure you 3 operations, for example, in the carbon treatment phase? 4 give him a chance to finish his question before you answer 4 A Yes, the spent carbon was a waste. 5 because she can't get it. 5 Q What happened to that? 6 Mr. Brock: It's easier for the court reporter; 6 A 1 don't know. Within the department we put it in 7 that's right. 7 some kind of container and it was carried off. 8 By Mr. Brock: 8 Q Do you recall there being spills or leaks during 9 Q Were there sewers in that department? 9 those operations? 10 A 1 suppose so, to collect rain runoff, but 1 don't 10 A Yes, that was a troublesome operation. Serious 11 remember any waste. 11 corrosion problems because of the nature of muriatic acid. 12 Q Just so I'm clear, you don't recall any solid, 12 When we had piping failures, muriatic acid would go to the 13 liquid or solid or liquid wastes or air emissions from that 13 sewer. 14 department? 14 Q Were there corrosion problems with things other 15 A No, 1 don't remember any. There would be sort of 15 than pipes or was it just pipes? 16 an air emission. At the end of the batch cycle, the vessel 16 A Storage tanks, pumps. It's a very difficult 17 would contain hydrogen under pressure so a valve would be 17 material. 18 opened and the hydrogen let off to the atmosphere. 18 Q When you say difficult, you mean -- you're 19 Q Do you recall there being spills or leaks during 19 referring to the fact that it's corrosive? 20 the Hb-40 operations? 20 A Yes. It's a very ordinary product of commerce 21 A It would be perhaps the way 1 characterized the 21 obviously. 22 Aroclor operation. Sometimes we'd have piping failures but 22 Q And again that was a sewer that went to the Savage, James (Aroclor Dept employee) in AETNA (1) Pages 73 - 76 HARTOLDMONO010089 Page 77 Page 79 1 limestone bed and then to Snow Creek ; is that right? 1 A I'm sure there was somebody but 1 don't remember 2 A That's right. 2 who it was. The main person we worked with on pollution 3 Q Do you recall there being any occasions on which 3 was Cliff Studz from St. Louis. 4 more Hcl was produced than there was a demand for? 4 Q Do you recall having contacts with him during the 5 A Yes. 5 time you were at the Anniston plant about the operations of 6 Q And there was a demand for muriatic acid? 6 the Anniston plant? 7 A Yes, muriatic acid in those days was typically in 7 A Well, 1 worked a lot with Cliff Studz at the time 8 oversupply and it was a challenge for the marketing 8 1 was working on the waste treatment plant for the Niran 9 department to move it all. Most of the time they were 9 department. 1 don't remember talking to Cliff during the 10 successful. 10 time 1 was production supervisor but 1 may have. 11 Q What would happen when the supply of the muriatic 11 Q What was the nature of Cliff Studz's involvement 12 acid outstripped the demand? 12 in the projects that you were doing concerning the waste 13 A 1 don't remember any incident like that. 13 treatment plant? 14 Q Would it be gotten rid of somehow? 14 A He was the process engineer. He was an expert on 15 A As far as 1 can recall, we always were able to 15 waste treatment. 16 get orders. Sometimes we'd have several tank cars backed 16 Q Do you recall there being any claims or 17 up in the yard waiting for orders, but as far as 1 recall 17 complaints about pollution in the area of the waste 18 it was all moved sooner or later. 18 treatment plant? 19 Q During the time that you were at the Anniston 19 A Are you going back to Niran now? 20 plant, either in your chemical engineering positions or as 20 Q Right, during the time that you were at 21 production supervisor, did you have contact with pollution 21 Anniston. 22 control personnel at the Anniston plant? 22 A Complaints from the community? Page 78 Page 80 1 A Do you mean from government agencies? 1 Q Right, or other Monsanto employees? 2 Q No. For example if 1 mentioned the name to you 2 A Sometimes people said the waste treatment plant 3 Eugene Wright, is that a name you recognize? 3 smelled bad and when they said so, they were usually right. 4 A Yes. 4 Q Do you recall there being any claims or 5 Q Bunky Wright, he was referred to or Gene Coley, 5 complaints that there had been emissions of chemicals into 6 do you recognize his name? 6 the soil or water in the area of the waste treatment plant? 7 A Yes. 7 A No. 8 Q Did you have contacts with them during your 8 Q Do you recall -- 9 tenure? 9 A 1 would not be the interface with the public so 1 10 A They were friends. It was a small plant. 10 wouldn't have direct knowledge of such things anyway. 11 Q Fair enough. Do you recall working with them on 11 Q Do you recall there being any lawsuits making 12 any projects that related to the operations of the Anniston 12 allegations of pollution from the Niran operations at the 13 plant? 13 Anniston plant? 14 A 1 remember both Coley and Wright at that time as 14 A Yes. Related to some people in the community who 15 having been in the analytical laboratory. 1 know from 15 complained of damage to the paint on their houses. 16 things that happened later that they took on pollution 16 Q Do you know who the people were? 17 responsibilities, but 1 don't remember that during the time 17 A No. People who lived near the plant. 18 1 was there as production supervisor they actually had 18 Q Was that lawsuit ongoing during the time that you 19 those responsibilities. 19 were at the Anniston plant? 20 Q Do you know whether anybody at the plant had that 20 A Yes. 21 type of responsibility during the time you were production 21 Q Are you familiar with one lawsuit or is it more 22 supervisor? 22 than one? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 77 - 80 HARTOLDMONO010090 Page 81 Page 83 1 A There were several houses, but 1 don't know 1 anybody else besides Mr. Hosmer? 2 whether it was one lawsuit or more than one. 2 A 1 don't remember. 3 Q Do you know how the people claim that their -- 3 Q And you don't recall any of the names of any of 4 strike that. 4 the claimants? 5 They were claiming that paint on their houses had 5 A Oh, no. 1 may have not ever known them. 6 been damaged? 6 Q Are you familiar with any other lawsuits claiming 7 A Yes. 7 pollution or environmental emissions from the operations at 8 Q And they were attributing that to Monsanto, 1 8 the Anniston plant? 9 take it? 9 A 1 don't recall any. 10 A Yes. 10 Q When you were at the Anniston plant, did you have 11 Q Do you recall how it was that they claimed 11 any contacts with any governmental agencies concerning the 12 Monsanto was responsible for that paint damage? 12 operations at the plant? 13 A Well, they claimed that there were episodes when 13 A No. 14 there was a smell of rotten eggs at night and that there 14 Q For example, Osha inspectors or that type of 15 were black patches on the paint the following day. 15 thing? 16 Q Was that lawsuit resolved to your knowledge? 16 A There wasn't any Osha. 17 A 1 think so but that's long ago. 17 Q Or safety inspectors, that type of thing from the 18 Q Were you ever asked to give any information about 18 state? 19 that or in connection with that lawsuit? 19 A Not that 1 recall. 20 A Yes. The Monsanto attorneys wanted pictures of 20 Mr. Burnett: Off the record. 21 the houses and since 1 was at the time an amateur 21 ( Whereupon, at 12: 30 p. m. , the deposition was 22 photographer, the plant manager asked me to get those 22 recessed, to be reconvened at 1: 30 p. m. this same day. ) Page 82 Page 84 1 pictures. 1 Afternoon Session ( 1: 40 p. m. ) 2 Q Do you recall where the houses were located? 2 Whereupon, 3 A They were in a residential area 1 think to the 3 James R. Savage 4 west or north of the plant but 1 couldn't pinpoint it more 4 resumed the stand and, having been previously duly sworn, 5 than that. 5 was examined and testified further as follows: 6 Q Does that refresh your recollection of -- strike 6 Examination ( Continued ) 7 that. 7 By Mr. Brock: 8 Do you recall approximately how many houses you 8 Q Mr. Savage, let's go to the time when you were 9 took pictures of? 9 supervising engineer at the Krummrich plant starting in 10 A 1 think six or eight, but that's very fuzzy. 10 1963. What were your job duties in that position? 11 Q Do you recall whether any individual Monsanto 11 A This again was part of the technical service 12 employees were made defendants in that lawsuit? 12 department, Tsd. 1 had a group of five or six engineers 13 A 1 have no idea. 13 reporting to me and we were doing processing improvement 14 Q Who was the plant manager who asked you to take 14 work in a number of different operating departments at the 15 the pictures? 15 Krummrich plant. 16 A Dez Hosmer. 16 Q Who did you report to? 17 Q Did you provide any other information in 17 A At first to Bill Tafey, who was a process 18 connection with that lawsuit? 18 superintendent in Tsd. 19 A No. That was my only role. 19 Q Where was he located? 20 Q How did you learn of that lawsuit? 20 A That was at Krummrich at that time. 21 A Because Dez told me he needed those pictures. 21 Q Was he at the Anniston plant before that? 22 Q Do you recall discussing that lawsuit with 22 A No, he was at Anniston after that. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 81 - 84 HARTOLDMONO010091 Page 85 Page 87 1 Q And as a supervising engineer in the Tsd 1 Q Was that because the Krummrich plant was a second 2 department, did you report to someone subsequently to Bill 2 plant? 3 Tafey? 3 A Sure. All that was long before my time. 4 A Bill Tafey, when Bill Tafey transferred to 4 Q Of the engineers who reported to you - well, 5 Anniston, 1 was promoted to replace him as the Tsd 5 first of all, did people who you said reported to you, were 6 superintendent and then 1 was reporting to the general 6 those all engineers during the time you were supervising 7 superintendent at the Tsd who was at that time John 7 engineer? 8 Mullendore. 8 A Yes. 9 Q Was Mr. Mullendore at the Krummrich plant? 9 Q Were their responsibilities divided by 10 A Yes. 10 department? 11 Q Do you recall the five or six engineers who 11 A Well, as 1 recall it all involved the chlorine 12 reported to you? 12 departments but there were two separate chlorine cell 13 A Roadway Scott, Herb Mccown. 13 houses and some ancillary facilities, chlorine 14 Q How do 1 spell that? 14 liquification and so forth. 15 A M-c-c-o-w-n, Dan Middleton, John Rodel, 15 Q What is chlorine liquification? 16 R-o-d-e-l, Harry Yapp, Y-a-p-p. 16 A Chlorine as it's produced is a gas and to be able 17 Q What were the -- 17 to ship it or be able to store any large quantity requires 18 A Bill Cramper was one other. These were not all 18 liquifying it, which involves compressing and cooling. 19 at the same time necessarily but over the course of a year 19 ( Savage Exhibit 3 identified. ) 20 or so. 20 By Mr. Brock: 21 Q What were the departments that were under your -- 21 Q Mr. Savage, I've marked as Exhibit 3 a map of the 22 for which you had job duties? 22 Krummrich plant that was previously marked in another Page 86 Page 88 1 A As a supervising engineer it was primarily for 1 deposition. Do you recognize this as a general layout of 2 the two chlorine plants and the two chlorine departments we 2 the Krummrich plant during your tenure there? 3 had at Krummrich, but then when 1 was promoted to 3 A Yes. 4 superintendent, 1 kept those but also had several others. 4 Q If you look at this, does this refresh your 5 Q Do you recall the numbers of the chlorine 5 recollection as to the numbers of the departments that were 6 departments offhand? 6 under your purview during that time? The chlorine 7 A No, 1 knew them once but 1 don't remember. They 7 departments during the time that you were supervising 8 were versions of 232, 1 think, but they had prefixes or 8 engineer? 9 something. 9 A Well, in fact by the time -- this map is dated 10 Q Letter prefixes? 10 1973 -- apparently, 1 think the chlorine plants were gone 11 A 1 think so, 1 don't remember. 11 by then so this is a lot of other things. 1 mentioned that 12 Q Do you have an understanding as to the 12 when 1 became the superintendent 1 also had some other 13 significance of the letter prefixes? 13 operations and some of those are visible here. 14 A Those that started with - that were in the 200 14 Q Were the -- 15 series originally were the Krummrich department. It was an 15 A Well, let me correct that. 1 see a box marked 16 old, old numbering system that described Queeny plant 16 Denora, that was one of the chlorine cell houses. 17 departments and Krummrich plant departments from many, many 17 Q Were the departments under your purview as 18 years ago. 18 supervising engineer, were they called the chlorine 19 Q Did the 200 system, did that - what did that 19 department? 20 mean? 20 A Well, the older chlorine cell house was Hooker 21 A Just that that was a different plant than those 21 diaphragm cells. And a lot of the general plant 22 that were 100. 22 terminology - if someone just said the chlorine plant, Savage, James (Aroclor Dept employee) in AETNA (1) Pages 85 - 88 HARTOLDMONO010092 Page 89 Page 91 1 they would be referring to that one. The Denora cell house 1 Usually if the wet chlorine piping developed a leak, the 2 would either have been called Denora or the mercury cells, 2 normal operation was to run that entire system at a slight 3 which was a separate operation. 3 vacuum, partly because that was convenient for gas handling 4 Q So the Denora cell house was under your purview 4 but also as a safety measure since chlorine is dangerous. 5- 5 So if there were leaks in the wet chlorine piping, the 6 A Oh, yes. 6 problem would be manifested by air getting into the system 7 Q -- as supervising engineer? 7 and the gas steam diluted, which was undesirable. So there 8 Was the chloro-alkali department under your 8 was always a substantial annual maintenance expense to keep 9 purview? 9 repairing piping because we couldn't tolerate a lot of 10 A That's another term for the same thing. 10 inert air in the chlorine. 11 Q So if 1 mentioned Department 231, does that 11 Q Were the Denora operations, those were part of 12 refresh your recollection or does that ring a bell at all? 12 the chlorine operation ; is that correct? 13 A No. 13 A Yes. But the Denora cell house was much newer. 14 Q Do you recall what type of process improvement 14 It was built sometime in the early ' 60s. It was completed 15 projects you worked on with regard to the chlorine 15 and started up at the time that 1 arrived at the Krummrich 16 operations as a supervising engineer? 16 plant but it had only been in operation for a year or two, 17 A The time that 1 arrived there was a project 17 whereas the Hooker diaphragm cells were much older. 18 underway to improve gas cooling and handling from the 18 Q As a supervising engineer, did you work on any 19 diaphragm cells. That was completed a few months after 1 19 projects addressing possible changes in any waste disposal 20 arrived there. We did some projects in the brine area at 20 methods at the Krummrich plant? 21 Denora. It was a relatively new operation but we were able 21 A Yes. 1 mentioned a project in the brine area at 22 to devise a significant improvement in the brine area that 22 Denora. There was some problem in some dissolved chlorine Page 90 Page 92 1 improved the chlorine yield, eliminated some difficult 1 in wastewater from the brine area. And the replacement 2 pieces of equipment. 2 system that we put in essentially eliminated that problem 3 Q What was the effect of improving the gas cooling 3 by recovering the chlorine gas from the water stream and 4 and handling in the chlorine operations? 4 recycling it into the main chlorine stream. 5 A That was largely a matter of improving the 5 Q Where did the wastewater with the dissolved 6 reliability, wet chlorine - chlorine as it's produced from 6 chlorine go? 7 the cells is wet and as a wet gas it's extremely 7 A Into the general plant sewers. 8 corrosive. And the older technology for cooling the warm 8 Q These were sewers from the process areas? 9 wet chlorine gas was to use coolers using Pyrex tubes with 9 A Yes. 10 cooling water in them. They were subject to breakage and 10 Q Do you recall what those sewers were called? 11 had very poor capacity. And by that time, metal titanium 11 A 1 have no idea. 12 had become readily available as an economic material for 12 Q Were those the sanitary sewers? 13 construction and permitted significant improvements in 13 A 1 don't know. That term normally implies human 14 reliability and economics of all of the wet chlorine 14 waste, but 1 don't know whether that term was used at 15 handling. So that was just a general trend going on at 15 Krummrich at that time or not. 16 that time was to replace older equipment with titanium 16 Q Do you know where the sewers went? 17 equipment. 17 A Well, eventually to the Mississippi River, 1 18 Q Had corrosion of the equipment in the chlorine 18 suppose, but by what route, through what kind of treatment, 19 department, did that lead to leaks and spills from time to 19 1 don't know. 20 time at the Krummrich plant? 20 Q Did you work -- as a supervising engineer, did 21 A Well, spills is kind of an imprecise word when 21 you work on any projects relating to the sewers? 22 you're speaking of a gas. It was a matter of reliability. 22 A No. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 89 - 92 HARTOLDMONO010093 Page 93 Page 95 1 Q As superintendent of Tsd, were you involved in 1 wet as a gas and it was processed in a similar way. The 2 any projects that related to the sewers? 2 brine area per se was simpler because the brine was used in 3 A Let me clarify. 1 was not superintendent of all 3 a kind of once-through way. That is, each time the brine 4 of Tsd. John Mullendore was superintendent for all of Tsd, 4 went in, it was converted to cell liquor. There was no 5 but 1 was what was informally called the group leader. 5 recycled brine stream per se. 6 John Mullendore was called the superintendent, but 1 was 6 Q Can you mark for me where the brine area is on 7 not responsible for the entire plant. 1 had about a 7 Exhibit3. You can just mark an X by the brine area. 8 quarter of it for technical work, not for production. 8 A I'm sorry, 1 can't. 1 don't know where. It's a 9 Q During the time that you were a group leader of 9 long time ago and most of those things have been torn down. 10 Tsd at the Krummrich plant, were you involved in any 10 Q Were there wastes or residues that were created 11 projects that related to sewers at the plant? 11 in the operations of the Denora cell houses? 12 A No, 1 don't think so. Ordinarily projects 12 A That was no different than Anniston. Spent 13 related to the sewers per se would be managed by the 13 anodes that would be thrown away. 14 maintenance department. 14 Q Anything else that you recall? 15 Q As supervising engineer did you become familiar 15 A The brine area for Hooker was different and 1 16 with the operations of the chlorine department? 16 recall that there was a sludge that was called gyp, g-y-p, 17 A Certainly. 17 by the people in the plant because it was, a substantial 18 Q Can you just briefly describe what those 18 part of it was sodium sulfate, which is called gypsum or 19 operations consisted of in the same way that you did for 19 calcium sulfate, maybe. This was just impurities from the 20 the various -- 20 rock salt and this material would be drawn off from time to 21 A 1 mentioned that one of the cell houses was 21 time. 1 don't remember what was done with it and 1 don't 22 Denora. Again that's a proprietary design of Denora in 22 remember whether there was a similar material from the Page 94 Page 96 1 Italy. The cells and so forth were made in Italy, imported 1 Denora plant or not. 2 and that operation, other than being four or five times as 2 Q Let's go to the time that you were group leader 3 large, was technically pretty much the same as the mercury 3 in Tsd at the Krummrich plant. What departments were undei 4 cell operation at Anniston. The other cell -- including 4 your purview during those years? 5 the fact that they were both sodium chloride and potassium 5 A Still the chlorine plants. In addition, the 6 chloride loops. The other cell house, the Hooker diaphragm 6 Aroclor department, the nitroanilines department, 7 plant, might superficially seem similar but in detail was 7 chlorobenzenes, nitrochlorobenzenes and some small 8 considerably different. The cells were much smaller and 8 nitration products. Nitrated dodecylbenzene, some other 9 there were a large number of them and brine was fed to one 9 small products made by nitration. 10 compartment of the cell. 10 Q Can you just read that back. 11 There was a diaphragm which made a deposit of 11 A At one time the phenol department which was a big 12 asbestos which separated the brine compartment from another 12 monstrous thing. 13 compartment. And in passing through the diaphragm under 13 ( The reporter read the record as requested. ) 14 the influence of the electronic current, the brine was 14 By Mr. Brock: 15 converted to something called cell liquor which was a 15 Q Did the nature of your job duties change when you 16 solution of both salt and caustic soda mixed together. And 16 switched from being supervising engineer to group leader of 17 then there was a large area where the cell liquor was 17 Tsd at the Krummrich plant? 18 concentrated and the salt crystallized out to form the 18 A Not really, just a few more engineers and more 19 product, caustic soda. 19 departments to be responsible for. 20 So the caustic soda side of that department was 20 Q So you still worked on process improvement? 21 much more complicated, used a large amount of energy. The 21 A That's right. 22 chlorine came off the cells in the same way. It was hot, 22 Q Let me go back to the time when you were Savage, James (Aroclor Dept employee) in AETNA (1) Pages 93 - 96 HARTOLDMONO010094 Page 97 Page 99 1 supervising engineer. Do you recall working on any other 1 from the Aroclor operations? 2 projects relating to the method of waste disposal or wastes 2 A Yes. It's the same material we talked about 3 other than the one that you talked about earlier involving 3 earlier. 4 chlorine and the wastewater? 4 Q Do you know how that was disposed of at the 5 A No, 1 don't remember. 5 Krummrich plant during that time? 6 Q Do you recall any of the process improvement 6 A No, 1 don't. 7 projects that you worked on regarding the Aroclor 7 Q You described a project that Dan Middleton worked 8 operations at the plant? 8 on as somehow isolating the system. Can you describe for 9 A 1 think there were quite a few but of course at 9 me what the change was? 10 that time being responsible for a number of engineers, it's 10 A 1 don't remember it in detail. It involved a 11 more difficult to remember individual projects. Dan 11 roller conveyor and some hoods, but 1 don't remember any 12 Middleton was working for me in the Aroclor department at 12 more detail than that. 13 that time and 1 remember one project of his related to 13 Q What was Dan Middleton's position, was he an 14 improving the drumming out of the still residue. 14 engineer? 15 Q Can you describe that project for me? 15 A Yes, chemical engineer. 16 A Well, it came to me as a work order from the 16 Q Do you recall who the other engineers were who 17 production supervisor. He was dissatisfied with the method 17 reported to you when you were group leader in Tsd? 18 of handling still residue because he thought it might be 18 A Bob Fields, Roger Spiller, Tony Angoli, 19 hazardous to the workers because they were working directly 19 A-n-g-o-l-i. 1 think there were a couple of others, but 1 20 with drums, very hot material. And Dan designed a system 20 don't remember their names. 21 that isolated the workers from the material and to a modest 21 Q Were those engineers in separate departments? 22 degree automated the way it was done. 22 A They were part of the technical service Page 98 Page 100 1 Q Do you recall who the production supervisor was 1 department but -- 2 at that time? 2 Q Were they assigned -- 3 A Woody Martin, E. E. Martin. He was Elwood, 1 3 A 1 would have each of them assigned to some 4 think. 4 specific department. 5 Q Is he the person who came to you with the work 5 Q Do you recall what department Bob Fields was 6 order regarding the still residues? 6 assigned to? 7 A 1 presume so because he was the production 7 A Yes, he was in the nitroanilines department. 8 supervisor at the time but 1 don't know specifically that 8 Q Do you recall offhand what that department was? 9 he was. 9 A Pardon me? 10 Q Do you recall what the production supervisor said 10 Q Do you recall offhand what that department was? 11 to you regarding whether the still bottoms -- strike 11 A That's 222. There were two of them. There was 12 that --whether the Aroclor could be hazardous to the 12 an O and P. Orthonitroaniline and paranitroaniline. 13 workers? 13 Q Ona and Pna? 14 A 1 have no idea what he said. 14 A Correct. 15 Q When that type of thing came to you, what did you 15 Q What about Roger Spiller, what department was he 16 do with it, what was the process? 16 assigned to? 17 A Sometimes it would come as a verbal request and 1 17 A The nitrochlorobenzenes. 18 would write up the work order myself or more commonly the 18 Q It's easier for me to pronounce the 19 production supervisor would write up the work order. If 1 19 abbreviation -- 20 agreed that it was a sensible project, 1 would sign off on 20 A Neb, Pncb. 21 it and assign it to one of the engineers. 21 Q Do you recall what numbers those were? 22 Q The still residues, that was a waste material 22 A 221. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 97-100 HARTOLDMONO010095 Page 101 Page 103 1 Q What about Tony Angoli, what department was he 1 Pncb or Oncb department, Department 221? 2 assigned to? 2 A Again, there were a number of small projects but 3 A He worked in the phenol department for a while. 3 we did have one fairly big project, which started out as 4 He only worked for me for a short while. He wasn't 4 what was called a debottlenecking project, that's a common 5 successful with the company. 5 term in the chemical business for relatively small projects 6 Q Why was that? 6 that can have a significant leverage on capacity. And the 7 A He wasn't a very good engineer. 7 original concept was that essentially the work order that 8 Q Do you recall any other process improvement-type 8 we were given was to add a fourth nitrator. There were 9 projects that you worked on with regard to the Aroclor 9 three nitrators at the time and we were to add a fourth one 10 department at that time? 10 to increase the capacity. 11 A No. I'm sure there were a number of them, but 1 11 We were able to come up with a different solution 12 don't remember any specific one. 12 of adding another step, a stripping still to remove 13 Q What about the nitroaniline department, do you 13 unreacted monochlorobenzene, which was one of the raw 14 recall any specific process improvement projects that you 14 materials. The project was actually installed by organic 15 were involved in with regard to that department? 15 engineering, division engineering group because it was 16 A There was a major project which Bob Fields 16 larger than the normal scope of a plant project but it was 17 handled and which was not completed during my time there in 17 a way of getting the desired capacity and improving the 18 which we set out to develop a new, continuous process to 18 yield at the same time. 19 replace the old batch process. But during my time there, 19 Q You mentioned the unreacted -- and 1 thought you 20 it only got as far as pilot plant. 20 said monochlorobenzene? 21 Q Were there any changes to the waste disposal 21 A Monochlorobenzene is one of the raw materials to 22 methods that you recall in that department during the time 22 make nitrochlorobenzene. Page 102 Page 104 1 you were there? 1 Q Was that a residue, the unreacted Neb? 2 A There was a waste stream from that department 2 A No, it's more complicated than that. To make 3 that contained ammonia -- ammonia is one of the raw 3 nitrochlorobenzene it requires a reaction between nitric 4 materials to make nitroanilines -- and we had some kind of 4 acid and monochlorobenzene, and it's rather difficult to 5 a program to improve the ammonia recovery from the 5 drive that reaction to completion. And therefore, there's 6 wastewater since that was a raw material that was 6 a small amount of unreacted monochlorobenzene left in the 7 undesirable to lose it to wastewater. 1 don't remember the 7 crude nitrochlorobenzene. And that monochlorobenzene would 8 nature of the project though. 8 stay with the product through the refining stage and 9 Q Where did that wastewater stream go? 9 eventually wound up in a fraction that was discarded but 10 A It went into the general plant sewers. 10 which consisted of metanitrochlorobenzene and a lot of 11 Q Do you recall there being any complaints about 11 other strange and undesired molecules. 12 ammonium going into the wastewater or the plant sewers? 12 Q How was that discarded? 13 A 1 think there were some local complaints within 13 A 1 don't know. That was part of-it was handled 14 the plant just due to the odor of ammonia coming out of the 14 like a still residue, but 1 don't know where it went. 15 sewers. But that as far as 1 know didn't leave the plant 15 Q And the still residues were taken off the plant 16 boundary, the problem didn't. 16 by shipping, to your knowledge? 17 Q Were there other waste streams from the Ona or 17 A As far as 1 know. 18 Pna operations? 18 Q Do you recall working on any projects relating to 19 A 1 think there were but 1 don't remember what they 19 waste streams or waste disposal from Department 221 during 20 were. 20 that time? 21 Q Do you recall what type of project or process 21 A No. 22 improvement project you worked with with regard to the Neb, 22 Q Do you recall working on any or being involved in Savage, James (Aroclor Dept employee) in AETNA (1) Pages 101 -104 HARTOLDMONO010096 Page 105 1 any projects regarding waste streams or waste disposal from 2 the phenol department at that time? Page 107 1 during -- 2 A Not a specific project. 1 knew them very well of 3 A 1 was only briefly involved with the phenol 3 course but 1 don't remember any particular project. 4 department. 1 only worked in a small part of it. 4 Q Were any claims or allegations of pollution or 5 Q What small part was that? 5 contamination from the departments under your purview 6 A 1 don't even remember. 1 left out another name. 6 brought to your attention at any time? 7 Ed Stewart worked for me during that time. Ed was a 7 A 1 don't remember anything specifically. 8 supervising engineer and he had working for him some people 8 Q What were your job duties as head of-strike 9 who worked in the phenol department, Tony Angoli was one o : 9 that. 10 those. And at some point as part of some reorganization Ed 10 1 believe you told me from 1967 to 1970 you were 11 reported to me but 1 didn't get very closely involved in 11 head of Tsd at the Queeny plant? 12 what was going on in the phenol department. 12 A That's right. 13 Q Did you become familiar with what the wastes 13 Q What were your job duties in that position? 14 were, if any, from the phenol department? 14 A We had three process groups, each headed by a 15 A ( Nonverbal response. ) 15 superintendent, which was like the job that 1 left at 16 Q She needs a verbal response just for the record. 16 Krummrich plant. One group 1 think we called plantwide 17 A No. 1 just broadly understood the function, 17 engineering or something like that. It's mechanical 18 that's about it. 18 engineers, and a small pollution group and the analytical 19 Q What about from the Neb, Pncb -- the 19 laboratory, chief chemist and group technicians reported to 20 chlorobenzene department, did you come to an understanding 20 me and we had a small process research group of chemists in 21 of what the wastes were from that department? 21 the laboratory. A total of about 150 people. 22 A Just roughly. It made by-product Hcl, which was 22 Q What were the process groups involved? Page 106 Page 108 1 used to make muriatic acid, much like the Hcl from 1 A These were mainly chemical engineers, again, 2 Aroclor. There was a still bottom from the final step, the 2 assigned to various production departments to do process 3 distillation of dichlorobenzene, but I've just said most of 3 improvements. 4 what 1 know about it. 4 Q Do you recall what the operations were? 5 Q Do you know what was done with the still bottoms? 5 A Well, that was the whole Queeny plant, everything 6 A No, 1 don't. 6 was made at the Queeny plant. 7 Q Do you know what they consisted of chemically? 7 Q So the whole Queeny plant was under your- 8 A Higher chlorinated materials in general. 8 A Technical work, the whole Queeny plant was mine. 9 Trichlorobenzene, tetrachlorobenzene. 9 That's not completely true because we had some guest 10 Q Do you recall working with the pollution control 10 operations from other divisions. The only one 1 remember 11 group at the Krummrich plant during the time, the ' 63 11 for sure is the agricultural division had an operation in 12 to ' 67 time frame that you were there? 12 there. 1 believe at that time they had a separate 13 A Well, 1 knew the people, Paul Hodges and-- 13 organization. I'm not very clear about that. 14 Q Clarrie Buckley, was he there around that time? 14 Q During that time frame did you have any 15 A Clarrie Buckley succeeded Paul. Clarrie had been 15 responsibilities with respect to the Krummrich, Anniston or 16 production supervisor of nitrochlorobenzenes at the time 16 Nitro plants? 17 that 1 arrived at the plant. But at some point Paul Hodges 17 A No. 18 moved on to the general office and 1 don't know whether 18 Q Are you familiar as a general matter with wastes 19 Clarrie Buckley overlapped with him or succeeded him but 19 being taken from the Queeny plant to something called the 20 Clarrie went from production into pollution control work. 20 Krummrich landfill? 21 Q Do you recall working with any of the pollution 21 A 1 was aware that that was done. 22 control personnel at the Krummrich plant on any projects 22 Q When you say you were aware, you mean during the Savage, James (Aroclor Dept employee) in AETNA (1) Pages 105-108 HARTOLDMONO010097 Page 109 Page 111 1 time that you were head of Tsd at the Queeny plant? 1 then can be crystallized. So this complicated separation 2 A Yes, yes. 1 was aware that things like still 2 step was a specialty operation at the Queeny plant which 3 residue from Queeny went to Krummrich. 3 separated the 221 oil to recover some more useful ortho and 4 Q And still residue from what? 4 para streams and to reject what was called the metafraction 5 A A lot of different things. Distillation is a 5 which was the stream that was beyond further separation by 6 very common purification step in chemical operations and 6 an economical method. A very small fraction of the 7 there usually is a still residue. 7 original amount of material made and everything that we did 8 Q You're referring to residues that were left at 8 in that department at Queeny was shipped back to Krummrich 9 distillation processes? 9 including the metafraction, which was waste. 10 A Yes. 10 Q You're right, it is complicated. 11 Q Do you have any recollection as to what the still 11 A 1 could give you a whole semester. 12 residues were that were taken to the Krummrich plant? 12 Q The still residues that went back to the 13 A The only one 1 remember, just because 1 had a 13 Krummrich plant from the Neb operations at the Queeny 14 little familiarity with it, was still residue from 14 plant, was that the metafraction that you talked about or 15 nitrochlorobenzene operations. There was a small 15 was that something else? 16 nitrochlorobenzene operation at Queeny that handled one 16 A No, metafraction was not a still residue. 1 17 by-product stream from Krummrich. 17 don't remember how exactly it arose. It was a complex of 18 Q When you say the Queeny plant handled one 18 crystallization and distillations done batchwise. The 19 by-product stream from Krummrich, by by-product stream 19 whole sequence of operations took about a month. 20 you're not referring -- are you referring to the still 20 Q What did the still residues from the Neb 21 residue? 21 operations that were taken back to the Krummrich plant 22 A No. This was a stream that at the Queeny plant 22 consist of? Page 110 Page 112 1 was called 221 oil because it came from Department 221 at 1 A In general materials that had been nitrated to a 2 Krummrich, nitrochlorobenzene department. The --this is a 2 higher level than nitrochlorobenzene so it could be things 3 fairly complicated subject. 3 like dinitrochlorobenzene and so forth. 4 The manufacture of nitrochlorobenzenes results in 4 Q Did you have any responsibilities during those 5 making a mixture of three isomers, which are superficially 5 years for the Anniston or Nitro plants? 6 the same molecule but with slightly different structure. 6 A No. 7 They're called ortho, meta and para. 7 Q What were your job duties as a manufacturing 8 Paranitrochlorobenzene, Pncb, is generally the desired 8 manager in the 1970 to 1975 time frame? 9 material because it's needed for some downstream products. 9 A 1970 1 became part of a new matrix organization. 10 Orthonitrochlorobenzene has some uses. 10 At that time 1 reported to the director of manufacturing, 11 Metanitrochlorobenzene might have some uses but the amount 11 Fred Holzapfel, H-o-l-z-a-p-f-e-l. Each of the 12 that's made is uneconomically small, and so we never 12 manufacturing managers was assigned to a specific business 13 isolated it for sale. In the separation of these isomers 13 group and was responsible for being sure that manufacturing 14 at the Krummrich plant by a combination of distillations 14 satisfied the needs of that business group from whatever 15 and crystallization, material was left which would normally 15 plants made the products of that business group. 1 was 16 be called a eutectic, e-u-t-e-c-t-i-c, and this is what the 16 assigned the specialty products group which was led by 17 Queeny plant called 221 oil. 17 Howard Bergen, he was business group director. Then about 18 What that term " eutectic oil" refers to is it's a 18 two years later the organization was changed somewhat so it 19 material that has reached a stable composition with respect 19 was no longer a matrix and 1 from then on reported directly 20 to crystallization and it's impossible to separate it 20 to Howard Bergen and had a dotted-line relationship to Fred 21 further by crystallization. 21 Holzapfel. 22 So it has to be distilled into fractions which 22 Q What plants were in the specialty products group Savage, James (Aroclor Dept employee) in AETNA (1) Pages 109-112 HARTOLDMONO010098 Page 113 Page 115 1 at that time during the first period of time when you said 1 Q How did you first learn about the issue of water 2 that was under your purview? 2 pollution with respect to Pcbs? 3 A Well, specialty products group never had all of 3 A Through outside reading at a time when 1 had 4 any one plant, but we had products in a number of different 4 nothing to do with it. Sometime in the late ' 60s some 5 plants. We had Aroclor at Anniston and Nitro and at 5 papers were published by Professor Riseborough at one of 6 Newport in Wales. 6 the California universities in which he described his 7 Q Did you have Aroclor at the Krummrich plant? 7 discovery that chlorinated biphenyls were affecting the 8 A Yes. And we had phosphate esters and hydraulic 8 raptors, carnivorous birds, specifically the peregrine 9 fluids at the Queeny plant and heat transfer fluids at 9 falcon. And 1 remember being astonished by that since 10 several plants. We had a specialty latex product at 10 those were products 1 had previous experience with. 11 Texas City and after a year or two, there was a further 11 Q Do you recall what university Professor 12 reorganization and we picked up the paper chemicals. So 12 Riseborough was at? 13 then we had mersize at Nitro and at Lasalle in Quebec. And 13 A 1 don't know, but it's very famous. 14 we were involved with a small Aroclor unit that ran for a 14 Q Do you recall when you read those -- when you 15 short time in a joint venture in Japan with Mitsubishi and 15 read his papers? 16 pentachlorophenol at Krummrich and at Newport, sodium 16 A Not exactly, but it would have been 1968 or 1969, 17 pentachlorophenate which we call Santobrite at both of 17 1 should think. 18 those places. 18 Q Was it during a time that you were at the Queeny 19 Q And those were again at Krummrich and Queeny? 19 plant? 20 A Krummrich and Newport in Wales. 20 A 1 think so. 21 Q And the pentachlorophenol was at what plants 21 Q What did you do after you had read the papers? 22 again? 22 What did you do with the information? Page 114 Page 116 1 A Krummrich and Newport. 1 A Well, 1 asked some of my scientist friends who 2 Q Did people at the plant level at the various 2 had something to do with Aroclors what they knew about it 3 plants report to you? 3 and whether they thought that the work was valid. And they 4 A Not directly. 1 had a dotted-line relationship 4 were quite familiar with it and said yes, as far as they 5 to one of the plant operating superintendents at each 5 could tell, it was valid. 6 plant, but formally each of them reported to the plant 6 Q Do you recall who it was, which scientists it was 7 manager at the site. 7 you asked? 8 Q Do you recall who the plant superintendent was, 8 A 1 have no idea. 9 with whom you had a dotted-line relationship at the 9 Q Were they scientists within Monsanto? 10 Krummrich plant? 10 A Yes, oh, yes. 11 A No, 1 don't remember. I'm surprised that 1 don't 11 Q Were they at the Queeny plant, do you know? 12 remember. 12 A No. 13 Q What about the Anniston and Nitro plants, do you 13 Q Were they in Creve Couer in St. Louis? 14 recall who -- 14 A 1 should think so but 1 don't remember for sure. 15 A At Anniston at first was Jesse Corder and later 15 1 only remember that 1 did that just because 1 had been so 16 on Hill Williams. At Nitro it was Dave Tippee. 1 remember 16 surprised by the article. 17 at Krummrich. It was Bill Corlew. 17 Q Do you know whether anybody else within Monsanto 18 Q Did you get involved in waste disposal matters at 18 had read those articles? 19 the various plants during the 1970 to ' 75 time frame? 19 A Oh, they were way ahead of me. They had 20 A Well, yes. By that time the Pcb issue had arisen 20 apparently been in contact with Dr. Riseborough. 21 in full force and the questions of particularly water 21 Q When you say they -- 22 pollution had become quite urgent. 22 A Whoever it was 1 talked to. It was somebody in Savage, James (Aroclor Dept employee) in AETNA (1) Pages 113-116 HARTOLDMONO010099 Page 117 1 research. 2 Q Do you recall the position of the person who you Page 119 1 how much Pcb was being lost to the sewers, if any, at the 2 various sites, and where we did find that there were Pcbs 3 talked to in research? 4 A No. 5 Q Did anybody you talked to question the validity 6 of Dr. Riseborough's works with respect to Pcbs at that 7 time? 8 A Not really. They said that it looked like his 9 work was valid. 10 ( Recess. ) 11 ( Savage Exhibits 4 through 29 12 identified. ) 13 By Mr. Brock: 14 Q For the record I've just had marked as Exhibits 4 15 through 29 some documents. To a certain extent, 16 Mr. Savage, I'm going to be asking you questions about 17 individual documents. But some of the documents are of the 18 same subject matter. So I'm going to be asking you about 19 them also as a group. I'd like to first ask you to turn to 20 what 1 marked as Exhibit 4 and after you've had a chance to 21 glance through it, tell me what it is. 22 ( Witness reviewed thedocument. ) 3 going to the sewers, figure out where they came from and 4 what we might do about it. So each of the plants that 5 might have been involved was writing something like this. 6 1 don't know when each of them started but this was a very 7 important part of what all of us were doing at that time. 8 Q When you say that was given urgent priority, why 9 was that? 10 A Well, this did in fact come out of 11 Dr. Riseborough's work. As the scientific community looked 12 at his work within Monsanto and elsewhere, it appeared that 13 the Pcbs were found in the environment, that they did not 14 biodegrade or at least certain components of Pcbs did not 15 biodegrade. They biomagnified in the food chain and 16 therefore were having a adverse effect on those animals 17 that were at the end of the food chain, primarily the 18 raptors. Dr. Riseborough's work was on the peregrine 19 falcon. 20 Q If you look at the subject line of this it reads 21 " Status of Aroclor pollution control." Do you see that? 22 A Yes. Page 118 Page 120 1 A It's a monthly report by Bob Mccutchan addressed 1 Q And some of the other exhibits also have that 2 to Bill Papageorge reporting on Aroclor pollution control 2 same heading, for example, Exhibit 5 and Exhibit 8. Do you 3 for the month of May 1970. 3 see that? 4 Q You see that you're a copy recipient on that; do 4 Mr. Burnett: At the bottom of 5? Maybe my 5 you see that? 5 numbers are wrong. 6 A That's right. 6 The Witness: Number 5 is Bill Corlew's memo to 7 Q When did monthly reports like this first -- 7 me. 8 regarding Aroclor pollution control -- first start being 8 Mr. Brock: My numbering must be wrong. What is 9 reported to your knowledge? 9 Number6? Is Number 6 dated June 10? 10 A Well, before 1 became manufacturing manager 10 The Witness: 6 is titled " June report by 11 obviously. This is dated May 1970 and it's no more than a 11 Mccutchan." 12 month after 1 began those duties. It's a little strange as 12 By Mr. Brock: 13 a matter of fact because it's dated May 8 and it purports 13 Q It's Number 6 then. So Number 6 and Number 8 14 to be a May report. So there's something a little wrong 14 also have that heading. Do you see that? 15 there. It's probably an April report. 15 A Yes. Mr. Mccutchan was a little fouled up again 16 Q 1 see what you're saying. What was - do you 16 because the memo dated June 10 is titled June report and 17 recall what the impetus was for the initiation of these 17 then the memo dated July 3 is also entitled June report. 18 monthly reports? 18 So- 19 A Well, at the time that 1 joined the business 19 Q He corrected himself maybe? 20 group, 1 found that Pcb questions had already developed a 20 A 1 think he was a month out of phase on the 21 fairly urgent priority. And at the time we were simply 21 earlier one. 22 trying to find out where we stood at the various plants, 22 Q Was this a particular program to keep track of Savage, James (Aroclor Dept employee) in AETNA (1) Pages 117-120 HARTOLDMONOOIOIOO 1 Pcb discharges from the plants? 2 A Oh, yes. Page 121 1 2 Page 123 Q What led to the unreliability? A Just the way that the sample was taken. When the 3 Q What was your -- what was the nature of your 3 issue first arose, naturally the first thing that anyone 4 involvement in that program? 4 would do is simply dip a sample bottle in a stream and take 5 A Well, since 1 had manufacturing responsibility 5 it to the laboratory and we found that the results were 6 for the business group, it was my job to be sure that the 6 very erratic, that samples that were taken under similar 7 plants did this, developed reliable information on Pcb 7 conditions and therefore should have resulted in similar 8 losses and developed programs to eliminate them to the 8 numbers instead gave us numbers all over the map and we 9 degree that we could. 1 think 1 should mention that this 9 eventually refined sampling methods to where we could get 10 is written within the capabilities of 1970 and that the 10 more consistent and believable results. 11 numbers that we were reporting at that time probably are 11 Q How were the sampling methods refined? 12 unreliable, perhaps incorrect, because over the course of 12 A Typically by putting a probe in the stream 13 succeeding months, we discovered that sampling methods and 13 pointed upstream where the sampling velocity was controlled 14 analytical methods were not as reliable or as accurate as 14 so it would be the same as the velocity in the stream so 15 we had thought and we refined these numbers to a 15 that the sample point from top to bottom in the stream was 16 substantial degree over the course of the next year or 16 at the right place to be a representative sample and what 17 two. So while the programs described here are valid, the 17 else, there's a lot of careful things like that that have 18 numbers are not necessarily valid. 18 to be done but continuous sampling is always more reliable 19 Q Do you recall a change in testing methodology 19 than simply grabbing a sample with a bottle. 20 leading to more reliable measures? 20 Q Who gave you the assignment of developing 21 A It was more -- well, there may have been changes 21 reliable information about Pcb discharges and developing 22 in testing. 1 would not have been directly involved in 22 programs to eliminate them? Page 122 Page 124 1 that but 1 was reasonably conversant with sampling 1 A Well, controlling Pcbs as part of the 2 problems. Since Pcbs are pretty insoluble in water, the 2 manufacturing responsibility was part of my initial lineup 3 Pcb content of a water sample is highly affected by the way 3 on what 1 was there for when 1 joined the business group, 4 that the sample is taken and that's because, particularly 4 because just in terms of understanding what's important 5 in wastewater there's usually some small amount of final 5 today in this business, that was a big part of it. As to 6 divided solids. Since the Pcb is insoluble in water, it 6 the business of getting more reliable numbers, 1 suppose 1 7 tends to attach to the solid particles and therefore unless 7 assigned that to myself because 1 discovered 1 couldn't 8 the sample is carefully taken to capture a representative 8 believe what 1 was seeing. But we got some good work done 9 number of the solid particles that are present, then the 9 at all the plants to get better numbers. 10 sample becomes fairly meaningless. Then there is a 10 Q How did it come about that you switched or you 11 substantial science to take a sample correctly. 11 moved from being head of the Tsd department at the Queeny 12 Q Do you know what was done in the earlier phases 12 plant to manufacturing manager in the general offices? 13 of the project that led to -- or that may have led to 13 A Right. And that was about April 1970. 14 unreliability and what specifically was done to alleviate 14 Q How did that come about? 15 that situation? 15 A Fred Holzapfel was brought in as director of 16 A 1 don't know what might have gone before this 16 manufacturing, 1 think to replace Ray Strafmeyer who left 17 time in 1970. 17 the company. I'm not sure he left just then, but Fred came 18 Q 1 thought you said that some of these numbers 18 in to take over manufacturing sometime perhaps six months 19 might be unreliable? 19 or so earlier than that and he spent a period of several 20 A Oh, yes. They certainly were unreliable at this 20 months studying the organization and figuring out how he 21 time, but it was then later on we learned better ways of 21 wanted to organize it and who he wanted and when he set up 22 taking samples. 22 his new organization, he invited me to be one of the new Savage, James (Aroclor Dept employee) in AETNA (1) Pages 121 -124 HARTOLDMONOOIOIOI Page 125 1 manufacturing managers. 2 Q Did the subject of Pcb releases come up? Let me 1 doing with regard to the process? 2 A Yes. Page 127 3 go back a second. Did you interview for the position in 3 Q Did you talk to him about the project or the 4 the general offices, is that how it worked? 4 Aroclor pollution control and I'm going to use the word 5 A Well, yes, but 1 didn't know it at the time. 5 program at this point for want of a better word? 6 Fred came around to all the plants and talked to all the 6 A He was an old friend and his office was right 7 general superintendents. Afterwards 1 compared notes with 7 around the corner so we discussed it. That was part of my 8 my friend who was the general superintendent of maintenance 8 indoctrination in a new job. 9 and he said he felt he was being interviewed for his 9 Q Did people at the plants report to you concerning 10 present job, but at any rate after Fred got through with 10 Aroclor releases from their plants? 11 that long process, he simply said this is the way it's 11 A Yes. It was a dotted-line kind of thing, but 12 going to be. 12 they did report to me. 13 Q When he came around and talked to you, did the 13 Q Do you recall who it was from the Krummrich 14 subject of Pcb releases from the plants come up? 14 plant? 15 A 1 have no idea what came up. He was an old 15 A It was Corlew -- 1 think at one time it was also 16 friend. He was the one that had hired me in 1957. 16 Art Leisy, but I'm a little fuzzy about who came before or 17 Q As manufacturing manager, did you report to 17 after who. Mccutchan worked for Corlew. 18 someone on the status of Aroclor pollution control steps by 18 Q What plants were being examined with regard to 19 Monsanto? 19 Pcb? 20 A By that time Bill Papageorge was -- 1 don't 20 A The three that manufactured Pcbs were Anniston, 21 remember what his title was but he was the focal point of 21 Krummrich and Newport and any place that we used Pcbs was 22 all the Pcb work and so when 1 first became manufacturing 22 also under some scrutiny. Page 126 Page 128 1 manager, my formal reporting relationship was to Fred 1 Q Did you undertake to familiarize yourself with 2 Holzapfel, later on to Howard Bergen and matters relating 2 the locations of the Pcb releases at the various plants? 3 to Pcb problems we all worked with Bill Papageorge and 3 A Yes, 1 had regular reviews with the plant people 4 reported to him what was going on. 4 to talk about how the program was going, encourage them to 5 Q Did you report on the subject of Aroclor 5 keep tracking down all the sources and if a capital project 6 pollution control to anybody other than Mr. Papageorge 6 was required above a certain size, they would need to come 7 during your tenure as manufacturing manager? 7 to me for approval of the project. 8 A Well, of course Howard Bergen was always very 8 Q What size was that? 9 interested in what was going on, it was his business. And 9 A 1 don't remember exactly but the plants could 10 so from a formal standpoint, 1 would report to Howard but 10 only approve projects up to a certain size, probably 3 - or 11 it was understood that Bill was the coordinator on 11 $5000 or something like that and 1 had an approval level 12 everything having to do with Pcbs. 12 that was higher than that. If it was above my approval 13 Q Do you know how that happened or how he came to 13 level, I'd goto Howard Bergen. 14 be the coordinator of those matters? 14 Q Did you receive three separate reports, one from 15 A No. 1 think he was in place in that job before 1 15 Anniston, one from Newport, one from Krummrich? 16 became a manufacturing manager. 1 had known him before 16 A Yes. 17 when he was a plant manager but 1 don't know how he got 17 Q And what did you do with those three reports? 18 that job. 18 A Well, 1 would put together a monthly report which 19 Q Was there a manufacturing manager before you who 19 usually just amounted to marking up the reports from the 20 was handling the issue? 20 plants and my secretary would put that together in a single 21 A Yes, that was Bill Kuhn, K-u-h-n. 21 report that would go on up the line. 22 Q So to some extent you took over what he had been 22 Q Would you send that to Papageorge? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 125-128 HARTOLDMON0010102 Page 129 Page 131 1 A Yes, and to Bergen and some other people in the 1 and the situation as it stood at that time in the 2 business group. 2 department. What Bill is talking about is a program that's 3 Q Who else would you send it to? 3 more plantwide and involves quote, using departments, which 4 A Well, certainly to Bill Richard, he was the 4 presumably refers to other departments where Aroclor is 5 director of research. I'm not sure who else. 5 used rather than manufactured. 6 Q If 1 could ask you to look at the first page of 6 Q Let me turn you back to Exhibit 4 for a second 7 Exhibit 4, there's a category for" Known Losses to Sewer in 7 then. Because that's the May 8, 1970 report from Mccutchan 8 April." Do you see that? 8 and down below where it says " Known Losses to Sewer," that 9 A Yes. 9 appears to me to refer to departments other than the 10 Q How was the sewer chosen as one area to sample at 10 Aroclor department. Do you see that? 11 the Krummrich plant? 11 A Yes, you're right. 12 A I'm not sure 1 understand the question. Where 12 Q With that in mind, does this impact on whether or 13 are you in this? 13 not you believe Exhibits 7 and 8 refer to the same program 14 Q On the first page of Exhibit 4. 14 or project or a different program? 15 A Okay. 15 A It's an interesting point, but Bob Mccutchan was 16 Q It references " Known Losses to Sewer in April." 16 production supervisor for Aroclor so perhaps as a matter of 17 A Well, what was known as the Pcb problem was 17 information he was reporting on losses from other 18 generally perceived to be a problem of Pcbs in water and in 18 departments, but as far as 1 know he had no direct 19 rivers and lakes and so forth. The path to causing a 19 responsibility for those things. 20 problem in wildlife was by way of aquatic organisms and 20 Q Let's go back to Exhibit 7 for a moment. There's 21 therefore controlling losses to the sewer was the most 21 a phrase in the first paragraph, item 3 " deals with 22 immediate priority. 22 eliminating sewered Pcbs from using departments," eliminate Page 130 Page 132 1 Q Do you know how the - strike that. 1 is the key. Do you see that? 2 Let's go for a second to Exhibit 7. If my 2 A Yes. 3 numbers are correct that's dated June 26, 1970. 3 Q Was it your understanding at the time that 4 A Okay. 4 Monsanto was going to be required to completely eliminate 5 Q Can you identify that for us? 5 Pcbs, Pcb discharges to the sewers? 6 A It's a memo from Bill Engman in Krummrich, Tsd to 6 Mr. Burnett: Object to the form of the 7 a long list of people who appear to be all plant people and 7 question. It's ambiguous. 8 even the carbonees seem to be all plant people. 8 The Witness: Bill's memo says that item 3 " deals 9 Q What was Engman's role in the program for Aroclor 9 with eliminating sewered Pcbs from using departments " is 10 pollution control? 10 quite different from the producing department, where Pcbs 11 A At the time he was a Tsd superintendent so he 11 were used in departments. 1 don't remember which 12 would have been in charge of technical work in a group of 12 departments used Pcbs. But Pcbs were sold as heat transfer 13 departments of which the Aroclor department was one. 13 fluid and also used for that purpose in various places in 14 Q Let me ask you to compare Exhibit 7 to exhibits 4 14 Monsanto and " eliminate " really refers to finding some 15 and Exhibit 8. Exhibit 8 for the record is dated July 3, 15 other process solution rather than using Pcbs as a heat 16 1970. 16 transfer fluid or for whatever they were being used. 17 A Okay. 17 By Mr. Brock: 18 Q My question is, for example, Exhibit 7 and 8, do 18 Q There's a statement that" latest word is that the 19 those relate to the same program or separate programs? 19 Feds ' plan a stepped up attack on Pcbs in July." Do you 20 A Well, Bill Engman's memo, Exhibit 7 is a little 20 see that? 21 broader than Bob Mccutchan's report, Exhibit 8 because Bob 21 A Yes, 1 see that. 22 Mccutchan, Exhibit 8 is reporting on the Aroclor department 22 Q Around this time was it your understanding that Savage, James (Aroclor Dept employee) in AETNA (1) Pages 129-132 HARTOLDMON0010103 Page 133 Page 135 1 the Feds were going to step up an attack concerning Pcbs? 1 the various plans and programs of the various plant groups 2 A 1 don't know what Bill was specifically referring 2 working on Pcb pollution control." Do you see that? 3 to here. We certainly anticipated increasing regulatory 3 A Yes. 4 pressure more severe regulatory requirements, but 1 can't 4 Q Do you recall there being various plans and 5 place in time any specific action that the federal 5 programs of various plant groups working on that subject? 6 government might have taken. 6 A Well, sure, there were various plant groups. 1 7 Q Why was increased regulatory pressure 7 certainly can't remember which ones at the present time. 8 anticipated? 8 Q The statement various plans and programs, how 9 A 1 don't know. 1 don't remember this memo. These 9 many plans or programs working on that subject do you 10 addressees are mostly production people in other parts of 10 remember in or about that time? 11 the plant so 1 think Bill is just trying to get their 11 A He's still just talking about the Krummrich 12 attention. 12 plant. 13 Q Let's go through those. Who is D. C. Armstrong? 13 Q Let's start with the Krummrich plant and then we 14 A Dallas Armstrong was in the laboratory. He was 14 can go to the other plants. Were there multiple programs 15 head of a small process research group. 15 concerning the Krummrich plant to your knowledge, dealing 16 Q Who was R. M. Fabian? 16 with the subject of Pcb pollution control? 17 A 1 don't know. 17 A Well, there were various parts to what we were 18 Q What about T. E. Greenman? 18 doing. Just broadly speaking there were programs relating 19 A Tom Greenman, 1 think, was a production 19 to the Aroclor department itself and then other parts of 20 superintendent. 20 the plant where Aroclors might be used or found for some 21 Q What about G. V. Vincent? 21 other reason. 22 A George Vincent was in Tsd. 1 think he ran the 22 Q What were the programs related to the Aroclor Page 134 Page 136 1 instrument department. 1 department itself? 2 Q What about D. Venters? 2 A Sampling. Since we were working on all the 3 A That's Dennis Venters. 1 don't remember what his 3 plants at the same time and since the Aroclor processes 4 job was. 4 were very similar at all the plants, there were similar 5 Q What about Kimball? 1 skipped Dalton, 1 know who 5 programs in place where we would sample, we would work 6 Dalton is. I've heard that name. 6 upstream from our main sampling point and try to track down 7 A Kimball was an operating superintendent. 1 think 7 the sources of Aroclor losses and then do engineering work 8 he was guest superintendent for ag operations at the time. 8 on each one of those sources. So there was a similar 9 Q And who was J. C. Hume? 9 package of projects at each one of the plants. They 10 A Jack Hume was another operating superintendent. 10 weren't identical, but they were similar to solve similar 11 1 think for most of his time at Krummrich he was in charge 11 problems at each place, try to eliminate any loss we could 12 of rubber chemicals, but I'm not sure he was at this 12 identify. 13 particular time. 13 Q Do you recall an effort to pull the various, 14 Q And up at the top, who was D. W. Jackson? 14 various plans and programs together under one - 15 A Darryl Jackson, 1 think, was general 15 A Well, there was a need to organize and track all 16 superintendent of technical service and lab at Krummrich, 16 of these things, this 1970, ' 71,' 72 was probably the 17 equivalent to the same job that 1 had left at Queeny. 17 busiest time of my life because we had so many things that 18 Q If you look on the next page of that same exhibit 18 we were trying to do at one time related to Pcbs, not just 19 that's a June 25, 1970 memorandum from Engman to 19 at the plants but with the products and so forth. Because 20 Papageorge ; is that correct? 20 there were so many things going on at once, there were a 21 A Yes. 21 lot of people involved. Simply track everything and make 22 Q There's a statement," This is to draw together 22 sure everything got the appropriate priority. We got a lot Savage, James (Aroclor Dept employee) in AETNA (1) Pages 133-136 HARTOLDMON0010104 Page 137 Page 139 1 of people involved and no one person had it all in his head 1 applications and people were working hard on replacements 2 at once. 2 and it was clear that the electrical industry would adopt 3 Q How much of your time during those years did you 3 those replacements as soon as they were satisfied that they 4 devote to the Pcb situation? 4 could make good products with them. 5 A It varied as other problems came along but 1 5 Q Mr. Engman's memo lists a number of categories. 6 would say on the average it was probably half my time, but 6 1 want to run through some of those briefly. One of the 7 not just on these questions of losses from the plant, but 7 goals was to - or under the heading one," Pcb levels in 8 reformulation of products and a lot of other things having 8 sewer, summarized published data gathered to date." Do you 9 to do with Pcbs. 9 see that? 10 Q What did you do along the lines of reformulation 10 A Yes. 11 of products? 11 Q Do you know what was done along those lines, 1 12 A Within Aroclor itself the biggest application, 12 mean, 1 see that it says who, it says Pierle? 13 the original application for Pcbs was a fire resistant 13 A Yes. I'm sure we did that, but 1 don't know 14 fluid for capacitors. We changed the nature of the product 14 whether we did it by the completion dates mentioned here or 15 that we sold for that purpose. What had been called 1242 15 not. 16 became 1016, which had been particularly refined to 16 Q Who is A. Rasmussen? 17 eliminate some of the less biodegradable isomers. In the 17 A That's Tony Rasmussen. 1 don't remember what his 18 case of the hydraulic fluids, speaking of the industrial 18 job was at that time. He was at various times a production 19 hydraulic fluids that contained Pcbs, we reformulated the 19 superintendent. That's the only job 1 remember for sure 20 entire product line twice, which meant that each time a 20 that he had. But 1 don't remember what his job was at this 21 dozen or more new products had to be created and put into 21 time. 22 production. Some new products were non-pcb products, were 22 Q Let's go to the category 2 or the Roman numeral Page 138 Page 140 1 used for carbon copy paper solvent. It was my 1 li. A is " Absorbed rupture disk repiping do you see 2 responsibility to get those products into production. 2 that? 3 Q Monsanto eventually went out of the Aroclor 3 A Yes. 4 business ; is that correct? 4 Q Do you know what that is? 5 A Yes, but that was after my time that the 5 A 1 know what a rupture disk is, but 1 don't know 6 operation was shut down completely. 6 why that repiping was called for. 7 Q You anticipated my next question, which was did 7 Q Are you aware of what was done in connection with 8 you have any input into that decision? 8 that repiping? 9 A No. 9 A No, 1 don't remember what the problem was. 10 Q Do you know or do you have an understanding as to 10 Q The next is " Basin for trenches." Do you know 11 how that decision was reached? 11 what that refers to? 12 A No. 1 think at the time that 1 left in business 12 A There were drainage trenches in the department 13 it was assumed it was only a matter of time before it was 13 that were used to catch rain runoff and so forth and the 14 discontinued but that decision was made well above my 14 basin was a settling basin that was put in so if there were 15 level. 15 any Aroclor in that water, it would be captured in the 16 Q Why was it a belief that it was only a matter of 16 basin. Aroclor is much heavier than water. 17 time? 17 Q What was done with the Aroclor - before 1970 18 A Well, a number of applications had been dropped 18 what was done with the Aroclor that settled in the settling 19 already. Very early in the game we stopped selling Aroclor 19 basin? 20 for use as a plasticizer. Then we stopped selling it for 20 A There wasn't any settling basin before that. 1 21 use as heat transfer fluid. We took it out of the 21 suppose if there was any Aroclor, it would have gone to the 22 hydraulic fluids so all that was left was the electrical 22 sewer. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 137-140 HARTOLDMON0010105 Page 141 Page 143 1 Q So this refers to the installation of a settling 1 because the effect of contamination was so critical. 2 basin to stop that? 2 So what we had decided to do was to take that 3 A That's right. 3 Aroclor back from our electrical customers and redistill it 4 Q What is a blow tank demister? 1 thought you used 4 and use it for the less demanding applications like heat 5 that term before. 5 transfer where those minor amounts of contaminants didn't 6 A Yes. Well, 1 used the term " blow tank" as well, 6 make that much difference. That was our customer service. 7 1 think. Blowing was one step of the Aroclor process. It 7 It was not a very big deal. 8 was the step between chlorination and distillation. In 8 Q If 1 understand your testimony correctly, that 9 that step air was blown through crude Aroclor to remove 9 didn't refer to Aroclor that had been disposed of, not by 10 Hcl. One of the things we had discovered as part of the 10 Monsanto, but that was Aroclor that had been with 11 sampling program was that there was a small amount of 11 Monsanto's customers? 12 Aroclor in the air leaving the blow tank and that by simply 12 A That's the only way in which we used the term 13 scrubbing that to the sewer, that was one of the ways that 13 " rework" that 1 recall. 14 Aroclor was getting to the sewer. The demister was a 14 Q Let's go to Exhibit 8 again for a second. And 15 device, again, one of these Brink demisters, it was put 15 again, that has a category of" Losses to sewer in June." 16 between the blow tank and the scrubber so that if there 16 Do you see that? 17 were any Aroclor in that air stream, that it would be 17 A Yes. 18 collected rather than going to the sewer. 18 Q Was it your understanding that the losses to the 19 Q And under Roman numeral Hi," Program to 19 sewer - well, you can see that those - strike that. 20 eliminate sewered Pcbs from using departments." B is 20 Was it your understanding that losses to the 21 " Provide disposal improvements and control facilities as 21 sewer of Aroclor was a routine thing at the Krummrich 22 needed." Do you see that? 22 plant? Page 142 Page 144 1 A Yes. 1 A Are you referring to this paragraph titled 2 Q Do you know of any disposal improvements that 2 " Losses to sewer in June "? Or are you referring to the 3 were provided for using departments? 3 entire report. 4 A No. 1 don't remember what the using departments 4 Q I'm referring to the general situation. 5 were or what the use was. But Aroclor was a product that 5 A Well, we had by that time discovered that there 6 was broadly used for heat transfer so it undoubtedly was 6 was a consistent loss of Aroclor at the sewer. 7 used for heat transfer somewhere. 7 Q When you say" by that time discovered," what do 8 Q But you don't recall what the disposal 8 you mean? 9 improvements would have been? 9 A Well, by" this time," 1 mean the middle of 1970 10 A No. 10 we recognized that we had, that we were losing Aroclor to 11 Q Number 6, Vi, is " Pcb rework project." Do you 11 the sewer essentially all the time. That's not something 12 know what that was? 1 mean, 1 see that it's got three 12 we would have recognized before the Pcb problem became 13 phases, but go ahead. 13 known because we had not been doing the kind of sampling it 14 A The customers who bought Aroclor for electrical 14 would have taken to find out. 15 applications didn't use it all, that is, in impregnator 15 Q Are you aware of any occasions on which Monsanto 16 capacitors or to some extent filling transformers, there 16 sampled to measure Pcb discharges to sewers before 17 would be some left over because the electrical properties 17 Professor Riseborough's work came out? 18 of Aroclor were extremely sensitive to minute amounts of 18 A I'm not aware of it. 19 impurities. They couldn't simply use that fluid to make 19 Q Let me turn you briefly to Exhibit 14 which is 20 the next batch of capacitors and so they had Aroclor left 20 dated September 1, 1970. And the first category there is 21 over that was contaminated in a very trivial way for most 21 " Pcb levels in sewer." Do you see that? 22 uses but could not be used for electrical applications 22 A Yes. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 141 -144 HARTOLDMON0010106 Page 145 Page 147 1 Q And it says " current losses to the river are 1 production superintendent at Newport and Hill Williams was 2 about 30 to 35 pounds per day." Do you see that? 2 the production superintendent at Anniston. 3 A Yes. 3 Q Let's go to Exhibit 10, that's dated August 4, 4 Q Was it your understanding that losses of Pcbs to 4 1970. Under the category with the li," projects to reduce 5 the sewer would take place on a daily basis from the 5 sewered Pcbs from Aroclor department." First of all, do 6 Krummrich plant? 6 you see that category? 7 A Yes. 7 A Yes. 8 Q Was it your understanding that Monsanto employees 8 Q And D under that is " provide paving curbs and 9 knew about the losses to the sewers before the sampling 9 catch basin in Aroclor department to prevent losses from 10 came on board even though they might not have known about 10 spills, especially in the tank car loading area." Do you 11 the quantities being released? 11 see that? 12 A 1 don't know. 12 A Yes. 13 Q For example, when you were - when the Aroclor 13 Q Are you familiar with that project? 14 department was under your purview at the Krummrich plant 14 A 1 don't remember that project specifically but 15 when you were a Tsd group leader, was it your understanding 15 it's consistent with the general approach we were taking, 16 that Aroclors were being released to the sewer at the 16 which was that if there was any place for a potential spill 17 plant? 17 or loss to the sewer, we were going to try to seal it off. 18 A 1 don't recall the question arising. Inmost 18 Q Do you know what that area was like, what the 19 departments, we would be quite aware of raw material 19 ground in that area was like before August of 1970? 20 consumption and if based on raw material consumption it 20 A No, 1 don't remember. 21 appeared that we were not getting good yield on the 21 Q Do you recall paving curbs and a catch basin 22 product, then we would begin an investigation which would 22 being installed? Page 146 Page 148 1 include sampling. But it was always believed that yields 1 A 1 think we did that but 1 don't know when it was 2 in Aroclor were very high and therefore there was no reason 2 completed. 3 to suspect that losses, at least losses of any economic 3 Q Let's go to the next page. Under B, it says " the 4 significance, were going on. 4 five organic Tsd groups have responded with programs for 5 Q But the yield in the Aroclor department was not 5 their areas." Do you see that? 6 100 percent; is that correct? 6 A Yes. 7 A No, not 100 percent but the difference could be 7 Q And my copy doesn't have them attached so 1 was 8 readily explained by the amount of still residue. 8 wondering whether you recall what those were. 9 Q When was the first time that you became aware of 9 A No, 1 don't. As you'll see, that's under the 10 losses of Aroclor to the sewer at the Krummrich plant? 10 heading of" program to eliminate sewered Pcbs from using 11 A When 1 joined the business group. 11 departments." So I'm sure this just refers to people who 12 Q Staying on Exhibit 8 for a moment, one of the 12 have responsibility for an area where the Pcbs were used in 13 copy recipients is H. Williams at the Anniston plant and 13 some way related to the process in that area, probably have 14 also F. Mcdonald at the Newport plant. Do you see that? 14 nothing to do with Aroclor manufacturing. 15 A Yes. 15 Q And Iv refers to " removal of soluble Pcbs from 16 Q Was information about the Pcb control -- strike 16 sewered stream." Do you see that? 17 that. 17 A Yes. 18 Was information about the Pcb situation generally 18 Q And it says " no work being done at Wgk." Do you 19 shared between the Krummrich, Anniston and Newport plants? 19 know why that was? 20 A Yes. The processes were nearly identical and so 20 A Well, the next sentence says that the research at 21 it was valuable to profit at each site from whatever was 21 Anniston," research at Anniston is working on a process." 22 learned at the other ones. Fred Mcdonald was the 22 There was no point in duplicating that work. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 145-148 HARTOLDMON0010107 Page 149 Page 151 1 Q Did the question come up of whether Monsanto 1 Q Let's go to Exhibit 11, which is dated August 5, 2 would be required to clean up Pcb contamination in the area 2 1970. Could you identify what this document is for us? 3 of the Krummrich plant? And I'm making a distinction just 3 A Mike Pierle was in the pollution control 4 between reducing discharges from, for example, sewers. 4 department at Krummrich at the time. Just on its face, 5 A What would now be called site remediation? 5 it's a program for sampling for Pcb losses in a number of 6 Q Something of that ilk, yes. 6 different places. 7 A 1 don't remember that we anticipated any 7 Q And how were those places chosen? The places are 8 particular requirement. 8 wastewater, water sediment and fish, those are the type, do 9 Q While you were manufacturing manager, do you 9 you see that? 10 recall any other companies being ordered to engage in a 10 A Yes. 11 cleanup with respect to Pcb contamination? 11 Q And you don't know how -- the places are under 12 A 1 wouldn't remember any government regulatory 12 the category source, is that correct, places where the 13 action against another company. 1 would have no reason to 13 sampling took place? 14 know that. 14 A Yes. 15 Q Have you ever heard of something called Findett 15 Q And you're not familiar with how those places 16 Corporation? 16 were chosen? 17 A Yes. 17 A I'd have to speculate. 1 don't know for a fact. 18 Q Did you have any dealings with Findett 18 Q The " Department 246 trench," 1 think you 19 Corporation? 19 mentioned that earlier? 20 A Yes. 20 A Yes. 21 Q What were your dealings with Findett Corporation? 21 Q Where did that go? 22 A My biggest interface with Findett was to use them 22 A That went into the general plant sewers. Page 150 Page 152 1 as a tool manufacturer to make some special materials that 1 Q And the treatment plant influent, what does that 2 we needed in another part of the business. Findett is a 2 refer to? 3 small specialty tool manufacturing company west of 3 A There was a treatment plant down near the river 4 St. Louis. 4 bank which 1 think was operated by Sauget village. 1 was 5 Q Did you ever speak with anybody at Findett about 5 never familiar with any of that. I've never actually been 6 whether Findett had been ordered to engage in a cleanup 6 there, but there was a treatment plant. 7 with respect to Pcb contamination? 7 Q What was a Monsanto dock? 8 A No, but now you remind me, that was the other 8 A We had a dock on the Mississippi River that we 9 deposition, the second one. 9 used for unloading. In fact, we may have had two because 10 Q Okay, when you say 1 reminded you, what did it 10 we received both benzene and salt by barge and so we have 11 remind you of? 11 docks. I'm not sure whether they really belong to Monsanto 12 A That that was the second time 1 gave a deposition 12 or were leased by somebody else but Monsanto dock could 13 on Pcbs. It was somebody looking for information about 13 refer to either one of those. 14 Findett. 14 Q Did you ever have any responsibilities regarding 15 Q Did you have any information about -- were you 15 those locations? 16 familiar with Findett's use of Pcbs? 16 A No. 17 A 1 knew that they reclaimed spent hydraulic fluid 17 Q What is East Carondolet, what does that refer to? 18 for our customers but 1 wasn't directly involved in that. 18 A East Carondolet is a village, 1 think it's south 19 Q Do you recall ever speaking with anybody at 19 of the plant. 1 don't know why that would have been 20 Findett concerning the subject of whether or not they would 20 picked. 21 be required to engage in a cleanup? 21 Q What is J. B. Bridge? 22 A No. 22 A Jefferson Barracks Bridge is a bridge across the Savage, James (Aroclor Dept employee) in AETNA (1) Pages 149-152 HARTOLDMONOOIOIO8 Page 153 Page 155 1 Mississippi about 10 miles south of it. 1 report. 2 Q Let's go to Exhibit 12. That's dated August 11, 2 Q Were there subsequent meetings about his reports? 3 1970. Can you identify what that is for us? 3 A Oh, we had a lot of meetings about Pcbs but 1 4 A Well, the original memo is from Bill Engman to 4 don't know that we specifically reviewed this report. 5 Bill Papageorge and refers to some specific losses from 5 Q What would you do as a matter of practice with 6 using departments. They mention one, Department 251. Ifl 6 the information provided to you in Mr. Papageorge's monthly 7 recall correctly that was the Acl department, the cyanuric 7 reports? 8 chloride, it was a swimming pool chemical. Someone has 8 A Well, his report was 1 think mostly intended for 9 written by hand on this, and 1 guess it's Mike Pierle 9 the information of people a level up from me. 1 would do 10 reflecting that this loss from a using department was 10 several things with a report like this. 1 would make sure 11 larger than, by far than the total that our whole target 11 that the information about manufacturing was properly 12 for the plant was. 12 reflected and nothing had got mixed up in the translation. 13 Q And the typewritten memo refers to " Aroclor 13 1 would be interested in what was going on in engineering. 14 losses to the sewer other than from routine Aroclor 14 It was a subject of great interest to all of us, and I'm 15 production." Do you see that? 15 sure 1 read the whole thing but there were only a few parts 16 A That's right. 16 of it that would directly involve research and engineering 17 Q By this time were most losses from the plant 17 mainly. 18 considered to be from the routine operations, production 18 Q There's a reference to " Aroclor incineration " on 19 operations at the plant? 19 the first page. 20 A 1 don't know. The numbers and that speak for 20 A Yes. 21 themselves. 1 don't remember. 21 Q Were you involved in any Aroclor incineration 22 Q Who was A. Glosecki? 22 projects? Page 154 Page 156 1 A 1 don't know. 1 don't recognize the name. 1 A Yes. 2 Q Who was B. Young? That's the last copyee. 2 Q What were those? 3 A I'm not sure. There was a Bob Young at the 3 A Well, there was only one. Essentially 1 was the 4 Krummrich plant who was in the maintenance department, but 4 sponsor of that project. We needed a way to dispose of 5 1 don't know why he would receive this. 5 still residue without sending it to a landfill, and also we 6 Q Who is W. A. Krull, K-r-u-l-l? 6 were concerned about the possibility of having to 7 A Wayne Krull became the production supervisor of 7 incinerate customer returns so we sent some samples of 8 the Aroclor department at some point, 1 believe. He may 8 typical Aroclor still residue to an incinerator 9 have been working as a Tsd engineer at that time. 9 manufacturer who did a pilot plant run to determine the 10 Mccutchan is still on this memo, so apparently he's still 10 proper operating conditions, and then based on that, we had 11 the production supervisor at the time but eventually Wayne 11 an incinerator designed and built and installed at the 12 Krull replaced him. 12 Krummrich plant. 13 Q Let's go to Exhibit 13, which is dated August 18, 13 Q Who was the incinerator operator, do you recall? 14 1970, for the record, has Bates numbers Mco 0407871 through 14 A The operator? The production supervisor was - 15 7788. Can you identify what this is for us? 15 Q No, you said you sent it to - 16 A Just on its face, it's Bill Papageorge's monthly 16 A - an incinerator manufacturer. 17 report on Pcbs. 17 Q Who was that? 18 Q Earlier you had talked about sending information 18 A 1 don't remember. There's only a few people in 19 to Papageorge. Did Mr. Papageorge send back to people 19 the country who do that sort of thing. It was a well-known 20 monthly reports on the Pcb situation? 20 company but 1 don't remember. 21 A Well, yes. He would summarize what he got from 21 Q You mentioned that you needed a way to dispose of 22 me as well as from other people and put it together in a 22 the still residue without sending it to a landfill. Had it Savage, James (Aroclor Dept employee) in AETNA (1) Pages 153-156 HARTOLDMON0010109 Page 157 Page 159 1 come to your attention that the still residues had been 1 page, and the Bates numbers are 782 and 783. Just let me 2 sent to a landfill before that? 2 know when you've had a chance to read that section to 3 A Well, that was just part of the general knowledge 3 yourself. 4 that we all had, was that it was going to a landfill. 1 4 ( Witness reviewed the document. ) 5 wasn't directly involved with that. My piece of this was 5 A Okay. 6 to do something different, and getting an incinerator 6 Q That references " a lawsuit claiming that cows had 7 installed at Krummrich was the best solution we could come 7 given milk contaminated by Aroclors." Do you see that? 8 up with. 8 A Yes. 9 Q When you were at the Krummrich plant in the 1963 9 Q Were you familiar with that lawsuit? 10 to 1967 time frame, did you understand at that time that 10 A 1 had heard of it. 11 the still residues were sent to a landfill? 11 Q Do you know how that lawsuit was resolved? 12 A 1 assume so but 1 didn't have any direct 12 A No. 13 involvement in that. 13 Q Do you know what Monsanto's response was to the 14 Q At this time frame in August of 1970, were 14 claim that the plaintiff's cows had given milk contaminated 15 Aroclor still bottoms still being sent to a landfill? 15 with Aroclors? 16 A 1 think so. There was no other place to go with 16 A No. There's no reason why 1 would have been 17 them. 1 think at some point we started to accumulate 17 involved in something like this. 18 material in a storage tank in anticipation of startup of 18 Q Were you familiar with any other claims or 19 the incinerator but 1 don't know when we did this. 19 lawsuits against Monsanto claiming that Aroclors from the 20 Q Was Aroclor sent to landfills in connection with 20 Krummrich plant had caused damage to property or damage to 21 all three of the plants, meaning Krummrich, Anniston and 21 wildlife or that type of thing? 22 the Newport plant, at this time? 22 A 1 had heard of things like that secondhand, but 1 Page 158 Page 160 1 A In general, yes. But Newport had actually 1 have no firsthand knowledge of that. 2 organized a relationship for the commercial incinerator 2 Q What did you hear secondhand? 3 near the site at some point. And it could be that at this 3 A It was about a lawsuit having to do with 4 point Newport had already done some incineration through 4 contamination of some kind of animal feed from a heater 5 this commercial incinerator, but 1 don't know exactly when 5 that used Aroclors, a heat transfer medium. 1 don't know 6 that happened. 6 any more about it than that. Other people were working on 7 Q Was that a separate project from the dealings 7 those problems. 1 had plenty of my own. 8 with the -- strike that. 8 Q Do you recall the general time frame when you 9 Was that a separate project from the Aroclor 9 heard about that lawsuit? 10 incinerator project than the Krummrich plant? 10 A No. 11 A Certainly. It's on the other side of the 11 Q Was it during the time that you were a 12 Atlantic. 12 manufacturing manager dealing with the Pcbs? 13 Q Right, but was there consideration given to using 13 A Yes. 14 the process that was used at the Newport plant at the 14 Q Do you know what the resolution of it was? 15 Krummrich plant? 15 A No. 16 A No. That was a commercial incinerator. There 16 Q Can 1 ask you to read the section under the 17 were -- we were not able to find a commercial incinerator 17 public relations heading just to yourself and let me know 18 in the United States that could operate at the unusual high 18 when you've had a chance to do that. 19 temperature and long residence time that was required to 19 ( Witness reviewed the document. ) 20 destroy Pcbs. 20 A Okay. 21 Q Let me ask you to turn to the second page of this 21 Q Had you ever heard stories to the effect that 22 under the category " legal," which continues on to the third 22 Pcbs caused birth defects? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 157-160 HARTOLDMONOOIO110 Page 161 1 A 1 don't specifically remember reading stories 2 about that. Page 163 1 A We reviewed this regularly. 1 visited the 2 Krummrich plant at least once a month and probably visited 3 Q Did any claims of that nature, did you hear or 4 learn of any claims of that nature? 5 A 1 never heard of anything like that. 6 Q Let me ask you to turn to page 6 of the document 7 under the heading " biodegradation testing-st. Louis." That 8 makes a reference to " semicontinuous activated sludge 9 units." Do you see that? 10 A Yes. 11 Q What were those sludge units? 12 A That was-- that work was done somewhere in 13 research and 1 never had any connection with it other than 14 to read reports like this that said the work was going on. 15 Q Do you know what the term " sludge unit" refers 16 to? 17 A Activated sludge is a conventional type of 18 biological treatment that's used for waste. 19 Q Let me ask you to turn to page 7 of the exhibit 20 under the heading for" Sauget Pcb levels in sewer." It 21 states that" current losses are about 45 pounds per day to 22 the river." Do you see that? 3 Anniston nearly as often, and talking about Pcb losses was 4 always a major item on the agenda, so we would always 5 review the latest figures and review the program, decide 6 whether the program was really addressing all of the losses 7 that we could identify, and if not, we would add whatever 8 was necessary. 9 Q Do you recall any specific occasions on which you 10 made a point to the plant people that the emissions were 11 too high and something needed to be done about them? 12 A 1 think we were a little more businesslike than 13 that. We would simply look at where we were and what we 14 had to do and get on with it. 1 don't recall preaching. 15 ( Recess. ) 16 By Mr. Brock: 17 Q Let me take you somewhat out of order, exhibit 18 wise, Mr. Savage. To Exhibits 28 and 29. Let's referto 19 Exhibit 29 first. Is that your signature at the bottom of 20 Exhibit 29? 21 A Yes. 22 Q And is this a memo you wrote to the addressees Page 162 Page 164 1 A Yes. 1 listed? 2 Q Do you recall any discussions along the lines of 2 A I'm sure it was. 1 don't remember writing it but 3 whether or not a figure of that type was too high? 3 I'm sure it was. 4 A 1 can't answer that. 1 can just comment that, 4 Q If you refer to Exhibit 28, does that appear to 5 considering that this is the middle of 1970, we felt our 5 you to be the attached memorandum from Bill Papageorge? 6 losses were too high and that we had to get them down, so 1 6 would just point out that the numbers, the Bates stamp 7 presume that's a higher number than we found acceptable, 7 numbers are sequential. 8 but that's too long ago for me to remember whatever target 8 A It appears to be, yes. 9 numbers we may have had. 9 Q Mr. Papageorge's memo states " we should not 10 Q Does it refresh your recollection to review 10 neglect to consider losses to the atmosphere through jet 11 Exhibit 12 where it says " the plant goal for losses is 10 11 exhausts, vents, stacks, et cetera." Do you see that? 12 parts per billion "? Exhibit 12? 12 A Yes. 13 A That doesn't add anything to what 1 remember. 13 Q Had those type of losses to the atmosphere not 14 Q 1 thought you said you didn't recall what the -- 14 previously been emphasized? 15 A Well, 1 can read - 15 A Notemphasized. 1 think we had thought about 16 Q - what the goal was. 16 some of those things before but had not emphasized them. 1 17 A 1 can read that it says that but 1 still don't 17 think the reason is simply that that seemed unlikely to be 18 remember it. 18 a serious problem because the vapor pressure of Aroclor is 19 Q If levels came back that were significantly above 19 very, very low so we would assume that that was not going 20 the plant goal for Pcb emissions, was there something that 20 to be a severe problem. Papageorge's memo, 1 think, points 21 you did as a matter of course when that came to your 21 out that we shouldn't just assume that, and 1 passed the 22 attention? 22 message along to the clients. Savage, James (Aroclor Dept employee) in AETNA (1) Pages 161 -164 HARTOLDMONOOIO111 Page 165 Page 167 1 Q When you say the vapor pressure was low, why 1 or Pcb material being sent to the Krummrich landfill at 2 would that lead you to believe that would not be a serious 2 around this time? 3 problem? 3 A Well, 1 believe what the memo says, but 1 don't 4 A To say something has a low vapor pressure is 4 remember what this was about. 5 equivalent to saying it's not very volatile, so a tank full 5 Q The next paragraph states " this should cease 6 of Aroclor out in the open would not give off any Aroclor. 6 about mid-september when the Protectoseal equipment 7 A very high boiling point, that's another way of saying the 7 arrives." Do you see that? 8 same thing. 8 A Yes, 1 don't know what that is. 9 Q In your memo in the second paragraph, it states 9 Q What, the Protecto-seal equipment? 10 " one of the first questions from semiknowledgeable 10 A Right. 11 legislators and control agency personnel is always how much 11 Q The reference to " this should cease," do you know 12 goes up your stacks." Do you see that? 12 what the " this " refers to? Does it refer to sending 13 A Yes, that's a little sarcastic, 1 guess. 13 something to the landfill? 14 Q Had you dealt with legislatures? 14 A Presumably it refers to the previous paragraph. 15 A No, not really. 15 On the face of this, that's what it says. 16 Q Had you dealt with control agency personnel? 16 Q Do you recall whether sending Pcb materials to 17 A No, no. 1 was just repeating some conventional 17 the landfill ceased in or about that time? 18 knowledge. 18 A No, 1 don't know. 19 Q Where did that conventional knowledge come from? 19 Q Somewhat out of order again, let me ask you to 20 A 1 don't know. 20 turn back to Exhibit 14, which is dated September 1, 1970. 21 Q Was it conveyed to you by people at Monsanto who 21 Is that your handwriting up at the top of that first page? 22 did deal with legislatures and control agency personnel? 22 A Yes. Page 166 Page 168 1 A No, 1 think this was just my personal sarcasm. 1 Q Is this a memorandum you would receive in the 2 Q I'm curious - were you aware of anybody within 2 ordinary course of your business with Monsanto? 3 Monsanto who at that time was dealing with legislatures or 3 A Yes. 4 control agency personnel with respect to the Pcb situation? 4 Q What would it mean - when you wrote 5 A No, not at all. 1 think what 1 was doing in this 5 " W. B. Papageorge " at the beginning, what would that mean? 6 paragraph was simply telling the guys at the plant don't 6 A Just that 1 bucked it up to Bill for some reason, 7 bother me with a sophisticated explanation of why there 7 but 1 don't know why. 8 shouldn't be any there. Let's go look. 8 Q On the last page there's a reference to 9 Q Let's go to Exhibit 15, which is dated September 9 " incineration liaison." 10 14,1970. Let me know when you've had a chance to see 10 A Right. 11 that. 11 Q What was that? 12 ( Witness reviewed the document. ) 12 A Well, Bill Engman was at the plant in the 13 A Okay. 13 technical service department, and what had happened was 14 Q First of all, is this a memorandum sent to you in 14 that the incinerator project had reached the point where it 15 the ordinary course of your employment with Monsanto? 15 was a formal project, and the procedure in those days is 16 A Yes. 16 that when a large formal project was launched, that 17 Q The second paragraph mentions " laboratory 17 somebody at the plant would be nominated to be the 18 continuing to send solvent-contaminated Pcb to the 18 manufacturing representative, which is referred to at the 19 landfill- 19 end of this paragraph, and once that had happened, then it 20 A Yes. 20 was no longer within the interest of the technical service 21 Q - through August." Does this refresh your 21 department, it was being handled in another channel. So 22 recollection as to being aware of Pcb-contaminated material 22 this just reflects the fact that the incinerator project Savage, James (Aroclor Dept employee) in AETNA (1) Pages 165-168 HARTOLDMONOOIO112 Page 169 Page 171 1 had become a formal project. 1 Q What does that refer to? 2 Q Let's go to Exhibit 16. My first question is 2 A " Chat" is a term that's used to describe crushed 3 just whether or not this is a memorandum you received in 3 rock which is often used as ground cover. 4 the ordinary course of your business or your employment 4 Q Do you recall that area being soaked with 5 with Monsanto. 5 Aroclor? 6 A Yes. 6 A No, 1 don't even remember what Department 270 7 Q On the left-hand side, there's some writing, and 7 was. 8 in between the first and second paragraphs 1 believe it 8 Q Do you recall any areas at the plant, at the 9 states " Krummrich." Do you see that? 9 Krummrich plant, being soaked with Aroclor? 10 A Yes. 10 A No, not really. 11 Q Is that your writing? 11 Q When you say not really, are you qualifying that 12 A Yes. 12 somehow? Were they soaked a little bit? 13 Q Was that to change the format of these for the 13 A Soaked is a word that could have all kinds of 14 purpose of sending your report to Bill Papageorge? 14 interpretations. If" soaked " means it's so juicy that it's 15 A This is my markup of the report, which 1 would 15 liquid when you walk on it, no, 1 don't remember anything 16 give to my secretary along with similar reports from the 16 like that. If it means that there's a coating on the 17 other plants so that she could put it together in a single 17 surface of the stone and therefore the stone ought to be 18 report that would be sent on to Bill Papageorge and others. 18 replaced, 1 can remember seeing things like that. 1 can't 19 Q Let me ask you to turn to page 2, under 19 tell you exactly where. 20 department 239. The next to last sentence reads " how to 20 Q Did you see situations like that during the time 21 sump the area around potential spills is still 21 you were at the Krummrich plant? 22 unresolved." Do you see that? 22 A 1 don't remember. Page 170 Page 172 1 A Uh-huh. 1 Q Do you recall any places at the Krummrich plant 2 Q First of all, do you recall what department 239 2 where the ground or soil would be discolored due to a layer 3 was? 3 of Aroclor? 4 A Well, from the rest of this paragraph, it speaks 4 A No, 1 don't remember. 5 of Santofin 1, and as 1 recall, that was the Santofin 5 Q Do you recall the area - strike that. 6 department. Santofin was a completely unrelated product. 6 Do you recall any areas at the Krummrich plant 7 Q Do you recall this subject coming up of whether 7 being discolored with materials other than Aroclor? Was 8 or not or how to sump the area around potential spills in 8 that a frequent thing? 9 that department? 9 A That's a pretty broad question. The Krummrich 10 A No. Must have been just a mechanical problem. 10 plant was a great big place. The only place that 1 can 11 Q Do you recall there being a concern about spills 11 remember that had a serious problem like that was actually 12 from that department reaching the ground or water? 12 in rubber chemicals, which was an operation 1 only visited 13 A 1 don't think there was any specific concern 13 a few times. 1 don't know anything about it. It had 14 about that department. It was just that, by that time, we 14 nothing to do with this. 15 had become sensitive enough to Pcb issues that we wanted to 15 Q When you say rubber chemicals, what plant was 16 be sure that any place that Pcbs were being used, that if 16 that or what plant are you talking about when you say 17 there were a spill, it wouldn't get away from us and get 17 rubber chemicals? 18 into water. 18 A I'm trying to remember what that's called. It's 19 Q Let's go down to the entry under Department 270. 19 the antioxidant operations down at the south end of the 20 There's a reference to " chat soaked with Aroclor around the 20 plant. They were at the south end of the plant at the 21 furnace." Do you see that? 21 time, but 1 don't remember the name of the product anymore. 22 A Yes. 22 Q Is that at the Krummrich plant? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 169-172 HARTOLDMONOOIO113 Page 173 Page 175 1 A Yes. 1 A Yes. 2 Q What was the material on the ground? 2 Q Do you know whose handwriting that is? 3 A 1 don't know. 3 A Not mine, but 1 don't know whose it is. 4 Q How did that situation come to your attention? 4 Q Are you aware of anybody who kept the file of Pcb 5 A Just by being involved in plant inspection teams 5 pollution-related matters? 6 where we'd go around and look at housekeeping. 6 A 1 would think that Papageorge did but -- each of 7 Q What did the plant inspection teams -- what were 7 us who were working on pieces of this would have our own 8 those? 8 personal files, but they would all be subject to the normal 9 A 1 don't remember exactly how those things were 9 records retention policy, so unless there was some specific 10 organized but housekeeping was an issue at every plant that 10 directive otherwise, they wouldn't be kept for very long. 11 1 was -- that 1 ever worked on, and we would have various 11 Q Let's go back to Exhibit 17. It's dated October 12 mechanisms for trying to set a high standard and to make 12 7,1970. Near the bottom of the first page there's a 13 recommendations as to places that we thought needed 13 reference to " regulatory action." Do you see that? 14 cleaning up. 14 A Yes. 15 Q Do you recall it being recommended that any 15 Q Where it says " telephone contact continued with 16 location at the Krummrich plant be cleaned up as a result 16 the Alabama Water Improvement Commission." 17 of discharges to the environment? 17 A Yes. 18 A Nothing specific. 18 Q Were you aware of telephone contacts with that 19 Q Let's go to Exhibit 17. Is this an example of 19 agency about the Pcb situation at that time? 20 the monthly Pcb reports that you sent to Papageorge? 20 A 1 was aware of contacts, but in this report, all 21 A This appears to be-just glancing through it, 21 I'm doing is picking up what the plant had reported to me. 22 it covers Anniston and Krummrich, and not Newport, which is 22 So 1 wouldn't necessarily be familiar with that in any Page 174 Page 176 1 a little surprising, but otherwise, yes, it seems like the 1 detail. 2 routine thing 1 would send to Papageorge. 2 Q Do you recall who it was at the Anniston plant 3 Q Why do you say that's surprising that Newport is 3 that reported to you? 4 not -- 4 A Well, 1 would get my reports generally from Hill 5 A My recollection is that we reported on all three 5 Williams, or later on, Jesse Corder, but it was probably 6 sites together, but I'm not sure whether 1 did that as part 6 somebody like Bunky Wright who was doing this. 1 really 7 of this report or maybe Fred Macdonald reported it directly 7 don't know. 8 to Papageorge. 1 don't remember. 8 Q Did you ever have any contacts with the Alabama 9 Q Would these be kept in the ordinary course of 9 Water Improvement Commission about the Pcb situation? 10 your employment with Monsanto? 10 A No. 11 A Pardon? 11 Q Did you ever have any contacts with them at all 12 Q Would you keep these in the ordinary course of 12 to your knowledge? 13 your employment? 13 A No. 14 A Keep them? 14 Q Let's go to the second page of the memo. Pcb 15 Q Right, keep them in a plant somewhere. 15 levels in sewer. 16 A 1 probably kept these for a year in the reading 16 A At Krummrich? 17 file. 17 Q Right. And again, that gives a range from 12 to 18 Q Along these lines, let me refer you to Exhibit 18 742 Ppbs, do you see that? 19 20, which is dated December 1, 1970. 19 A Yes. 20 A Yes. 20 Q Do you recall there being any discussion or 21 Q Up near the top of the page, there's some 21 concern about leakage of Pcbs from the sewers leading from 22 handwriting " Pollution -- Pcbs." Do you see that? 22 the Krummrich plant? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 173-176 HARTOLDMONOOIO114 Page 177 Page 179 1 A 1 remember problems with the sewers at Krummrich, 1 Q For Exhibit 18, 1 just have a simple question. 2 but whether that was expressed in terms of leakage of Pcbs 2 Is this a memo that you received in the ordinary course of 3 from the sewer, 1 don't remember. The Krummrich plant 3 business of your employment with Monsanto? 4 sewer system at that time was a mixture of sewers that had 4 A Yes. 5 been built at various times through its long history, and 5 Q And is Exhibit 19 a memorandum that you sent in 6 so there were problems. But exactly what they were, 1 6 the ordinary course of your business with Monsanto? 7 don't remember. 7 A Yes. 8 Q Do you recall how those problems came to your 8 Q Let me ask you to turn to Exhibit 22. Can you 9 attention? 9 identify what that is for us? 10 A Just in the course of our sampling efforts to 10 A Well, it's a memo from Bill Papageorge to me in 11 track where the Pcbs were coming from. It was kind of 11 which he underlines how far we are from our goals at the 12 confusing to figure out what the flows in the sewers really 12 plant. 13 were for a while. Eventually that was worked out. 13 Q In the first paragraph, he sets forth a goal -- 14 Q When you say it was confusing to figure out where 14 or a maximum of 50 parts per billion in wastewater 15 the flows really were, what do you mean by that? 15 effluent; is that correct? 16 A Well, the total losses from the plant were larger 16 A That's what it says. 17 than could be accounted for just from the Aroclor 17 Q If we go back to Exhibit 12, again, that's the 18 production facilities, so one would suspect from that that 18 handwritten addition to an August 11, 1970 memo that states 19 it was also coming from some using departments, and the 19 " the plant goal for losses is 10 Ppb." 20 sampling program was to determine how much was coming from 20 A Yes. 21 where, and the conditions of the sewers was a confusing 21 Q I'm trying to put together what the situation 22 factor. The way they were interconnected was such that it 22 was. How would you explain the reference to 10 Ppb in one Page 178 Page 180 1 was a bit ambiguous as to where the flows came from. 1 and the 50 Ppb in the other? 2 Q Do you recall an investigation or study being 2 Mr. Burnett: Object to the form of the 3 done to determine where the sewers came from and went at 3 question. Mischaracterizes the documents. 4 the Krummrich plant? 4 Mr. Brock: Hang on. 5 A Well, we must have done that, but 1 don't 5 By Mr. Brock: 6 remember anything about it. 6 Q How do you explain or what would be your 7 Q Do you recall who may have been involved in that? 7 explanation for the 50 Ppb level appearing in the 8 A No. 8 December 7, 1970 memorandum and the 10 Ppb level being 9 Q Was that in conjunction with the Pcb issue that 9 referenced in the August 1970 memorandum? 10 that was done? 10 A Just that Pierle is talking about the longer 11 A 1 think so because it did take us a while to 11 range goal of 10. Papageorge is also pointing out that we 12 track down the sources and be confident that we knew what 12 have an interim goal that was higher than that. 13 they were. 13 Q Were you involved in the setting of the interim 14 Q Do you recall being involved in that project at 14 goals or the long-range goals? 15 all? 15 A No. 16 A 1 don't think 1 was. 16 Q Papageorge's memo states, there's a sentence that 17 Q Would it have been the maintenance personnel? 17 states " We do not have the luxury of unlimited time to 18 I'm just trying to get -- who would be likely to know about 18 combat this problem." Do you see that? 19 that? 19 A Yes. 20 A There was the utilities department and there was 20 Q Was it your understanding that the Pcb problem 21 a maintenance department, and it might have been either 21 was, at that time was a problem that Monsanto should 22 one. 22 address with some dispatch? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 177-180 HARTOLDMONOOIO115 Page 181 Page 183 1 A Absolutely. 1 A Yes. 2 Q And what was the -- what was the reason that that 2 Q Do you know what projects the Anniston and 3 problem needed to be addressed quickly? 3 Krummrich expenditures, for example, capital expenditures 4 A There was a feeling that government regulation 4 referred to? 5 was sure to come, and that if we voluntarily got our losses 5 A No, 1 don't remember. They're mentioned in some 6 down to the absolute minimum, that we could accomplish -- 6 of these earlier memos that we looked at, but 1 don't 7 that the regulation would be less punitive, perhaps it 7 remember the details. 8 would avoid adverse publicity for the company. It just 8 Q Let's go to Exhibit 24, and to speed it along, my 9 seemed good business to get ahead of the problem as quickly 9 first question is whether or not this is a January 5, 1971 10 as we could. 10 memorandum from W. Engman to you that you received in the 11 Q Do you know whether Monsanto people were 11 ordinary course of your employment with Monsanto. 12 communicating to governmental people concerning Monsanto's 12 A Yes. 13 voluntary efforts to reduce the Pcb problem? 13 Q Let me take you first to the second page under 14 A 1 had heard of those things, but 1 wasn't 14 the category with Iv. Number 3 states " clean all 15 directly involved. 15 contaminated sewers and sewer boxes." Do you see that? 16 Q What did you hear? 16 A Yes. 17 A Papageorge had talked to regulatory people in 17 Q Does that refresh your recollection at all as to 18 Washington, 1 think at some point he may have testified to 18 Monsanto undertaking to clean up past contamination as 19 some Congressional committee. Again, I'm just hearing this 19 opposed to just -- or as opposed to reducing ongoing 20 stuff secondhand. 1 wasn't directly involved in any of it. 20 emissions? 21 Q Did you ever deal with any governmental people in 21 A 1 don't remember. This seems like a plausible 22 Washington on the Pcb situation? 22 action to take but 1 don't remember exactly what we did. Page 182 Page 184 1 A No. 1 Q Do you recall being involved in any projects 2 Q Did you ever testify in that situation? 2 during that time to go back and clean up past contamination 3 A No. 3 as opposed to just -- to reducing ongoing emissions? 4 Q Did you ever make any speeches or presentations 4 A No, 1 really don't remember. 5 concerning that situation? 5 Q What is Rogers Terminal? 6 A No. 6 A 1 don't know that either. 7 Q Let's go to Exhibit 23. Could you identify what 7 Q For Exhibit 25, a very simple question: Is this 8 that is for us? 8 a memorandum that you sent to Mr. Papageorge in the 9 A This is a memo from me to Bill Papageorge just 9 ordinary course of your employment with Monsanto? 10 outlining the financial requirements for the Pcb control 10 A Yes. 11 program. 11 Q Let me ask you to turn to Exhibits 26 and 27 12 Q What was your -- what were your responsibilities 12 together. Is this an example of an occasion on which you 13 with regard to the level of expenditures for Pcb control? 13 received information concerning the Pcb situation at the 14 A 1 had a certain capital approval level, so 1 14 Krummrich plant and transmitted that information in a 15 could approve projects up to a certain size. Those were 15 report to Mr. Papageorge? 16 larger than projects that could be approved at the plants. 16 A Yes. 17 And above the level that 1 could approve it, then 1 would 17 Q When the reports would come to you of the -- for 18 have to go to Howard Bergen or somebody else. Basically 18 example, the February -- Exhibit 26, the February 2, 1971 19 I'm just telling Bill how much money we need. Presumably 19 report to you from Engman, when you got those, did you 20 he needed that information for some summary that he was 20 undertake to -- strike that. 21 putting together. 21 What, if anything, did you do with those reports 22 Q The M, does that refer to thousands? 22 before including them in your reports to Papageorge? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 181 -184 HARTOLDMONOOIO116 Page 185 Page 187 1 A Well, 1 read them, obviously. Usually 1 was in 1 A Well, the Aroclor department operations had 2 such close contact with the plant on these issues that it 2 always been considered to be very stable. The yields were 3 would be unusual if 1 would be surprised by anything in 3 always consistent. We had never suspected that there was 4 here. It was almost always something that 1 was already 4 any remarkable loss of product. 5 familiar with. If 1 were surprised by anything 1 read 5 Q Do you recall there being any attempt to discover 6 here, 1 would have called Bill and tried to learn a little 6 precisely how the past contamination had got there, for 7 more about it. 7 example, during what years or what proportions, during what 8 Q You would call Mr. Papageorge? 8 time frames, that type of thing? 9 A No, Bill Engman. 9 A 1 have no idea how you'd do that. 10 Q Oh, I'm sorry. 10 Mr. Brock: Off the record. 11 A Obviously, if it appeared that it was a bad 11 ( Discussion off the record. ) 12 situation and something had to be done about it, we'd talk 12 ( Savage Exhibit 30 through 33 13 about what should be done. The formal reporting was kind 13 identified. ) 14 of after the fact. Everybody was working pretty closely 14 By Mr. Brock: 15 together as a team, and the formal report was just kind of 15 Q Mr. Savage, let's go to Exhibit 30. Is that a 16 for the record and to let the people on up the line know 16 March 1, 1971 memorandum you received in the ordinary 17 about it. 17 course of your employment with Monsanto? 18 Q Let me turn you to page 2 of Exhibit 26 and page 18 A Yes. 19 3 of Exhibit 27. It's your report to Papageorge. The 19 Q There's a reference near the bottom to a " village 20 third paragraph from the bottom of exhibit -- the page on 20 sewer." Do you see that? 21 Exhibit 26 talks about past sewer contamination, and that 21 A Yes. 22 same reference is made on the third page of Exhibit 27. Do 22 Q Does that refresh your recollection as to what Page 186 Page 188 1 you see those references, page 3 of Exhibit 27? 1 Rogers Terminal was? 2 A Yes. It appears to be identical. 2 A Just on the face of this, it's a place where, in 3 Q For clarity of the record, the statement reads 3 the previous one, it's a place where trucks were washed, 4 " losses at the treatment plant are expected to remain 4 but 1 didn't remember that. 5 above 10 Ppb by 9/1/71 due to past sewer contamination." 5 Q Do you recall the reason for Monsanto instituting 6 Do you see that? 6 a sampling program with respect to the village sewer or 7 A Yes. 7 Rogers Terminal location? 8 Q Do you recall any attempt to address the question 8 A I'd have to speculate. 1 don't remember. 9 of how that past sewer contamination had gotten there? 9 Q The village sewer, does that refer to a separate 10 A 1 don't recall this particular paragraph 10 sewer system that plant sewers -- and if you look up above, 11 obviously. It's more than 20 years ago. The past sewer 11 there's a reference to main plant sewers. 12 contamination presumably was simply the consequence of the 12 A What 1 recall is that the plant sewer eventually 13 ordinary operation. 1 don't think there's-- there is no 13 went into the village sewer, so the village sewer would be 14 reason that 1 can recall to suppose it reflects this 14 the plant plus something else, but 1 didn't get involved in 15 particular incident so much as the operating condition that 15 that area. Other people were working on that part of it 16 we discovered when we began sampling and studying the 16 and 1 had plenty to do. 17 problem. 17 Q On the second page, the last page of that 18 Q Was that understanding shared by others within 18 exhibit, just under the heading of" Pcb levels in the 19 Monsanto, to your knowledge? 19 atmosphere," there's a reference to a nitrogen purge. What 20 A 1 guess so. 20 is that? It says " replacing the nitrogen purge with the 21 Q And what leads you to believe that that was the 21 nitrogen blanket." 22 case? 22 A Well, 1 can tell you just as an engineer what the Savage, James (Aroclor Dept employee) in AETNA (1) Pages 185-188 HARTOLDMONOOIO117 Page 189 Page 191 1 difference is between a purge and a blanket. 1 don't 1 A Well, again, looking at the face of it, 1 presume 2 remember this project. A purge implies that nitrogen flows 2 this is a change, that Rogers trailers are now coming to 3 into the tank and out on a continuous basis as a way to 3 that place instead of where they were before. 1 don't 4 create an nitrogen atmosphere inside the tank, which might 4 remember that particular situation. It fits with the rest 5 be done to keep it dry or something like that. 5 of what we're doing. 6 A nitrogen blanket implies that some kind of 6 Q Let's go to Exhibit 32. Is this a memorandum 7 pressure device has been put on the tank so that a nitrogen 7 that Engman sent jointly - was sent from Engman joint to 8 atmosphere exists inside the tank but there isn't any 8 you and Mr. Papageorge in April of 1971? 9 continuous flow. 9 A Yes. 10 Q And up above in that page under li, it references 10 Q Do you have an understanding as to why this was 11 two projects to be completed, and the first is " paving and 11 sent jointly, does this refer to a different project or 12 trenching the loading and storage areas." Do you see that? 12 program? 13 A Yes. 13 A 1 don't think so. 1 don't know why he did that. 14 Q And that references - that's in connection with 14 Maybe 1 was out of town or something. 15 the Aroclor department, is that your understanding? 15 Q Is that your - some handwriting that says 16 A Yes. 16 " file," do you know whose handwriting that is? 17 Q Are youfamiliar with efforts to pave and - pave 17 A It looks like mine but 1 can't be sure. The 18 those areas? 18 arrow on this document indicates that this copy went to me, 19 A 1 don't remember that project in particular but 19 so 1 suppose it is. 20 that's the kind of thing we were doing at the time. 20 Q Under the entry for" Pcb levels in sewer," the 21 Q Do you recall those areas, the trench loading and 21 last sentence talks about" removing the sludge from the 22 storage areas? 22 treatment plant settling basins." Do you see that? Page 190 Page 192 1 A The pave and trench is a combined verb. Loading 1 A Yes. 2 and storage areas are the subject. 2 Q Do you know what that sludge was? 3 Q 1 see. 3 A No. This no doubt refers to the village 4 A 1 remember generally where the loading and 4 treatment plant because there was no treatment plant within 5 storage area was. It was just adjacent to the department, 5 the Krummrich boundary, but it was outside any area that 6 but 1 don't remember much about it. 6 I've been involved in. 7 Q Do you know what the ground consisted of in that 7 Q There's reference below to the Therminol unit 8 area prior to this time? 8 changeouts. What were Therminol unit changeouts? 9 A Well, the general practice in that plant, as most 9 A Where are you? 10 plants, was to cover the ground with crushed rock, so 1 10 Q Just down below, immediately underli. 11 presume before there was paving, that's what was there. 11 A What was going on here is that it had been 12 Q Under lii, category F states " all Aroclor 12 decided that -- let me back up. Therminol was the trade 13 trailers including Rogers trailers are being washed at 13 name given to Aroclor when it was used as a heat transfer 14 Wgk rip track." What was a rip track? 14 fluid. What this refers to was that at some point we 15 A That was an area in the plant run by the shipping 15 decided it was not sufficient to simply put down curbs and 16 department where tank cars in general were serviced, which 16 so forth but that instead we should simply eliminate the 17 included cleaning them or making minor repairs. 17 use of Aroclor as a heat transfer fluid in our plants, and 18 Q Do you recall there being a concern about 18 changeout means that that conversion was going on, that 19 Aroclors getting into the environment from that location? 19 some other heat transfer fluid was being put into the 20 A No. 20 systems. Usually that required something more than simply 21 Q Do you know why that location appears in Engman's 21 taking out fluid and putting in fluid. Typically there 22 report to you, or at least in this report? 22 would have to be some mechanical changes, the replacement Savage, James (Aroclor Dept employee) in AETNA (1) Pages 189-192 HARTOLDMONOOIO118 Page 193 Page 195 1 fluids would be combustible whereas Aroclor was not. 1 about that time? 2 Q Let's go to Exhibit 33. Could you identify what 2 A It could be, but 1 don't remember. 1 don't think 3 that is for us? 3 so. 4 A This is a letter from me to the operating 4 Q Let me ask you to turn to the second page of the 5 superintendents at the two U. S. plants, and 1 was giving 5 exhibit, and that references a number of different 6 them instructions about how to set up accounts for the 1972 6 projects ; is that correct? 7 budget. 7 A Yes. 8 Q There's a reference to toxicological accounts. 8 Q And the Aroclor scrap rework, is that the matter 9 What does that refer to? 9 we talked about earlier about reworking the Aroclor 10 A That's a little fuzzy in my recollection, but it 10 obtained back from other customers? 11 seems to me that in the early days we collected those costs 11 A Yes, 1 think so. 12 in a separate category ; that is, costs at the plant related 12 Q " Contaminant collection at rip track," do you 13 to solving Pcb problems, and for 1 think probably some 13 know what that refers to, the contaminant collection? 14 historical reasons, that was accounted for -- that name was 14 A No. It sounds just like a routine part of our 15 given to it, toxicological expense, because when the 15 program to do that everywhere. 16 problem was first discovered in the later' 60s, that's kind 16 Q What about" pave under Therminol unit"? Do you 17 of the way it was characterized. 17 know what that entailed? 18 Q As a toxicological problem? 18 A No, 1 don't remember that. That seems like kind 19 A Yes. 19 of an anomaly because it refers to Therminol unit, but it's 20 Q Did you have responsibility relating to other 20 talking about 246, which is the Aroclor department. Maybe 21 toxicological accounts? 21 there was a Therminol heater in the Aroclor department but 22 A No. This just refers to plant accounts, and that 22 1 don't remember that. Page 194 Page 196 1 would be the only place where 1 would have a concern. 1 ( Savage Exhibit 35 identified. ) 2 Q Who is A. J. Koenig, K-o-e-n-i-g? 2 By Mr. Brock: 3 A Art Koenig was our business group accounting 3 Q For the record, I've marked Exhibit 35, and the 4 manager. 4 Bates numbers are 0248589 through 92. 5 ( Savage Exhibit 34 identified. ) 5 My first question, Mr. Savage, is just whether or 6 By Mr. Brock: 6 not this is one of the memoranda that you sent to Bill 7 Q I've had Exhibit 34 marked, and the Bates numbers 7 Papageorge in or about April of 1971. 8 are 0292923 through 926. 8 A Yes. 9 Mr. Savage, is this a memorandum you received 9 Q Let me ask you to turn to the second page where 10 from Mr. Stewart in the ordinary course of your employment 10 it's talking about project evaluations, and specifically 11 with Monsanto? 11 number 2 where it says " samples from 36 storm sewers 12 A Yes. 12 recently repaired to avoid infiltration show definite 13 Q Did Stewart replace Engman in some capacity at 13 decrease in Pcb." Do you see that? 14 the Krummrich plant? 14 A Yes. 15 A 1 think so. 1 think Ed Stewart was working for 15 Q You can see that that's referring to the Anniston 16 Bill at that time. 1 don't know why the change in 16 plant; correct? 17 reporting occurred here, but this is obviously the same 17 A Yes. 18 kind of report that Bill had been sending me. 18 Q Are you familiar with storm sewers at the 19 Q Engman is listed as a copyee on the right-hand 19 Anniston plant being repaired around this time frame? 20 column. Do you see that? 20 A No, 1 didn't remember that at all. 21 A Right. 21 Q Do you recall the sewers at the Anniston plant 22 Q Do you know whether he changed positions in or 22 being repaired or replaced at any time? Savage, James (Aroclor Dept employee) in AETNA (1) Pages 193-196 HARTOLDMONOOIO119 Page 197 Page 199 1 A No, it's not remarkable. It's an old plant. 1 1 correct? 2 don't remember it. 2 A That's right. 3 Q Do you recall it coming to your attention that -- 3 Q Let me ask you to turn to the second page of 4 let me rephrase it. Do you recall ever hearing or learning 4 Exhibit 37 under the project that's given a number of 5 that Pcbs were thought to be, or that there was a 5 2422. The last sentence in that reads " major sewer to be 6 possibility that Pcbs were leaking from the sewers at the 6 installed to north Edc extended to 10/1/71." Do you see 7 Anniston plant? 7 that? 8 A 1 don't remember that. 8 A Yes. 9 Q 1 take it you just don't recall what the impetus 9 Q And then in Exhibit 38, that information - you 10 was for that project or what it involved? 10 transmit that information to Mr. Papageorge on the second 11 A No. 11 page of Exhibit 38 ; is that correct? 12 ( Savage Exhibit 36 identified. ) 12 A Yes. 13 By Mr. Brock: 13 Q Do you recall a project involving a major sewer 14 Q In what may be a futile attempt to refresh your 14 to be installed to the northern part of the Krummrich plant 15 recollection, I'll show you Exhibit 36, and my first 15 in or about this time? 16 question is whether or not this is a memorandum that you 16 A No, 1 don't know what that means. 17 sent to Mr. Papageorge in or about June of 1971. 17 Q What is Edc? 18 A Yes. 18 A Estimated date of completion. 19 Q If you'd turn to page 3 under projects and 19 Q Do you recall any projects involving 20 evaluations, up near the top, entry 2 reads " the 36-inch 20 installation, replacement or repair in the north area of 21 sewer repairs have accomplished a goal of minimizing 21 the Krummrich plant at or around this time? 22 Aroclor infiltration into storm sewer." Do you see that? 22 A I'd be a little careful about characterizing that Page 198 Page 200 1 A Yes. 1 as north area. North area referred specifically to a hunk 2 Q Does that refresh your recollection at all as to 2 of the plant that was across the highway and which 1 3 that repair, storm sewer repair project? 3 believe by that time had been sold to Edwin Cooper. 1 4 A It seems like something maybe 1 ought to remember 4 hardly think that this went to what we call the north 5 but 1 don't. 5 area. 1 think he refers to it as the compass direction as 6 ( Savage Exhibits 37 and 38 identified.) 6 to where the sewer is going to be installed. 7 By Mr. Brock: 7 Q You're probably right. 8 Q For the record, I've marked Exhibits 37 and 38. 8 A The north area would be a long way away. 9 37 is dated September 1, 1971 and has Bates numbers 0292977 9 Q Do you recall a major sewer that was to be 10 through 980, and Exhibit 38 is dated September 9, 1971 with 10 installed in connection with the Aroclor department at that 11 the Bates numbers 0008722 through 8725. 11 time? 12 Mr. Savage, is Exhibit 37 a September 1, 1971 12 A No. 13 memorandum that you received in the ordinary course of your 13 Q On the third page of Exhibit 37 - and it's 14 employment with Monsanto? 14 repeated on page 2 of Exhibit 38 - there's a reference to 15 A Yes. 15 routine and special sewered samples. Do you see those 16 Q And Exhibit 38 is a memorandum that you sent to 16 references? 17 Mr. Papageorge in the ordinary course of your employment 17 A Yes. 18 with Monsanto? 18 Q What were special sewer samples? 19 A Yes. 19 A 1 can interpret the sentence as 1 read it, but 1 20 Q And in Exhibit 38, you transmitted the 20 don't remember anything in particular. We of course did 21 information that had been transmitted to you in Exhibit 37 21 have routine samples. A special sample would be something 22 along with information concerning other plants ; is that 22 simply to answer some unusual question as part of the Savage, James (Aroclor Dept employee) in AETNA (1) Pages 197 - 200 HARTOLDMON0010120 Page 201 1 investigation. 2 Q Do you recall what special question that was? 3 A No, no idea. 4 Q Let me takeyou to the Anniston section of 5 Exhibit 38, and under regulatory action it mentions a 6 visit, an August 19 visit to the plant by two Epa 7 representatives and a representative of the Awic, Alabama 8 Water Improvement Commission. Do you see that? 9 A Yes. 10 Q Do you recall Epa representatives or Awic 11 representatives visiting the Anniston plant to take Pcb 12 samples? 13 A No, 1 was not at the plant at the time, and I'm 14 simply repeating what the plant has reported. 15 Q Do you recall raising the question of why the Epa 16 or the Awic wanted to take samples at the Anniston plant? 17 A No, no. 18 Q Do you recall being concerned about that? 19 A No. This would not have been particularly 20 remarkable. It was well known that both the state and 21 federal government were concerned about Pcbs and no doubt 22 collecting some information. 1 don't think we felt we had Page 202 1 anything to hide. This would not have been a big surprise. 2 Q Do you recall there being any consideration given 3 to whether or not the Epa or the Awic might have served 4 some type of claim against Monsanto with respect to Pcb 5 effluents from the Anniston plant? 6 A 1 have no idea. 7 Q That was not something that you recall 8 discussing? 9 A No. 1 would not have been surprised that the 10 state or federal government were interested in this issue. 11 1 wouldn't have bothered about what the specific reason was 12 for this visit. 13 Mr. Brock: 1 see we've come to 5: 30. 14 ( Whereupon, at 5: 30 p. m. , the deposition was 15 adjourned, to reconvene at 9: 30 a. m. , on Wednesday, May 19, 16 1993.) 17 ------------------------- 18 James R. Savage Savage, James (Aroclor Dept employee) in AETNA (1) Pages 201 - 202 HARTOLDMON0010121 [& - 40] Transcript Word Index & 1262 1971 25 & 1:9 2:2__________________ 0 56:15 13 154:13 14 3:14,15 183:9 184:18 134:19 184:7 187:16 191:8 196:7 197:17 251 198:9,10,12 153:6 1972 26 00 144:19 166:10 167:20 18:20 193:6 130:3 184:11,18 185:18,21 1:19 15 1973 27 0008722 40:20 166:9 18:21 88:10 184:11 185:19,22 186:1 198:11 150 1975 270 0048 107:21 15:11,13,14 112:8 170:19 171:6 52:22 16 1977 28 0248589 169:2 15:17 163:18 164:4 196:4 17 1978 29 0292923 173:19 175:11 15:19,20 3:11 117:11,15 163:18,19 194:8 1792817 198 163:20 0292977 198:9 0407871 154:14__________________ 1 1 3:8 49:14,15 50:5 52:20 83:22 84:1 144:20 167:20 170:5 174:19 187:16 198:9 198:12 10 1:19 32:7 120:9,16 147:3 153:1 162:11 179:19,22 180:8,11 186:5 10/1/71 199:6 100 86:22 146:6,7 1016 137:16 11 151:1 153:2 179:18 117 3:11 118-1 1:8 12 83:21 153:2 162:11,12 176:17 179:17 1220 1:18 1221 56:3,6,10,15 1242 56:4,7,14 137:15 1248 56:4,7,14 1254 56:14 1260 56:14 49:16 1792839 50:4 18 1:15 154:13 179:1 187 3:12 19 179:5 201:6 202:15 19103 2:12 194 3:13 1957 10:14 12:16 17:1250:15 125:16 1958 13:7 22:7 24:5 196 3:14 1963 14:1 22:7 84:10 157:9 1967 14:11 107:10 157:10 1968 115:16 1969 115:16 197 3:15 1970 15:2,3 107:10 112:8,9 114:19 118:3,11 121:10 122:17 124:13 130:3,16 131:7 134:19 136:16 140:17 144:9,20 147:4,19 151:2 153:3 154:14 157:14 162:5 166:10 167:20 174:19 175:12 179:18 180:8,9 3:16 19801 2:5 1982 16:6,7 1993 1:15202:16 2 2 3:9 50:1,18,20 51:13 52:4 139:22 169:19 184:18 185:18 196:11 197:20 200:14 20 174:19 186:11 200 86:14,19 2005 2:11 22 179:8 221 100:22 103:1 104:19 110:1 110:1,17 111:3 222 100:11 23 182:7 231 89:11 232 86:8 239 169:20 170:2 24 183:8 2422 199:5 246 151:18 195:20 3 3 3:10 87:19,21 95:7 120:17 128:10 130:15 131:21 132:8 183:14 185:19 186:1 197:19 30 3:12 40:22 71:16 83:21,22 145:2 187:12,15 202:13,14 202:15 300 73:7 32 68:14 191:6 33 3:12 187:12 193:2 34 3:13 68:14 194:5,7 35 3:14 145:2 196:1,3 350 2:3 36 3:1565:18 196:11 197:12 197:15,20 37 3:16 198:6,8,9,12,21 199:4 200:13 38 3:16 198:6,8,10,16,20 199:9,11 200:14201:5 4 4 3:4,5,11 117:11,14,20 129:7,14 130:14 131:6 147:3 40 48:2,8 66:14,20 71:16 72:12,14 73:9,10,10 74:20 84:1 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010122 [45 - alleviate] 45 80 161:21 40:22 55:14 49 849 3:8 53:17 56:2 5 5 120:2,4,6 151:1 183:9 202:13,14 50 3:9 24:14 179:14 180:1,7 5000 128:11 50s 71:7 58 17:12 6 6 120:9,9,10,13,13 142:11 161:6 60s 18:1991:14 115:4 193:16 63 106:11 67 106:12 7 855 49:17 50:4 862 52:21 87 3:10 8725 198:11 875 57:14 88c 1:8 9 9 198:10 202:15 9/1/71 3:16 186:5 9/9/71 3:16 902 2:4 92 196:4 926 7 194:8 130:2,14,18,20 131:13,20 938 161:19 175:12 180:8 50:5 70s 980 18:15 198:10 71 136:16 72 136:16 742 176:18 75 114:19 7788 154:15 78 15:18 782 159:1 783 159:1 8 a abbreviation 20:6 26:4 35:13 100:19 able 29:20 34:17 45:5 77:15 87:16,17 89:21 103:11 158:17 absolute 181:6 absolutely 181:1 absorbed 140:1 absorber 75:10,15,16 acceptable 27:16 162:7 8 accepted 118:13 120:2,13 130:15,15 21:21 130:18,21,22 131:7,13 accommodate 143:14 146:12 10:8 accomplish adjusted 181:6 72:4 accomplished adopt 197:21 139:2 accounted adopted 177:17 193:14 29:22 accounting adverse 194:3 119:16 181:8 accounts aeration 193:6,8,21,22 39:1840:1941:5,10 accumulate aesthetic 31:19 157:17 27:17 accurate aetna 121:14 1:9 acid afternoon 20:2 21:11 29:16,19 39:17 84:1 46:1447:14,1863:1571:14 ag 75:7,17,18 76:11,12 77:6,7 134:8 77:12 104:4 106:1 agencies acidic 78:1 83:11 71:19 agency acl 165:11,16,22 166:4 175:19 153:7 agenda action 163:4 1:7 49:13 133:5 149:13 ago 175:13 183:22 201:5 4:21 16:5,1442:1681:17 activated 86:18 95:9 162:8 186:11 33:18 39:4 161:8,17 agreed active 98:20 72:19 agreement add 34:10 103:8,9 162:13 163:7 agricultural added 108:11 46:4 53:7 57:4 58:18 72:17 ahead 73:4 116:19 142:13 181:9 adding aid 103:12 43:14 58:18 addition air 35:8 96:5 179:18 24:17,20 28:20 29:5 31:8 additional 34:1 41:2,3 42:20 59:11 48:1 57:4 60:7 64:6 66:11 74:13,16 address 91:6,10 141:9,12,17 11:10 19:14,18 29:12 33:16 al 180:22 186:8 1:10 addressed alabama 11:7 12:5 19:12 118:1 4:15 175:16 176:8 201:7 181:3 alive addressees 55:13 133:10 163:22 alkali addressing 89:8 12:1022:1,4 91:19 163:6 alkaline adjacent 71:14 40:641:11 190:5 allegations adjourned 80:12 107:4 202:15 alleviate 122:14 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010123 [allow - assignments] allow anniston (cont.) applications (cont.) aroclor (cont.) 44:16 62:7 72:12 77:19,22 78:12 143:4 119:21 125:18 126:5 127:4 allowed 79:5,6,21 80:13,19 83:8,10 appreciate 127:10 130:9,13,22 131:4 44:19 84:21,22 85:5 94:4 95:12 26:5 131:10,16 135:19,22 136:3 altogether 108:15 112:5 113:5 114:13 approach 136:7 137:12 138:3,19 15:21 114:15 127:20 128:15 147:15 140:15,16,17,18,21 141:7,9 amalgam 146:13,19 147:2 148:21,21 appropriate 141:12,14,17 142:5,14,18 65:13 157:21 163:3 173:22 176:2 34:14 136:22 142:20 143:3,9,10,21 144:6 amateur 183:2 196:15,19,21 197:7 approval 144:10 145:13 146:2,5,10 81:21 201:4,11,16 202:5 51:12 128:7,11,12 182:14 147:5,9 148:14 153:13,14 ambient annual approve 154:8 155:18,21 156:8 61:1 61:1862:1,1791:8 51:15 128:10 182:15,17 157:15,20 158:9 164:18 ambiguous anode approved 165:6,6 170:20 171:5,9 132:7 178:1 68:2 51:16 182:16 172:3,7 177:17 187:1 amendment anodes approximately 189:15 190:12 192:13,17 50:2 65:6 67:22 68:9,12 95:13 69:11 82:8 193:1 195:8,9,20,21 197:22 amendments anomaly april 200:10 50:17 51:4,7,17 195:19 3:14 118:15 124:13 129:8 aroclors ammonia answer 129:16 191:8 196:7 116:2 135:20 145:16 159:7 102:3,3,5,14 65:22 74:4 162:4 200:22 aquatic 159:15,19 160:5 190:19 ammonium answers 129:20 arose 102:12 10:5 aqueous 111:17 123:3 amount anticipated 43:9 59:8 63:11 64:3 66:16 arrival 6:7 20:10,21 34:15 39:21 133:3,8 138:7 149:7 arbitration 49:10 42:22 43:6,12,15 44:11 anticipation 1:9 arrived 57:5 60:1 63:1 67:8 94:21 157:18 arduous 24:5 33:2 40:12 89:17,20 104:6 110:11 111:7 122:5 antioxidant 61:4 91:15 106:17 141:11 146:8 172:19 area arrives amounted anybody 28:7 70:4 71:21,22 72:2 167:7 128:19 58:10 78:20 83:1 116:17 79:17 80:6 82:3 89:20,22 arrow amounts 117:5 126:6 150:5,19 166:2 91:21 92:1 94:17 95:2,6,7 191:18 59:3 60:8 66:4 142:18 175:4 95:15 129:10 147:10,18,19 art 143:5 anymore 148:12,13 149:2 169:21 127:16 194:3 anaerobic 75:13 172:21 170:8 171:4 172:5 188:15 article 39:6,15 anyway 190:5,8,15 192:5 199:20 116:16 analytical 38:14 60:7 80:10 200:1,1,5,8 articles 78:15 107:18 121:14 apparatus areas 116:18 ancillary 69:21 92:8 148:5 171:8 172:6 asbestos 87:13 apparently 189:12,18,21,22 190:2 94:12 anderson 88:10 116:20 154:10 arisen aside 2:2 appear 114:20 61:13 angoli 130:7 164:4 arising asked 99:18 101:1 105:9 appearances 145:18 81:18,22 82:14 116:1,7 animal 2:1 armstrong asking 160:4 appeared 133:13,14 10:4 32:17 117:16,18 animals 34:16 119:12 145:21 aroclor aspirin 119:16 185:11 3:8 46:4,7,14,15,20 47:7 20:3 anniston appearing 48:3,11 50:3,9 51:6 52:1,9 assign 4:15 6:7 13:6,8,11,14,22 180:7 52:15 53:12,21 54:1,2 98:21 21:6 22:9,15 23:2,16 27:17 appears 55:16,20 56:3 57:17 58:15 assigned 28:7,21 29:7 31:5 33:2 34:2 131:9 164:8 173:21 186:2 58:17 59:3,9,19,22 60:5,8 100:2,3,6,16 101:2 108:2 34:6,10,17 36:1,5,7,11,12 190:21 60:10,20,20,21 61:8,9,14 112:12,16 124:7 36:15,22 37:2,10,13,19 application 61:15,15 62:10,20 63:2,8,8 assignment 38:21 39:3 40:12 41:22 137:12,13 74:22 75:14,20 96:6 97:7 19:3 45:13 123:20 45:11 46:10 47:22 50:3 applications 97:12 98:12 99:1 101:9 assignments 53:14 55:17 58:8 59:14 138:18 139:1 142:15,22 106:2 113:5,7,14 118:2,8 15:15 19:8 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010124 [assistant - bottom] assistant 12:22 13:13 17:11 19:7 22:3,10,12,16 23:2 42:21 assume 157:12 164:19,21 assumed 138:13 astonished 115:9 atlantic 158:12 atmosphere 66:12 67:2 69:19 74:18 164:10,13 188:19 189:4,8 atmospheric 53:4 attach 122:7 attached 148:7 164:5 attack 132:19 133:1 attempt 186:8 187:5 197:14 attention 32:14 107:6 133:12 157:1 162:22 173:4 177:9 197:3 attorneys 81:20 attributing 81:8 august 147:3,19 151:1 153:2 154:13 157:14 166:21 179:18 180:9 201:6 autoclave 73:5,6,13 automated 97:22 available 68:14 90:12 average 137:6 avoid 181:8 196:12 aware 41:13 108:21,22 109:2 140:7 144:15,18 145:19 146:9 166:2,22 175:4,18,2 aways 47:3 awic 201:7,10,16 202:3 b behalf biomagnified bachelor's 1:21 2:6,13 119:15 10:12 belief biphenyl back 138:16 59:21 13:1829:547:3 65:17 believable biphenyls 67:12 71:20 72:5,7 73:15 123:10 115:7 73:18 79:19 96:10,22 111:8 believe birds 111:12,21 125:3 131:6,20 50:21 55:3 107:10 108:12 115:8 143:3 154:19 162:19 124:8 131:13 154:8 165:2 birth 167:20 175:11 179:17 167:3 169:8 186:21 200:3 160:22 184:2 192:12 195:10 believed bit backed 146:1 68:15 171:12 178:1 77:16 bell black background 89:12 61:1281:15 10:9 belong blanket bad 152:11 188:21 189:1,6 26:22 80:3 185:11 benzene blended bank 152:10 6:7 152:4 bergen blew barge 112:17,20 126:2,8 128:13 41:2 152:10 129:1 182:18 blow barker best 141:4,6,12,16 47:16 26:22 67:19 157:7 blowing barracks better 59:11,17 60:7,7 63:22 152:22 19:19 122:21 124:9 127:5 141:7 based beyond blown 34:9 145:20 156:10 111:5 141:9 basically big board 182:18 32:2 61:21 62:16,21 64:9 36:1,12 145:10 basin 96:11 103:3 124:5 143:7 bob 140:10,14,14,16,19,20 172:10 202:1 33:6 45:19 99:18 100:5 141:2 147:9,21 bigger 101:16 118:1 130:21,21 basins 9:8,11 131:15 154:3 39:18 40:19,20 41:4,5,10 biggest boil 191:22 24:22 137:12 149:22 25:13 basis bill boiling 21:1648:16 145:5 189:3 19:2 30:8,19 84:17 85:2,4,4 165:7 batch 85:18 114:17 118:2 120:6 book 32:6 45:6 51:20 73:16 125:20 126:3,11,21 129:4 11:15,19 74:16 101:19 142:20 130:6,20 131:2 133:2,11 borrow batches 153:4,5 154:16 164:5 168:6 56:11 31:19,19 57:4 168:12 169:14,18 179:10 boss batchwise 182:9,19 185:6,9 194:16,18 17:14 18:22 32:21 33:1 60:4 111:18 196:6 45:18 bates billion bother 49:16 50:4,5,6 52:20 53:17 162:12 179:14 166:7 56:2 57:13 154:14 159:1 bill's bothered 164:6 194:7 196:4 198:9,1' 132:8 29:3 202:11 bed biodegradable bottle 30:4 37:20 38:4,5,6,11 137:17 123:4,19 39:17,22 40:1,1,2,6,8,11,11 biodegradation bottom 40:17 41:5 63:19 67:4 77:1 161:7 39:8 53:18 54:15 57:14 began biodegrade 65:16 69:18 106:2 120:4 66:13 118:12 186:16 119:14,15 123:15 163:19 175:12 beginning biological 185:20 187:19 60:12 168:5 39:19 161:18 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010125 [bottoms - changing] bottoms buckley capabilities causing 98:11 106:5 157:15 106:14,15,19 121:10 129:19 bought budget capacitors caustic 142:14 193:7 137:14 142:16,20 64:16,20,20 94:16,19,20 boundary buffer capacity caution 102:16 192:5 31:21 24:17 42:19 90:11 103 74:3 box building 103:17 194:13 cease 88:15 2:3 29:9 capital 167:5,11 boxes built 128:5 182:14 183:3 ceased 183:15 34:11 36:2,6 71:7 91:14 capture 29:7 167:17 break 156:11 177:5 122:8 cell 10:841:1742:9 bunky captured 65:11,1766:21 67:1271:16 breakage 78:5 176:6 140:15 71:18 87:12 88:16,20 89:1 90:10 burned car 89:4 91:13 93:21 94:4,4,6 breathe 27:4 147:10 94:10,15,17 95:4,11 31:22 burnett carbon cells breathing 2:1 38:4 41:16 74:3 83:20 33:18 65:5 75:18 76:3,. 65:2,3,4,7,18,19 66:19,19 69:20 120:4 132:6 180:2 138:1 67:22 68:9,10,11,14 72:4,8 bridge burns carbonees 88:21 89:2,19 90:7 91:17 152:21,22,22 47:17 130:8 94:1,8,22 briefly busiest careful center 59:18 64:11 93:18 105:3 136:17 123:17 199:22 37:2 139:6 144:19 business carefully certain brine 6:17,18,19,21 10:18 16:22 62:5 122:8 55:22 57:5 117:15 119:14 64:21,22 65:1,6,9 66:5 17:3 18:15,16,17,18,18 carnivorous 128:6,10 182:14,15 67:12 68:20,20,22 69:1 103:5 112:12,14,15,17 115:8 certainly 70:3,4,9,17 71:1,12,15,18 118:19 121:6 124:3,5,6 carondolet 93:17 122:20 129:4 133:3 71:21,22 72:3,4,7,9,10 126:9 129:2 138:4,12 152:17,18 135:7 158:11 89:20,22 91:21 92:1 94:9 146:11 150:2 168:2 169:4 carried cetera 94:12,14 95:2,2,3,5,6,7,15 179:3,6 181:9 194:3 76:7 164:11 brink businesslike cars chain 29:14,21 30:1 141:15 163:12 77:16 190:16 57:3 119:15,17 broad c case challenge 172:9 broader caffeine 21:12 1:10 5:12,13 7:17,21,22 8:2 77:8 8:6 9:14,16 16:17 37:10 chance 130:21 cake 52:12 72:17 137:18 186:22 11:18,21 50:22 74:4 117:20 broadly 105:17 135:18 142:6 brock 2:7 3:4 4:7,9 13:15,17 38:8 41:19,20 42:8,11 49:15,22 43:12,16 58:16,21 59:1 calcium 95:19 California 115:6 castle 1:3 casualty 1:9 catalyst 159:2 160:18 166:10 change 16:10 22:21 29:11 44:20,21 53:10,11 96:15 99:9 121:19 169:13 191:2 194:16 50:11,19 74:6,8 84:7 87:20 96:14 117:13 120:8,12 132:17 163:16 180:4,5 187:10,14 194:6 196:2 197:13 198:7 202:13 call 113:17 185:8 200:4 called 1:164:46:19,21 7:2 8:19 20:7 22:11 25:14 26:7,8,14 60:2 72:17,18 73:4,4,14,15 73:16 catch 140:13 147:9,21 categories changed 13:1221:22 58:7 112:18 137:14 194:22 changeout 192:18 broke 26:17 29:14 37:8 38:7 48:2 53:3,6 139:5 changeouts 42:12 brought 53:21 64:14 54:4 55:11 60:5,12 65:12 72:15,18 88:18 category 53:5 129:7 139:22 143:15 192:8,8 changeover 63:4 72:4,16 73:7,9 107:6 124:15 bubble 89:2 92:10 93:5,6 94:15 95:16,18 103:4 107:16 108:19 110:1,7,16,17 111:4 144:20 147:4,6 151:12 158:22 183:14 190:12 193:12 65:18 changes 44:17,20,22 91:19 101:21 41:3 bucked 137:15 140:6 149:5,15 172:18 185:6 cathode 65:5,6 121:21 192:22 changing 168:6 cannister caused 44:14 51:20 57:16 33:18 159:20 160:22 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010126 [channel - composition] channel chlorine (cont.) clients commercialization 168:21 91:10,12,22 92:3,4,6 93:16 17:9 164:22 30:3 characterized 94:22 96:5 97:4 cliff commission 74:21 193:17 chloro 79:3,7,9,11 175:16 176:9 201:8 characterizing 89:8 clock committee 199:22 chlorobenzene 49:9 181:19 characters 105:20 close common 47:5 chlorobenzenes 185:2 103:4 109:6 charge 96:7 closed commonly 37:17 130:12 134:11 chosen 72:8 98:18 chat 129:10 151:7,16 closely communicating 170:20 171:2 chronology 105:11 185:14 181:12 checking 13:20 cloud communication 48:22 49:6 chunk 27:18 30:19 chemical 68:4 coat community 10:13,20 12:22 13:12 17:11 city 61:9 25:4 79:22 80:14 119:11 19:7 21:722:3,10,12,12,16 34:10,10,13,18,22 36:13,15 coating companies 22:16 23:2 26:17 35:13 36:19 37:1,4,5 39:3 40:17 171:16 4:11 72:22 149:10 42:22 44:4 77:20 99:15 113:11 coley company 103:5 108:1 109:6 153:8 civil 78:5,14 1:5,9 2:6,14 4:9 8:1,2,9,9 chemically 1:7 collect 8:10 9:3 17:4 30:2 101:5 25:21 72:19 106:7 claim 21:20 35:2 74:10 124:17 149:13 150:3 chemicals 4:11 81:3 159:14 202:4 collected 156:20 181:8 11:6,16 12:6,7,12,14 31:10 claimant 29:15,18,1931:5 43:17 compare 35:16,17 40:5 41:10 80:5 7:13,22 8:1 44:2 141:18 193:11 130:14 113:12 134:12 172:12,15 claimants collecting compared 172:17 83:4 201:22 125:7 chemist claimed collection compartment 35:21 107:19 9:8 81:11,13 195:12,13 94:10,12,13 chemistry claiming color compass 10:22 5:19 9:3,10 81:5 83:6 159:6 35:11 200:5 chemists 159:19 colorful complained 107:20 claims 47:4 80:15 Chicago 8:5 41:9 63:7 79:16 80:4 Columbia complaint 5:18 107:4 159:18 161:3,4 1:20 5:11 28:9 32:12 chief clarify column complaints 107:19 29:10 93:3 194:20 28:6 32:8,15 63:8 67:15,18 chloride clarity combat 79:17,22 80:5 102:11,13 60:2 64:13,18,18 65:1 66:1 186:3 180:18 completed 66:1 67:13,13 71:13,17 clarrie combination 33:5 36:8 89:19 91:14 72:6,9,10 94:5,6 153:8 106:14,15,15,19,20 34:18 110:14 101:17 148:2 189:11 chlorinated clay combined completely 54:9,11 106:8 115:7 43:14,16,17 58:17 59:2 190:1 108:9 132:4 138:6 170:6 chlorination 60:12 combustible completion 75:14 141:8 clean 193:1 104:5 139:14 199:18 chlorinator 8:8 43:15 61:6,13,15 149:2 comfortable complex 60:3,5 183:14,18 184:2 49:20 111:17 chlorinators cleaned coming complicated 60:3 62:20 63:2,5 71:21 173:16 102:14 170:7 177:11,19,20 26:2 65:18 94:21 104:2 chlorine cleaning 191:2 197:3 110:3 111:1,10 45:13,15,21 46:4,22 64:10 173:14 190:17 comment component 64:12,13,14,15 65:2,8 cleanup 162:4 27:1 35:9 68:1969:1,1,2,5,19 71:19 61:16,21 62:16 149:11 commerce components 86:2,2,5 87:11,12,13,15,16 150:6,21 2:9 76:20 26:21 119:14 88:6,10,16,18,20,22 89:15 clear commercial composition 90:1,4,6,6,9,14,18 91:1,4,5 10:7 74:12 108:13 139:2 158:2,5,16,17 44:5 110:19 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010127 [compressing - course] compressing consideration content copy 66:13 87:18 158:13 202:2 11:11 16:6,10 122:3 12:2 118:4 138:1 146:13 compressor considerations contents 148:7 191:18 42:20 11:12 52:19 53:2 copyee compressors considered context 154:2 194:19 41:1 70:11 153:18 187:2 5:1 9:18 corder computer considering continued 114:15 176:5 10:19 162:5 1:22 84:6 175:15 corlew concentrated consist continues 114:17 127:15,17 94:18 21:1525:11 39:1240:19 158:22 corlew's concentration 43:16 54:8 63:13 68:3 continuing 120:6 35:11 71:16 111:22 166:18 corner concentrations consisted continuous 50:21 127:7 27:7 25:20 30:3 39:17 44:2 59:1 27:1351:21 101:18 123:18 corporate concept 59:2 60:7 75:8 93:19 189:3,9 17:22 30:16 103:7 104:10 106:7 190:7 continuously corporation concern consistent 28:4 60:4 149:16,19,21 170:11,13 176:21 190:18 123:10 144:6 147:15 187:3 control correct 194:1 constructed 77:22 106:10,20,22 118:2,8 19:9 25:8 53:14 67:20 concerned 37:11 119:21 125:18 126:6 127:4 88:15 91:12 100:14 130:3 156:6 201:18,21 construction 130:10 135:2,16 141:21 134:20 138:4 146:6 151:12 concerning 90:13 146:16 151:3 165:11,16,22 179:15 195:6 196:16 199:1 46:7 53:6 79:12 83:11 consult 166:4 182:10,13 199:11 127:9 133:1 135:15 150:20 11:21 controlled corrected 181:12 182:5 184:13 consultant 123:13 120:19 198:22 16:22 controlling correctly concerns consumed 124:1 129:21 5:13 15:8 65:22 122:11 67:16 67:22 71:18 convenient 143:8 153:7 concrete consumption 41:1642:8 91:3 correspondence 41:1261:10 145:20,20 conventional 3:12 condition contact 39:4,9 161:17 165:17,19 corrode 33:3 48:22 49:6 186:15 30:18,19 77:21 116:20 conversant 71:1 conditions 175:15 185:2 122:1 corroon 27:1944:14,1661:1 123:7 contacts conversion 2:2 156:10 177:21 78:8 79:4 83:11 175:18,20 192:18 corrosion confident 176:8,11 converted 68:21 69:19 71:3 76:11,14 178:12 contain 21:3 94:15 95:4 90:18 confusing 74:17 conveyed corrosive 177:12,14,21 contained 165:21 68:21 71:8,11,20 76:19 congressional 6:1 9:12 102:3 137:19 conveyor 90:8 181:19 container 99:11 cost conjunction 76:7 coolers 34:15 43:2 178:9 containers 90:9 costs connected 43:18 cooling 193:11,12 5:10 34:7 contaminant 87:18 89:18 90:3,8,10 couer connection 195:12,13 cooper 15:6 16:2 116:13 5:2 7:8 62:11,17 67:16 contaminants 200:3 country 81:19 82:18 140:7 157:20 143:5 coordinate 156:19 161:13 189:14200:10 contaminated 30:10 county consequence 142:21 159:7,14 166:18,22 coordination 1:3 186:12 183:15 17:21 18:9,13 30:15 couple consider contamination coordinator 15:16 20:7 32:3 51:3 62:18 164:10 107:5 143:1 149:2,11 150:7 126:11,14 70:10 99:19 considerably 160:4 183:18 184:2 185:21 coproduction course 94:8 186:5,9,12 187:6 64:16 9:12 11:6 24:1335:7 59:3 66:12 68:1 69:21 85:19 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010128 [course - deposition] course (cont.) customer deals 97:9 107:3 121:12,16 126:8 8:15,16,16 143:6 156:7 131:21 132:8 162:21 166:15 168:2 169:4 customers dealt 174:9,12 177:10 179:2,6 5:10 142:14 143:3,11 165:14,16 183:11 184:9 187:17 150:18 195:10 dean 194:10 198:13,17 200:20 cv 52:6,12 courses 1:8 debottlenecking 10:15,17,21 11:2,5,9,11 cyanuric 103:4 12:5,8 153:7 december court cycle 174:19 180:8 1:1 7:2,17 9:16,18 10:4 58:20 73:8 74:16__________ decide 74:6 cover 34:15 171:3 190:10 covered 11:13 covers 173:22 cows 159:6,14 cracked 41:14 cramper 85:18 create 189:4 created 56:22 58:15 66:6 76:2 95:10 137:21 creates 27:6 creek 37:8,8,19,22 63:20 67:5 77:1 creve 15:6 16:2 116:13 critical 143:1 crude 60:5,8,10,10,20,21 75:18 104:7 141:9 crushed 70:4,6 171:2 190:10 crystallization 110:15,20,21 111:18 crystallized 94:18 111:1 curbs 147:8,21 192:15 curious 166:2 current 65:7 70:2 94:14 145:1 161:21 curry 47:16 d 163:5 daily 145:5 dallas 133:14 decided 34:20 54:20 143:2 192:12 192:15 decision dalton 138:8,11,14 134:5,6 damage decomposer 65:12,17 80:15 81:12 159:20,20 damaged 81:6 decomposers 66:9 decrease dan 85:15 97:11,20 99:7,13 196:13 dedicated dangerous 11:1669:2 91:4 darryl 55:22 deep 40:21 134:15 data defects 160:22 21:20 31:6,6 35:2 139:8 defendant date 139:8 199:18 dated 50:1588:9 118:11,13 120:9 120:16,17 130:3,15 144:20 9:20 defendants 1:11 82:12 defined 21:17 147:3 151:1 153:2 154:13 definite 166:9 167:20 174:19 175:11 198:9,10 dates 139:14 dave 196:12 degree 10:12,20 18:1 97:22 121:9 121:16 degrees 114:16 day 21:15,1527:1432:7 45:15 45:1548:15,15,16,1681:15 83:22 145:2 161:21 10:15 delaware 1:2,14 2:3,5 delay 64:11 days delegated 23:18 55:11 62:5,18 77:7 168:15 193:11 48:22 demand deal 143:7 165:22 181:21 dealing 77:4,6,12 demanding 143:4 135:15 160:12 166:3 dealings demister 29:15,18,21 141:4,14 149:18,21 158:7 demisters 141:15 dennis 134:3 denora 65:4 88:16 89:1,2,4,21 91:11,13,22 93:22,22 95:11 96:1 department 14:8 17:19 18:3 20:18 21:1323:7,9,12,13,15,21 24:2,11 25:5,17 32:17,18 32:22 34:8,8,13,19 35:6 36:5,8,10,19 37:3 38:18 39:2 41:7 42:6,18 43:1,8,21 44:7 46:4,5,7,14,15,19,20 47:7,15 48:2,3,11 49:1 51:7 51:8 52:1,9 53:12 54:17 55:7,8,10 58:15 59:6,9 61:8 61:16 62:11 63:9,18 64:4,6 64:10,12,14 66:14,17 72:16 73:12 74:9,14 75:14,20 76:6 77:9 79:9 84:12 85:2 86:15 87:10 88:19 89:8,11 90:19 93:14,16 94:20 96:6 96:6,11 97:12 100:1,4,5,7,8 100:10,15 101:1,3,10,13,15 101:22 102:2 103:1,1 104:19 105:2,4,9,12,14,20 105:21 110:1,2 111:8 124:11 130:13,22 131:2,10 132:10 134:1 135:19 136:1 140:12 145:14 146:5 147:5 147:9 151:4,18 153:6,7,10 154:4,8 168:13,21 169:20 170:2,6,9,12,14,19 171:6 178:20,21 187:1 189:15 190:5,16 195:20,21 200:10 departments 17:22 18:13 19:9 23:22 36:22 41:6 47:22 48:1,15 61:18 84:14 85:21 86:2,6 86:17,17 87:12 88:5,7,17 96:3,19 99:21 107:5 108:2 130:13 131:3,4,9,18,22 132:9,11,12 141:20 142:3,4 145:19 148:11 153:6 177:19 depending 27:18 59:21 65:20 deposed 7:5,19 10:1 deposit 94:11 deposition 1:13,16,173:7 4:13,17 5:1 6:12 83:21 88:1 150:9,12 202:14 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010129 [describe - duration] describe difficult (cont.) discussions document (cont.) 19:1931:1544:1264:11 104:4 162:2 191:18 72:13 93:18 97:15 99:8 digester disk documents 171:2 39:6,15 140:1,5 3:11 51:20 64:9 117:15,17 described diluted dispatch 117:17 180:3 86:16 99:7 115:6 121:17 91:7 180:22 dodecylbenzene design dinitrochlorobenzene disperses 96:8 31:6 34:8 35:2 39:9 40:13 112:3 66:12 doing 40:16 93:22 dioxide disposal 24:4 49:22 54:4 79:12 designed 27:10 53:4,6 58:11 91:19 97:2 84:13 119:7 127:1 135:18 25:2 31:4 35:2 97:20 dip 101:21 104:19 105:1 144:13 166:5 175:21 176:6 156:11 123:4 114:18 141:21 142:2,8 189:20 191:5 designers direct dispose domestic 31:1,2,3 28:8 80:10 131:18 157:12 22:5 25:1 156:4,21 34:18 desirable direction disposed dotted 44:16 200:5 26:20 27:22 61:5 63:3 99:4 33:11 112:20 114:4,9 desired directive 143:9 127:11 54:10 103:17 110:8 175:10 dissatisfied doubt destroy directly 97:17 192:3 201:21 26:22 158:20 21:13 34:13 37:19 97:19 dissolve downstream detail 112:19 114:4 121:22 73:2 31:20 110:9 13:18 94:7 99:10,12 176:1 150:18 155:16 157:5 174:7 dissolved dozen details 181:15,20 60:9 63:14 64:22 65:1,10 137:21 183:7 director 72:3,6 91:22 92:5 dr determine 16:5,9,11 18:6,7 112:10,17 dissolving 116:20 117:6 119:11,18 73:11 156:9 177:20 178:3 124:15 129:5 71:13 drainage develop directors distill 140:12 101:18 18:19 45:5,9 54:3 56:21 draw developed dirt distillation 134:22 30:3 91:1 118:20 121:7,8 70:7 25:2,12 45:4 58:6 106:3 drawn developing disbursed 109:5,9 141:8 31:20 54:15 57:6,7,10 16:21 123:20,21 73:1 distillations 73:17 95:20 device discarded 110:14 111:18 drive 29:3,14 30:1 33:15 141:15 68:2,5,7 104:9,12 distilled 104:5 189:7 discharge 26:9 45:8 54:5 60:11,11 dropped devise 59:11 64:8 110:22 58:22 138:18 89:22 discharges distinction drummed devote 53:4 121:1 123:21 132:5 22:11 149:3 43:13 137:4 144:16 149:4 173:17 distribution drumming dez discolored 41:3 97:14 28:14 82:16,21 172:2,7 district drums diaphragm discontinued 1:20 54:16 58:22 97:20 88:21 89:19 91:17 94:6,11 138:14 divided dry 94:13 discover 87:9 122:6 189:5 dichlorobenzene 187:5 division due 106:3 discovered 103:15 108:11 69:18 102:14 172:2 186:5 difference 8:8 121:13 124:7 141:10 divisions duly 143:6 146:7 189:1 144:5,7 186:16 193:16 108:10 4:4 84:4 different discovery dock dumpster 15:21 23:3 56:3 71:3 84:14 115:7 152:7,8,12 63:4 86:21 94:8 95:12,15 103:11 discussed docks dumpsters 109:5 110:6 113:4 131:14 127:7 152:11 61:5 132:10 151:6 157:6 191:11 discussing document duplicating 195:5 82:22 202:8 3:8 49:16,18,19,21 50:9 148:22 difficult discussion 51:2 117:22 151:2 159:4 duration 61:5 76:16,18 90:1 97:11 13:16 176:20 187:11 160:19 161:6 166:12 13:3 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010130 [duties - examined] duties either (cont.) engineer epa 19:6 22:18,21 23:1,12,21 65:14,20 77:20 89:2 152:13 13:1,12 14:2 17:11 19:7 201:6,10,15 202:3 45:12 84:10 85:22 96:15 178:21 184:6 21:21 22:3,10,12,12,16,16 episodes 107:8,13 112:7 118:12 electric 23:2 30:7 42:1,22 79:14 81:13 e 65:7 84:9 85:1 86:1 87:7 88:8,18 equally earlier 97:3 99:3 120:21 122:12 124:19 151:19 154:18 183:6 195:9 early electrical 89:7,16 91:18 92:20 93:15 138:22 139:2 142:14,17,22 96:16 97:1 99:14,15 101:7 143:3 105:8 154:9 188:22 electrolytic engineered 65:3 69:22 29:3 33:16 38:6 equipment 24:19 44:15,17,20 54:3 75:12 90:2,16,17,18 167:6 167:9 34:1671:791:14 138:19 electrolyzed engineering equivalent 193:11 easier 74:6 100:18 east 152:17,18 65:8 10:13,21,22 25:5,7 30:9,16 16:19 134:17 165:5 electronic 35:3 77:20 103:15,15 erratic 94:14 107:17 136:7 155:13,16 123:6 eliminate engineers especially 121:8 123:22 131:22 132:4 23:22 84:12 85:11 87:4,6 147:10 easy 132:14 136:11 137:17 96:18 97:10 98:21 99:16,21 esq 69:22 economic 141:20 148:10 192:16 eliminated 107:18 108:1 engman 2:1,7 essentially 70:11 90:12 146:3 economical 111:6 29:16 90:1 92:2 eliminating 131:22 132:9 130:6 134:19 153:4 168:12 183:10 184:19 185:9 191:7 191:7 194:13,19 16:4 22:19 29:16 31:21 39:16 92:2 103:7 144:11 156:3 economics 90:14 elwood 98:3 engman's 130:9,20 139:5 190:21 esters 113:8 ed 105:7,7,10 194:15 edc emergency 69:20 emission entail 62:2 entailed estimated 199:18 et 199:6,17 edelblut 74:16 emissions 195:17 entered 1:10 164:11 ethyl 46:6 64:6 69:4 74:13 80:5 83:7 8:7 9:5,6 23:8 26:6,7 31:14,16 educational 10:9 edwin 200:3 effect 162:20 163:10 183:20 184:3 emphasized 164:14,15,16 employed entering 67:2 enthusiastic 61:6 entire eugene 78:3 eutectic 110:16,18 evaluations 50:12,13 90:3 119:16 143:1 12:17 16:20,21 13:20 42:5 47:10 58:4 196:10 197:20 160:21 effective 24:9 effectively 45:5 employee 23:9 employees 19:4 33:19 48:10 80:1 82:12 145:8 59:13 91:2 93:7 137:20 144:3 entirely 23:12 entitled evening's 49:11 eventually 42:17 92:17 104:9 123:9 138:3 154:11 177:13 effluent 42:5 179:15 effluents 202:5 effort employment 120:17 7:8 166:15 169:4 174:10,13 entity 179:3 183:11 184:9 187:17 14:20 194:10 198:14,17 entrained enclosed 67:12 188:12 everybody 61:6 185:14 evident 61:12 61:4,21 136:13 72:3 entrance evolved efforts 61:13,15 177:10 181:13 encourage 128:4 66:21 entry 53:9 exactly 189:17 eggs 81:14 ends 50:5 52:20 53:17 56:2 57:14 170:19 191:20 197:20 environment 119:13 173:17 190:19 20:21 29:21 111:17 115:16 128:9 158:5 171:19 173:9 177:6 183:22 eight 82:10 energy 94:21 environmental 9:13 53:3,6 83:7 examination 1:16 3:2 4:6 84:6 either engage environments examined 5:17 59:21 61:2 64:19 149:10 150:6,21 71:4,7,10 4:5 84:5 127:18 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010131 [example - five] example explained familiarize filling 11:9,14 56:1 61:16 76:3 146:8 128:1 142:16 78:2 83:14 120:2 130:18 explanation family filter 145:13 149:4 173:19 183:3 166:7 180:7 8:199:1,2 43:12,14,15,16 58:16,17,18 184:12,18 187:7 expressed famous 58:19,20,21 59:1 73:14 excuse 67:16 177:2 115:13 filtered 72:6 expressing far 43:13 58:19 75:20 exhausts 58:10 63:15 64:8 77:15,17 101:20 filtration 164:11 extended 102:15 104:17 116:4 58:20 60:13,13 exhibit 199:6 131:18 153:11 179:11 final 3:8,9,10,13,14,1549:14,15 extent fate 26:11 43:13 58:16 106:2 50:1,1,5,18,20 51:13 52:4 49:19 117:15 126:22 12:6,14 122:5 52:20 87:19,21 95:7 117:20 142:16 fault financial 120:2,2 129:7,14 130:2,14 extremely 9:4 182:10 130:15,15,18,20,21,22 90:7 142:18 faulty find 131:6,20 134:18 143:14 eye 38:13 71:8 118:22 119:2 144:14 144:19 146:12 147:3 151:1 29:2 32:1 february 158:17 153:2 154:13 161:19 eyes 184:18,18 findett 162:11,12 163:17,19,20 32:9 fed 149:15,18,21,22 150:2,5,6 164:4 166:9 167:20 169:2 173:19 174:18 175:11 179:1,5,8,17 182:7 183:8 184:7,18 185:18,19,20,21 fabian 133:16 f 57:3 94:9 federal 133:5 201:21 202:10 feds 150:14,20 findett's 150:16 finding 185:22 186:1 187:12,15 151:4 154:16 167:15 188:2 132:19 133:1 188:18 191:6 193:2 194:5,7 195:5 196:1,3 197:12,15 198:10,12,16,20,21 199:4,9 191:1 facilities 87:13 141:21 177:18 feed 60:1 72:17 73:6 160:4 feel 199:11 200:13,14 201:5 exhibits fact 9:4,6 64:15,17 67:16 76:19 49:20 feeling 3:11,12,16 117:11,14 120:1 88:9 94:5 118:13 119:10 181:4 130:14 131:13 163:18 184:11 198:6,8 exist 18:12 exists 151:17 152:9 168:22 185:14 factor 177:22 failed feet 40:20,22,22 66:19,20,20 fell 71:16 felt 189:8 25:22 69:18 125:9 162:5 201:22 exit 66:21 expand failure 97 69 6 9 failnrpc ferric 60:2 fiber 42:18 expanded 60:17 74:22 75:3,6 76:12 30:4 fields 132:14 fine 30:4 finish 74:4 finished 32:6 54:3,5 60:14 75:21 fire 137:13 first 4:4,21 5:5,6,13 13:7 17:14 33:2 36:11 45:13,18 48:17 51:12,1559:22 66:1084:17 87:5 113:1 114:15 115:1 117:19 118:7,8 123:3,3 125:22 129:6,14 131:21 144:20 146:9 147:5 155:19 163:19 165:10 166:14 42:17 expected 186:4 expenditures 182:13 183:3,3 expense 91:8 193:15 expensive 8:8 67:19 experience 115:10 expert 79:14 explain 179:22 180:6 78:11 fairly 26:2 35:11 59:20 103:3 1103 11821 12210 falcon 99:18 100:5 101:16 fifth 1:18 figure 119:3 162:3 177:12,14 1159 11919 figures familiar 10:2 11:19 80:21 83:6 163:5 figuring 93:15 105:13 108:18 116:4 147:13 150:16 151:15 152:5 159:9,18 175:22 124:20 file 174:17 175:4 191:16 185:5 189:17 196:18 familiarity files 175:8 109:14 filled 31:22 32:5 167:21 169:2,8 170:2 175:12 179:13 183:9,13 189:11 193:16 196:5 197:15 firsthand 160:1 fish 151:8 fits 191:4 five 4:22 13:9 15:10 22:14 32:7 55:18 84:12 85:11 94:2 148:4 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010132 [flat - graduated] flat 66:20 floor 1:192:1061:3,8,10 flow 42:20 65:11 189:9 flowed 37:21 flowing 65:5 flows 177:12,15 178:1 189:2 fluid 7:21 8:7,19 9:2,5,8,10,12 132:13,16 137:14 138:21 142:19 150:17 192:14,17 192:19,21,21 fluids 6:3,6 8:17 113:9,9 137:18 137:19 138:22 193:1 focal 125:21 focus 20:14 following 81:15 follows 4:5 84:5 food 119:15,17 force 46:17,1847:16,18,19 114:21 foreman 45:16 47:7,13,16 48:6 foremen 46:21 47:19 48:22 form 65:14 72:19 94:18 132:6 180:2 formal 126:1,10 168:15,16 169:1 185:13,15 formalized 18:20 formally 18:3 114:6 format 53:8 169:13 formation 18:14 formed 18:18 44:3 forth 15:15 58:5 87:14 94:1 112:3 129:19 136:19 forth (cont.) further glass 140:13 179:13 192:16 10:15 26:13 31:20 84:5 30:4 fouled 110:21 111:5 113:11 glosecki 120:15 futile 153:22 found 197:14 go 118:20 119:13 123:5 fuzzy 20:13 21:19 24:4 29:5 135:20 162:7 82:10 127:16 193:10 34:13 36:14 37:5,6,19 four g 40:17 49:6 55:6 62:7,13 4:22 23:17 94:2 fourth gallons 32:3 70:3 76:12 84:8 92:6 96:2 96:22 102:9 125:3 128:13 103:8,9 game 128:21 130:2 131:20 fraction 104:9 111:6 fractions 110:22 frame 138:19 garlette 30:8,19 gas 8:12 65:9 69:2,5 75:14,20 133:13 135:14 139:22 142:13 143:14 147:3 148:3 151:1,21 153:2 154:13 157:16 166:8,9 169:2 170:19 173:6,19 175:11 17:13 22:7 55:17 58:19 87:16 89:18 90:3,7,9,22 176:14 179:17 182:7,18 106:12 108:14 112:8 114:19 157:10,14 160:8 91:3,7 92:3 95:1 gathered 183:8 184:2 187:15 191:6 193:2 196:19 frames 187:8 139:8 gene 78:5 goal 162:11,16,20 179:13,19 180:11,12 197:21 fred 112:11,20 124:15,17 125:6 general 6:16 10:2 14:15,18 15:4 goals 139:7 179:11 180:14,14 125:10 126:1 146:22 174:7 free 75:2 16:2 18:10 19:20 21:18 44:13 57:10 85:6 88:1,21 90:15 92:7 102:10 106:8,18 goes 47:3 going 165:12 frequency 63:21 70:16 108:18 112:1 124:12 125:4 125:7,8 134:15 144:4 4:13 10:4 13:18,19 31:13 34:17 38:15,20 41:17 54:21 frequent 147:15 151:22 157:3 158:1 62:5 79:19 90:15 102:12 70:8 172:8 frequently 57:768:769:11 fresh 72:7 160:8 190:9,16 generally 5:1421:1730:20 69:17 110:8 129:18 146:18 176:4 190:4 105:12 117:16,18 119:3 125:12 126:4,9 127:4 128:4 132:4 133:1 136:20 141:18 146:4 147:17 155:13 157:4 161:14 164:19 192:11,18 friend george 200:6 125:8,16 127:6 friends 78:10 116:1 fritz 30:7 133:22 getting 70:13 91:6 103:17 124:6 141:14 145:21 157:6 190:19 good 4:8 62:19 70:13 73:4 101:7 124:8 139:4 145:21 181:9 gotten 77:14 186:9 front 37:20 63:19 full 25:8 31:7 114:21 165:5 fumes give 10:3,9 74:4 81:18 111:11 165:6 169:16 given 19:8 103:8 119:8 158:13 government 78:1 133:6 149:12 181:4 201:21 202:10 governmental 83:11 181:12,21 29:2 159:7,14 192:13 193:15 grabbing function 105:17 199:4 202:2 gives 123:19 grade functional 18:5 furlow 176:17 giving 193:5 55:22 grades 55:20 56:3,8 1:18 furnace glance 49:19 117:21 graduate 10:15,16 58:4 170:21 glancing graduated 173:21 10:11,14 12:16 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010133 [granules - impetus] granules handling heater houses 73:2 34:9 65:15 89:18 90:4,15 160:4 195:21 80:15 81:1,5,21 82:2,8 graphite 91:3 97:18 126:20 heavier 87:13 88:16 93:21 95:11 67:22 68:3,4 handwriting 140:16 howard gray 167:21 174:22 175:2 heavy 112:17,20 126:2,8,10 55:11,11 191:15,16 43:11 128:13 182:18 great handwritten hedworth hubbard 155:14 172:10 179:18 33:6 52:13,14 greenman hang held huh 133:18,19 180:4 22:15 170:1 ground happen herb human 70:4,5 147:19 170:12 171:3 63:22,22 69:8,10 70:10 85:13 92:13 172:2 173:2 190:7,10 77:11 hide hume group happened 202:1 134:9,10 3:11 6:17,18,20,21 18:15 45:7 60:21 69:17 76:5 high hunk 18:16,1723:17,1924:8 78:16 126:13 158:6 168:13 10:10,11 34:19 54:12 146:2 200:1 48:13 84:12 93:5,9 96:2,16 168:19 158:18 162:3,6 163:11 hydraulic 99:17 103:15 106:11 hard 165:7 173:12 6:3,6 7:21 8:17,18 9:2 107:16,18,19,20 112:13,14 71:15 139:1 higher 113:8 137:18,19 138:22 112:15,16,17,22 113:3 harmful 10:18 52:17 106:8 112:2 150:17 117:19 118:20 121:6 124:3 11:6 128:12 162:7 180:12 hydrogen 129:2 130:12 133:15 harold highly 66:9,10,13 73:6 74:17,18 145:15 146:11 194:3 52:14 54:9 122:3 hydrogenation groups harry highway 73:9 18:18 107:14,22 135:1,5,6 85:16 200:2 hydroxide 148:4 hauled hill 64:17,20 65:14,15,16 guess 14:4 64:11 153:9 165:13 186:20 guest 108:9 134:8 guide 64:10 guidelines 10:2 guy 55:10 guys 166:6 gyp 95:16 gypsum 95:18 h half 14:4 137:6 hand 50:21 153:9 169:7 194:19 handbook 11:16 handle 34:1771:15 handled 43:10 55:9 59:5,10 63:12 101:17 104:13 109:16,18 168:21 43:18,20 58:22 114:16 147:1 176:4 hazardous hired 97:19 98:12 125:16 hb historical 48:2,8 66:14 72:12,14 193:14 73:10 74:20 history hcl 177:5 60:8 63:14 75:14,20,22 hodges 77:4 105:22 106:1 141:10 106:13,17 head hold 14:15 107:8,11 109:1 13:2 14:3,10 15:1,9 16:3 124:11 133:15 137:1 holzapfel headed 112:11,21 124:15 126:2 107:14 hoods heading 99:11 120:2,14 139:7 148:10 hooker 160:17 161:7,20 188:18 88:20 91:17 94:6 95:15 hear hope 38:1 40:4 41:9 160:2 161:3 16:16 181:16 hosmer heard 28:14 82:16 83:1 134:6 149:15 159:10,22 hot 160:9,21 161:5 181:14 94:22 97:20 hearing hour 36:17,21 181:19 197:4 41:18 heat house 113:9 132:12,15 138:21 88:20 89:1,4 91:13 94:6 142:6,7 143:4 160:5 192:13 housekeeping 192:17,19 61:1962:1,6,9,14,17,21 63:6 173:6,10 i idea 82:13 92:11 98:14 116:8 125:15 187:9 201:3 202:6 identical 136:10 146:20 186:2 identified 3:7 49:14 50:18 87:19 117:12 187:13 194:5 196:1 197:12 198:6 identify 49:20 51:1 130:5 136:12 151:2 153:3 154:15 163:7 179:9 182:7 193:2 ii 140:1 147:4 189:10 192:10 iii 141:19 190:12 ilk 149:6 illinois 4:155:18 immediate 129:22 immediately 69:7 192:10 impact 131:12 impetus 28:15 51:22 118:17 197:9 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010134 [implement - issue] implement included 21:22 49:4 11:11 45:15 190:17 implies includes 48:17 92:13 189:2,6 50:16 important including 68:8,10,13 71:8 119:7 94:4 111:9 184:22 190:13 124:4 incorrect imported 121:12 94:1 increase impossible 42:20 103:10 24:8 110:20 increased imprecise 133:7 90:21 increasing impregnator 133:3 142:15 indicated improve 49:13 19:10 20:15 24:18 43:3 indicates 89:18 102:5 191:18 improved individual 20:20 44:9 45:3 90:1 61:1482:11 97:11 117:17 improvement indoctrination 20:12 24:16,17 43:2 49:3 127:8 84:13 89:14,22 96:20 97:6 industrial 101:8,14 102:22 175:16 137:18 176:9 201:8 industry improvements 139:2 44:15 90:13 108:3 141:21 inert 142:2,9 91:10 improving infiltration 19:21 20:9 23:4 42:4,14 196:12 197:22 43:3 45:4 62:6 90:3,5 97:14 influence 103:17 94:14 impurities influent 95:19 142:19 152:1 inactive informally 73:17 93:5 inch information 197:20 11:13 17:5 81:1882:17 incident 115:22 121:7 123:21 69:12,16 77:13 186:15 131:17 146:16,18 150:13 incidental 150:15 154:18 155:6,9,11 44:21 182:20 184:13,14 198:21 incinerate 198:22 199:9,10 201:22 156:7 informed incinerated 28:9,11,15 28:3,4 43:11 45:10 initial incineration 124:2 27:1 28:1 155:18,21 158:4 initials 168:9 21:4 incinerator initiated 24:22 156:8,11,13,16 157:6 51:18 157:19 158:2,5,10,16,17 initiation 168:14,22 118:17 include initiator 146:1 51:16 input intermittent 138:8 37:8 inside interpret 31:22 189:4,8 200:19 insoluble interpretations 122:2,6 171:14 inspection interrupting 61:19 63:6 173:5,7 70:1 inspections interview 62:1,11,14,17,21 125:3 inspectors interviewed 83:14,17 125:9 installation introduced 25:7 35:3 141:1 199:20 73:6 75:15 installed invented 29:14 42:19 103:14 147:22 30:1 156:11 157:7 199:6,14 investigation 200:6,10 145:22 178:2 201:1 instance invited 20:18 56:10 124:22 instances involve 60:22 155:16 instituted involved 29:11 44:18 45:1 6:11,138:11 20:1 22:2 instituting 31:1559:1887:11 93:1,10 188:5 99:10 101:15 104:22 105:3 instruction 105:11 107:22 113:14 12:9 114:18 119:5 121:22 instructions 136:21 137:1 150:18 193:6 155:21 157:5 159:17 173:5 instrument 178:7,14 180:13 181:15,20 134:1 184:1 188:14 192:6 197:10 insurance involvement 2:144:9,10 11:3 6:9 8:13 30:21 79:11 121:4 intended 157:13 155:8 involves intense 87:18 131:3 35:11 involving intention 97:3 199:13,19 34:12 irritant interconnected 32:1 177:22 irritants interest 29:2 155:14 168:20 irritating interested 32:9 126:9 155:13 202:10 isolated interesting 97:21 110:13 131:15 isolating interface 99:8 80:9 149:22 isomers interim 110:5,13 137:17 180:12,13 issue intermediate 9:1327:17 114:20 115:1 25:22 26:1,8,13,15 29:1 123:3 126:20 173:10 178:9 31:11 45:6,7 202:10 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010135 [issued - leader] issued july know (cont.) I 33:20 120:17 130:15 132:19 138:10 139:11,13 140:4,5,5 lab issues june 140:10 142:2,12 145:12 134:16 170:15 185:2 3:15 120:9,10,16,16,17 147:18 148:1,19 149:14 laboratory italy 130:3 134:19 143:15 144:2 151:11,17 152:19 153:20 14:16,19 78:15 107:19,21 65:4 94:1,1 197:17 154:1,5 155:4 157:19 158:5 123:5 133:14 166:17 item junk 159:2,11,13 160:5,14,17 lackey 131:21 132:8 163:4 63:6 161:15 165:20 166:10 47:1 iv k 167:8,11,18 168:7 172:13 lakes 148:15 183:14 karbate 173:3 175:2,3 176:7 178:18 129:19 j 75:11 181:11 183:2 184:6 185:16 landfill ja 1:8 jack 134:10 jackson karl 45:18 katzenstein 1:18 kcl 190:7,21 191:13,16 192:2 194:16,22 195:13,17 199:16 knowledge 6:22 21:1,8 80:1081:16 55:1 108:20 156:5,22 157:2 157:4,11,15 166:19 167:1 167:13,17 landfills 157:20 134:14,15 72:6 104:16 118:9 135:15 157:3 large james 1:13,16 2:1 3:3 4:3 84:3 keep 91:8 120:22 128:5 174:12 160:1 165:18,19 176:12 186:19 40:2041:1 47:15,15,18 56:9,12 65:7 87:17 94:3,9 202:18 january 10:14 12:16 183:9 174:14,15 189:5 kept 46:4 86:4 174:9,16 175:4 known 5:14 9:9 21:4 38:14 63:14 83:5 126:16 129:7,16,17 94:17,21 168:16 largely 90:5 japan 113:15 175:10 key 131:8 144:13 145:10 156:19 201:20 larger 61:14 103:16 153:11 jefferson 152:22 jesse 132:1 kimball 134:5,7 knox 17:14 19:1,3 koenig 177:16 182:16 largest 72:1 114:15 176:5 jet kind 7:15 18:727:1933:11 194:2,3 kristine lasalle 113:13 164:10 35:11 43:14,17 44:3,20 1:19 late jets 64:7 jim 17:14 19:1,3 job 59:22 70:21 76:7 90:21 92:18 95:3 102:4 127:11 144:13 160:4 177:11 185:13,15 189:6,20 193:16 194:18 195:18 krull 154:6,7,12 krummrich 4:14 6:7 14:1,7 20:22 21:2 21:3 84:9,15,20 85:9 86:3 18:19 115:4 latest 132:18 163:5 latex 113:10 16:6,10 18:9 19:6 21:19 kinds 86:15,17 87:1,22 88:2 launched 22:18,21 23:1 24:9 45:12 24:16 171:13 84:10 85:22 96:15 107:8,13 knew 107:15 112:7 121:6 125:10 63:15 64:8 86:7 106:13 126:15,18 127:8 134:4,17 107:2 116:2 145:9 150:17 139:18,19,20 178:12 90:20 91:15,20 92:15 93:10 168:16 96:3,17 99:5 106:11,22 law 107:16 108:15,20 109:3,12 1:17 10:18 109:17,19 110:2,14 111:8 lawsuit 111:13,21 113:7,16,19,20 4:10 5:4,6 6:10,22 8:13 joe 30:1 john 13:1 32:20 33:4 85:7,15 93:4,6 know 6:2,4 7:1,17,22 8:3,5,21 9:14 10:7 11:20 21:5 28:8 34:20 35:18,20,22 36:4 43:18,20 44:1,2,4 52:18 114:1,10,17 127:13,21 9:21 80:18,21 81:2,16,19 128:15 129:11 130:6 82:12,18,20,22 159:6,9,11 134:11,16 135:11,13,15 160:3,9 143:21 145:6,14 146:10,19 lawsuits 149:3 151:4 154:4 156:12 5:2,4 80:11 83:6 159:19 johnson 53:5,10,11 54:18,20 55:1,2 157:7,9,21 158:10,15 layer 5:14,167:15 joined 55:7,11,13,16 59:1 63:1 64:3 68:6,7 69:12,15 70:6 159:20 163:2 167:1 169:9 27:19 61:9 172:2 171:9,21 172:1,6,9,22 layout 118:19 124:3 146:11 joint 113:15 191:7 76:6 78:15,20 80:16 81:1,3 92:13,14,16,19 95:8 98:8 99:4 102:15 104:13,14,17 173:16,22 176:16,22 177:1 88:1 177:3 178:4 183:3 184:14 leaching 192:5 194:14 199:14,21 40:4 jointly 191:7,11 106:4,5,7,18 115:13 116:11 116:17 119:6 122:12,16 kuhn 19:2 126:21 lead 60:18 90:19 165:2 juicy 125:5 126:13,17 130:1 leader 171:14 131:18 133:2,9,17 134:5 93:5,9 96:2,16 99:17 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010136 [leader - manifested] leader (cont.) levels little (cont.) losses (cont.) 145:15 139:7 144:21 161:20 171:12 174:1 185:6 193:10 181:5 186:4 leading 162:19 176:15 188:18 199:22 lost 36:18,22 38:2 121:20 191:20 lived 119:1 176:21 leverage 80:17 lot leads 103:6 loading 79:7 88:11,21 91:9 104:10 186:21 liaison 147:10 189:12,21 190:1,4 109:5 123:17 136:21,22 leak 168:9 local 137:8 155:3 69:2 91:1 liberty 102:13 louis leakage 2:134:9 located 6:8 13:1 25:5 30:9,12,19 36:18,21 38:1 176:21 177:2 licensed 5:16 8:3 82:2 84:19 33:10,12,13 35:2 48:20 leaked 65:4 location 52:7 79:3 116:13 150:4 41:10,1461:3 63:9 licensing 173:16 188:7 190:19,21 161:7 leaking 15:21 16:5,10,11,12 17:3 locations low 197:6 life 128:2 152:15 35:11 164:19 165:1,4 leaks 136:17 log lubricant 36:1860:15,1861:7 68:18 limestone 49:10 8:19 68:20,22 70:3,9,17 74:19 37:20 38:3,10,10 39:17,22 long lump 76:8 90:19 91:5 40:1,1,2,6,8,11,15,1741:5 4:21 13:2,8 14:3,10 15:1,8 16:18 learn 63:19 67:4 77:1 16:3 18:12 22:10,14 40:22 luxury 24:1 38:1 40:4 41:9 82:20 line 42:16 45:20 49:18 50:16 180:17 115:1 161:4 185:6 15:21 33:11 51:12 112:20 66:19,20,20 71:1 81:17 m learned 122:21 146:22 114:4,9 119:20 127:11 128:21 137:20 185:16 87:3 95:9 125:11 130:7 158:19 162:8 175:10 177:5 macdonald 174:7 learning 24:9 36:17,21 197:4 leased lined 40:8,10 lines 180:14 200:8 longer 4:22 112:19 168:20 180:10 main 43:9 58:5 65:1 70:18 79:2 92:4 136:6 188:11 152:12 leave 51:11 137:10 139:11 162:2 174:18 look 11:21 49:10 50:20,22 52:21 maintaining 52:11 102:15 lineup 56:1 62:19 88:4 119:20 maintenance leaving 124:2 65:1671:18 141:12 liquid led 34:9 35:5 36:5 39:2 41:6 31:1663:18 112:16 122:13 42:5 43:11 74:1,13,13 129:6 134:18 163:13 166:8 173:6 188:10 looked 117:8 119:11 183:6 38:18 49:1 70:19,20 91:8 93:14 125:8 154:4 178:17 178:21 122:13 123:1 171:15 looking 27:1,10 70:21 101:16 163:4 left liquids 56:2 150:13 191:1 199:5,13 200:9 25:13 26:9 28:4 68:1 104:6 61:2 105:6 107:15 109:8 110:15 liquification 124:16,17 134:17 138:12 87:14,15 138:22 142:17,20 169:7 liquifying legal 87:18 looks 191:17 loop 72:3 loops making 26:6,7 62:5 64:15 80:11 110:5 149:3 190:17 manage 68:10 158:22 legislators 165:11 legislatures 165:14,22 166:3 liquor 94:15,17 95:4 list 130:7 listed 72:8 94:6 lose 102:7 losing 144:10 managed 93:13 management 47:17 68:9 manager leisy 164:1 194:19 loss 6:16 8:15 15:5,22 16:11 127:16 letter lists 139:5 136:11 144:6 147:17 153:10 187:4 28:12 33:8 81:22 82:14 112:8 114:7 118:10 124:12 86:10,13 193:4 literally level 31:4 17:22 18:11 30:15,16 34:20 little losses 121:8 136:7 129:7,16,21 131:8,17 137:7 143:15,18,20 125:17 126:1,7,16,17,19 149:9 160:12 194:4 managers 52:17 73:9 112:2 114:2 128:11,13 138:15 155:9 39:14 43:9 59:4 65:12 68:1573:11 109:14 118:12 144:2 145:1,4,9 146:3,3,10 147:9 151:5 153:5,14,17 18:4,5,8 112:12 125:1 manifested 180:7,8 182:13,14,17 118:14 120:15 127:16 161:21 162:6,11 163:3,6 91:6 130:20 163:12 165:13 164:10,13 177:16 179:19 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010137 [manned - monsanto] manned materials (cont.) memo middle 48:10 172:7 120:6,16,17 130:6,20 132:8 144:9 162:5 manta math 133:9 139:5 153:4,13 middleton 2:8 10:18 154:10 163:22 164:9,20 85:15 97:12 99:7 manufacture matrix 165:9 167:3 176:14 179:2 middleton's 110:4 112:9,19 179:10,18 180:16 182:9 99:13 manufactured matter memoranda migrated 20:22 127:20 131:5 7:14 22:13 70:1 90:5,22 3:16 196:6 41:10 manufacturer 108:18 117:18 118:13 memorandum migration 150:1 156:9,16 131:16 138:13,16 155:5 3:13,14,15 134:19 164:5 12:6,12 40:5 manufacturing 162:21 195:8 166:14 168:1 169:3 179:5 mike 3:9 6:11,13,15,168:15 15:5 matters 180:8,9 183:10 184:8 151:3 153:9 15:20 18:5,6,7 44:4 50:3,8 11:3 114:18 126:2,14 175:5 187:16 191:6 194:9 197:16 miles 51:8 53:7,9,13 112:7,10,12 maximum 198:13,16 153:1 112:13 118:10 121:5 124:2 179:14 memos milk 124:12,16,18 125:1,17,22 mccown 183:6 159:7,14 126:7,16,19 148:14 149:9 85:13 mention milwaukee 150:3 155:11 160:12 mccutchan 121:9 153:6 5:18 168:18 118:1 120:11,15 127:17 mentioned mind map 130:22 131:7,15 154:10 28:19 31:9 34:4 42:12 42:17 45:2 55:9 131:12 3:10 87:21 88:9 123:8 mccutchan's 63:11 78:2 88:11 89:11 mine march 130:21 91:21 93:21 103:19 139:14 108:8 175:3 191:17 16:15 187:16 mcdonald 151:19 156:21 183:5 minimize mark 146:14,22 mentions 67:19 47:9 48:8 49:22 95:6,7 mco 166:17 201:5 minimizing marked 49:16 50:4 154:14 mercury 197:21 49:15 87:21,22 88:15 mean 65:4,5,6,10,11,13,16 66:22 minimum 117:14,20 194:7 196:3 17:2 42:1 56:16,19 71:11 67:1,1,7,17,18 89:2 94:3 181:6 198:8 76:18 78:1 86:20 108:22 mersize minor marker 139:12 142:12 144:8,9 113:13 143:5 190:17 35:12,15 168:4,5 177:15 message minute market meaning 164:22 142:18 1:18 2:4,11 65:21 57:3 61:16 157:21 meta mischaracterizes marketing meaningless 110:7 180:3 77:8 122:10 metafraction mississippi marking means 111:4,9,14,16 92:17 152:8 153:1 128:19 20:1572:15 171:14,16 metal mitsubishi markup 192:18 199:16 73:18 90:11 113:15 169:15 meant metallic mixed martin 137:20 65:9 73:2 60:1 73:2 94:16 155:12 98:3,3 measure metanitrochlorobenzene mixture material 91:4 144:16 104:10 110:11 110:5 177:4 20:20 21:2 25:12 26:21 measurement method modest 39:18 44:1,1 48:5 54:15 73:11 97:2,17 111:6 97:21 59:4,21,22 60:3 61:2 70:22 measures methodology molecule 71:5,9 72:14 73:3 75:19,22 121:20 121:19 26:2 110:6 76:17 90:12 95:20,22 97:20 mechanical methods molecules 97:21 98:22 99:2 102:6 9:7 107:17 170:10 192:22 22:4 91:20 101:22 121:13 104:11 110:9,15,19 111:7 145:19 mechanisms 121:14 123:9,11 moment 145:20 157:18 166:22 173:12 methyl 131:20 146:12 167:1 173:2 medium 23:8 26:7,8 money materials 160:5 microfilm 34:15 182:19 12:1041:1443:444:10 meetings 52:22 monochlorobenzene 54:9,14 61:1 64:19 66:1 155:2,3 mid 103:13,20,21 104:4,6,7 70:13 102:4 103:14,21 member 167:6 monsanto 106:8 112:1 150:1 167:16 33:6 1:5 2:6 4:10 5:9,19 7:9 9:4 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010138 [monsanto - o'connor] monsanto (cont.) n new (cont.) north 12:3,20 14:20 16:17 17:9 name 89:21 101:18 112:9 124:22 82:4 199:6,20 200:1,1,4,8 19:15 22:4 30:2 32:8,11 4:8 8:2 18:16 26:2 29:22 124:22 127:8 137:21,22 northern 33:19 34:14 36:14,18 39:11 50:21 55:12 72:22 75:10 50:9 61:20 80:1 81:8,12,20 78:2,3,6 105:6 134:6 154:1 82:11 116:9,17 119:12 172:21 192:13 193:14 125:19 132:4,14 138:3 named newer 91:13 newport 113:6,16,20 114:1 127:21 5:17 199:14 notary 1:19 note 143:10 144:15 145:8 149:1 18:19 72:21 152:7,11,12 159:19 165:21 names 128:15 146:14,19 147:1 50:5,6 53:4 157:22 158:1,4,14 173:22 notes 166:3,15 168:2 169:5 174:10 179:3,6 180:21 6:20 25:15 47:5 52:4 55:9 83:3 99:20 174:3 nickel 125:7 notice 181:11 183:11,18 184:9 napnp 72:18,19 73:1,1 1:17 186:19 187:17 188:5 35:14 night nozzles 194:11 198:14,18 202:4 natural 81:14 41:3 monsanto's 8:12 39:19 niran number 4:12,1430:11 143:11 naturally 23:7,9,12 24:1,11 25:17,18 1:7 3:7 4:10 42:3,13 43:2 159:13 181:12 123:3 34:7,8,12 35:6 36:5,8,10,19 45:16 50:2,5 52:20,22 monstrous nature 39:2 41:7 42:6 43:1,8 44:7 53:17 56:2 57:13 65:2,19 96:12 month 5:11 6:9 8:5 10:16 11:6 19:6,1723:1 24:10,15 79:8,19 80:12 nitrated 71:3 72:22 84:14 94:9 97:10 101:11 103:2 113:4 111:19 118:3,12 120:20 163:2 29:10 30:21 33:15 39:1 42:1545:1251:1052:15 96:8 112:1 nitration 120:6,9,9,13,13,13 122:9 138:18 139:5 142:11 151:5 monthly 118:1,7,18 128:18 154:16 154:20 155:6 173:20 months 64:11 102:8 76:11 121:3 79:11 96:15 137:14 161:3,4 96:8,9 nitrator neb 100:20 102:22 104:1 103:8 nitrators 162:7 183:14 195:5 196:11 199:4 numbering 86:16 120:8 70:11 89:19 121:13 124:18 105:19 111:13,20 103:9 numbers 124:20 near nitric 49:16 50:4,6 53:18 86:5 moody 45:19 46:6 morning 80:17 152:3 158:3 174:21 175:12 187:19 197:20 nearly 104:3 nitro 4:1621:6 108:16 112:5 88:5 100:21 120:5 121:11 121:15,18 122:18 123:8,8 124:6,9 130:3 153:20 4:8 49:8 146:20 163:3 113:5,13 114:13,16 154:14 159:1 162:9 164:6,7 motors necessarily nitroaniline 194:7 196:4 198:9,11 5:14,167:15 38:14 85:19 121:18 175:22 101:13 numeral move necessary nitroanilines 139:22 141:19____________ 15:19 77:9 moved 21:20 163:8 need 96:6 100:7 102:4 nitrochlorobenzene object o 14:13 15:20 22:9 77:18 106:18 124:11 mullendore 32:20 33:4 85:8,9 93:4,6 multi page 49:16 multiple 135:14 municipal 10:8 56:22 128:6 136:15 182:19 needed 18:10 21:22 42:18 49:2 64:15 82:21 110:9 141:22 150:2 156:4,21 163:11 173:13 181:3 182:20 needs 10:5 105:16 112:14 103:22 104:3,7 109:15,16 110:2 112:2 nitrochlorobenzenes 96:7 100:17 106:16 110:4 nitrogen 188:19,20,21 189:2,4,6,7 nominated 168:17 non 132:6 180:2 obtained 195:10 obvious 26:15 28:18 obviously 76:21 118:11 185:1,11 186:11 194:17 occasion 34:11,17 36:7 39:9 muriatic neglect 164:10 1:9 137:22 noncorrosive 11:15 19:18 184:12 occasionally 46:14 47:13,18 63:15 75:7 neither 75:17 76:11,12 77:6,7,11 71:14 75:1 nonverbal 60:17 occasions 106:1 mutual neutral 71:14 105:15 normal 77:3 144:15 163:9 occurred 2:13 4:9 neutralization 39:17 49:8,9 91:2 103:16 175:8 normally 194:17 o'connor new 27:5 30:1851:1468:14 1:19 1:3 34:11 68:12 70:22 92:13 110:15 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010139 [October - particular] October operation (cont.) original papageorge (cont.) 50:15 175:11 75:2 76:10 89:3,21 91:2,12 34:8,12 40:13,16 71:6 169:14,18 173:20 174:2,8 odor 91:16 94:2,4 108:11 109:16 103:7 111:7 137:13 153:4 175:6 179:10 180:11 102:14 111:2 138:6 172:12 186:13 originally 181:17 182:9 184:8,15,22 offhand operations 25:2 71:12 86:15 185:8,19 191:8 196:7 86:6 100:8,10 5:8 37:4,15,17 38:2 46:2,7 ortho 197:17 198:17 199:10 office 46:11 47:14 48:15 49:7,11 110:7 111:3 papageorge's 6:16 16:1,2 18:10 106:18 50:10 51:20 52:8 56:21 orthonitroaniline 154:16 155:6 164:9,20 127:6 64:12 68:19 72:12,13 74:20 100:12 180:16 offices 75:8,8 76:3,9 78:12 79:5 orthonitrochlorobenzene paper 1:17 15:4 30:12 124:12 80:12 83:7,12 88:13 89:16 110:10 58:20,21 113:12 138:1 125:4 90:4 91:11 93:16,19 95:11 os ha papers oh 97:8 99:1 102:18 108:4,10 83:14,16 115:5,15,21 18:18 48:2 68:8 69:12 83:5 109:6,15 111:13,19,21 ought para 89:6 116:10,19 121:2 134:8 153:18,19 172:19 171:17 198:4 110:7 111:4 122:20 155:3 185:10 187:1 outlining paragraph oil operator 182:10 131:21 144:1 165:9 166:6 110:1,17,18 111:3 156:13,14 outside 166:17 167:5,14 168:19 okay operators 115:3 192:5 170:4 179:13 185:20 26:6 41:19 53:19 129:15 45:16 47:2 73:11 outstripped 186:10 130:4,17 150:10 159:5 opportunities 77:12 paragraphs 160:20 166:13 19:20 49:3 overlapped 169:8 old opposed 106:19 paranitroaniline 21:12 70:21 86:16,16 183:19,19 184:3 oversupply 100:12 101:19 125:15 127:6 197:1 optimize 77:8 paranitrochlorobenzene older 44:15 overtime 110:8 88:20 90:8,16 91:17 option 62:18 paranitrophenate ona 16:18 oxidation 35:10 100:13 102:17 order 39:19 paranitrophenetole oncb 103:1 once 50:22 56:10 61:16 68:16 86:7 95:3 136:20 137:2 163:2 168:19 ones 135:7 146:22 ongoing 80:18 183:19 184:3 open 165:6 opened 58:21 74:18 operate 158:18 operated 47:18 57:3 152:4 operating 19:9,11,17 35:1 44:14 84:14 114:5 134:7,10 156:10 186:15 193:4 operation 24:5 25:18 27:13 42:4 44:15,16 45:15 46:16,22 48:9 49:2,9 52:10 55:17 68:13 69:22 72:2 74:22 21:18 32:16 56:17 97:16 P 20:3,4,18 98:6,18,19 103:7 163:17 167:19 ordered 149:10 150:6 orders 32:19 49:1,4 77:16,17 p2o5 29:15,17 package 75:10,11 136:9 packed 304 paraphenitidine 21:3 parathion 23:8,8,21 26:6,7,14 34:19 35:19 37:3 42:18 pardon ordinarily 93:12 ordinary 76:20 166:15 168:2 169:4 174:9,12 179:2,6 183:11 packing 6018 page 52:3,21 53:16 56:1 57:15 129:6,14 134:18 148:3 100:9 174:11 part 8:189:1,2,4 11:723:11 24:8 25:13,22 27:11 30:2 33:3 40:12 44:3 45:9 59:16 184:9 186:13 187:16 194:10 198:13,17 organic 25:5,7 30:9 35:3 75:19 103:14 148:4 155:19 158:21 159:1 161:6 161:19 167:21 168:8 169:19 174:21 175:12 176:14 183:13 185:18,18 185:20,22 186:1 188:17,17 65:2 68:8 71:17 72:1 84:11 91:11 95:18 99:22 104:13 105:4,5,10 112:9 119:7 124:1,2,5 127:7 141:10 150:2 157:3 174:6 188:15 organisms 189:10 195:4 196:9 197:19 195:14 199:14200:22 129:20 organization 199 3 11 200 13 14 paint particle 27:6 18:5,15,20 124:20,22 organize 108:13 112:9,18 80:15 pap 5511 81:5,12,15 particles 29:15,17 39:8 122:7,9 particular 70:20 124:21 136:15 organized 158:2 173:10 papageorge 118:2 125:20 126:3,6 128:22 134:20 153:5 154:19,19 164:5 168:5 5:86:13 17:7 32:11 64:17 107:3 120:22 134:13 149:8 186:10,15 189:19 191:4 200:20 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010140 [particularly - plant] particularly pcbs (cont.) phases place (cont.) 62:19 71:15 114:21 122:4 150:13,16 154:17 155:3 122:12 142:13 188:2,3 191:3 194:1 137:16201:19 158:20 160:12,22 170:16 phenetole placed parties 174:22 176:21 177:2,11 20:5 43:17 65:20 73:5 1:21 197:5,6 201:21 phenol places partly pet 96:11 101:3 105:2,3,9,12 61:11,1271:4,5 113:18 27:17 91:3 26:7,8,10,11 31:14,16 105:14 132:13 151:6,7,7,11,12,15 parts pending Philadelphia 172:1 173:13 70:21 133:10 135:17,19 7:17 2:12 plaintiff 155:15 162:12 179:14 Pennsylvania phosphate 1:6 2:6 9:20 pass 2:12 113:8 plaintiff's 71:18 pension phosphoric 159:14 passed 16:17 29:15,19 plan 65:7 71:15 72:5 164:21 pentachlorophenate phosphorus 48:20 132:19 passing 113:17 25:3 26:17 27:3,4,5,9 29:12 plans 94:13 pentachlorophenol photographer 135:1,4,8,9 136:14 patches 113:16,21 81:22 plant 81:15 pentoxide phrase 4:14,15,15 5:9,15,20 6:4,8 patent 25:3 26:17 27:5 29:12 131:21 6:14 13:1,4,6,8,11,22 14:1 33:20 people picked 14:7,12,14,22 17:12,17,19 patents 24:6 26:1430:11,15,16 113:12 152:20 18:4,5 19:1,12 20:22 21:3,3 33:20 35:2 51:15 62:3,7 69:20 picking 22:5,9 23:2,16,16,20 25:6 path 80:2,14,16,17 81:3 87:5 175:21 26:14 27:18 28:12,21 29:7 129:19 95:17 105:8 106:13 107:21 pictures 29:10 30:15,18 31:4,6 33:2 paul 114:2 127:9 128:3 129:1 81:20 82:1,9,15,21 33:8 34:2,6,11,14,17,22 106:13,15,17 130:7,7,8 133:10 136:21 piece 35:1,4 36:2,6,7,11,15 37:1 pave 137:1 139:1 148:11 154:19 54:3 58:5 157:5 37:2,11,14,19 38:21 39:3,5 189:17,17 190:1 195:16 154:22 155:9 156:18 160:6 pieces 39:10,11 40:2,5,15 41:22 paving 163:10 165:21 181:11,12 90:2 175:7 42:4,14 43:10,22 45:11,13 147:8,21 189:11 190:11 181:17,21 185:16 188:15 pierle 45:15,21 46:10,22 47:22 pay perceived 139:12 151:3 153:9 180:10 50:3 53:14 55:17 58:8 34:14 129:18 pilot 59:14 62:5 64:17 65:2 71:6 pcb percent 25:6 29:9 31:4,6 35:1 72:12 77:20,22 78:10,13,20 5:2 114:20 118:20 119:1 71:16 73:10 146:6,7 101:20 156:9 79:5,6,8,13,18 80:2,6,13,17 121:1,7 122:3,6 123:21 peregrine pinpoint 80:19 81:22 82:4,14 83:8 125:2,14,22 126:3 127:19 115:8 119:18 82:4 83:10,12 84:9,15,21 85:9 128:2 129:17 132:5 135:2 period pipe 86:16,17,21 87:1,2,22 88:2 135:16 137:4,22 139:7 15:16 113:1 124:19 73:7 88:21,22 90:20 91:16,20 142:11 144:12,16,21 periodic pipeline 92:7 93:7,10,11 94:7 95:17 146:16,18 149:2,11 150:7 70:20 8:1,2,7,9 9:3,5,6 96:1,3,17 97:8 99:5 101:20 151:5 154:20 161:20 permitted pipes 102:10,12,14,15 103:16 162:20 163:3 166:4,18,22 90:13 38:2,16 41:1,2 71:2 75:4 104:15 106:11,17,22 167:1,16 170:15 173:20 person 76:15,15 107:11,16 108:5,6,7,8,19 175:4,19 176:9,14 178:9 52:6,11,17 79:2 98:5 117:2 piping 109:1,12,18,22 110:14,17 180:20 181:13,22 182:10 137:1 60:18 65:18 68:22 69:6,8 111:2,13,14,21 113:4,7,9 182:13 184:13 188:18 personal 70:21 71:6,6 74:22 75:3,5 114:2,5,6,6,8,10 115:19 191:20 193:13 196:13 166:1 175:8 76:12 91:1,5,9 116:11 124:12 126:17 201:11 202:4 personally pit 127:14 128:3 129:11 130:7 pcbs 12:1 62:13 38:3,4,4,7,10 130:8 133:11 135:1,5,6,12 6:1 7:11 9:1254:11 115:2 personnel place 135:13,15,20 137:7 143:22 117:6 119:2,13,14 122:2 15:15 30:17 77:22 106:22 16:2 27:12 39:19 40:12 145:6,14,17 146:10,13,14 124:1 126:12 127:20,21 165:11,16,22 166:4 178:17 51:8 55:5 56:21 62:19 64:1 149:3 151:22 152:1,3,6,19 129:18 131:22 132:5,9,10 ph 75:16 123:16 126:15 153:12,17,19 154:4 156:9 132:12,12,15,19 133:1 71:14,19 72:4 127:21 133:5 136:5,11 156:12 157:9,22 158:10,14 136:18 137:9,13,19 141:20 phase 145:5 147:16 151:13 158:15 159:20 162:11,20 145:4 147:5 148:10,12,15 33:5 34:16 76:3 120:20 157:16 170:16 172:10,10 163:2,10 166:6 168:12,17 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010141 [plant - production] plant (cont.) pointing prefixes problem 171:8,9,21 172:1,6,10,15 180:11 86:8,10,13 9:9,11 21:17,20 25:6,9 172:16,20,20,22 173:5,7,10 points present 28:10,18 32:17 38:10 42:7 173:16 174:15 175:21 164:20 1:21 39:18,21 122:9 125:10 70:12 91:6,22 92:2 102:16 176:2,22 177:3,16 178:4 policy 135:7 129:17,18,20 140:9 144:12 179:12,19 184:14 185:2 175:9 presentations 164:18,20 165:3 170:10 186:4 188:10,11,12,14 pollution 182:4 172:11 180:18,20,21 181:3 190:9,15 191:22 192:4,4 4:11 5:15,20 24:17,18,20 presently 181:9,13 186:17 193:16,18 193:12,22 194:14 196:16 28:20 29:6 31:8 34:1,5 16:20 17:6 problems 196:19,21 197:1,7 199:14 41:21 77:21 78:16 79:2,17 press 5:3,15 19:9,11,11,14,17,20 199:21 200:2 201:6,11,13 80:12 83:7 106:10,20,21 58:21 23:4 38:12 76:11,14 122:2 201:14,16 202:5 107:4,18 114:22 115:2 presses 126:3 136:11 137:5 160:7 plants 118:2,8 119:21 125:18 58:19 177:1,6,8 193:13 4:12,14 6:4,4,15 18:10,11 126:6 127:4 130:10 135:2 pressure procedure 18:13 19:15 21:6 62:4,8,13 135:16 151:3 174:22 175:5 73:7 74:17 133:4,7 164:18 168:15 86:2 88:10 96:5 108:16 pool 165:1,4 189:7 proceeding 112:5,15,22 113:5,10,21 61:3 153:8 presumably 49:12 114:3,13,19 118:22 119:4 poor 131:4 167:14 182:19 process 121:1,7 124:9 125:6,14 90:11 186:12 3:9 11:11 19:10 21:14 23:3 127:9,10,18 128:2,9,20 position presume 23:4 24:9 29:6,8,11 44:4,20 135:14 136:3,4,9,19 146:19 12:21 13:2,5,10,21 14:3,5 50:15 98:7 162:7 190:11 44:21,22 50:3,9 51:8 52:11 157:21 169:17 182:16 14:10,13 15:1,3,9,13,19 191:1 52:16 53:9,13 54:2,20 58:6 190:10 192:17 193:5 16:3,5,8,9 17:15 84:10 pretreat 58:17 66:7 75:13 79:14 198:22 99:13 107:13 117:2 125:3 34:22 84:17 89:14 92:8 96:20 plantwide positions pretty 97:6 98:16 101:8,14,18,19 107:16 131:3 13:20 22:15 77:20 194:22 57:2 94:3 122:2 172:9 102:21 107:14,20,22 108:2 plasticizer possibility 185:14 125:11 127:1 132:15 138:20 34:21 156:6 197:6 prevent 133:15 141:7 148:13,21 platen possible 67:1 147:9 158:14 58:19 10:791:19 preventing processed plausible possibly 61:6 26:14 95:1 183:21 6:6 preventive processes plenty pot 70:19 19:12,15,22 21:9 23:5 24:1 160:7 188:16 57:16 58:1,5 previous 31:1553:7 59:1960:16 plume potash 29:5 49:11 61:11 115:10 73:21 109:9 136:3 146:20 25:3 26:16 27:6,8 28:7 64:20 167:14 188:3 processing 29:12,16 potassium previously 31:20 84:13 plus 64:18,20 65:1,9,13,14,16 84:4 87:22 164:14 produce 43:16 188:14 65:20 66:1 67:13 71:13,17 primarily 64:19 pna 72:6,9 94:5 4:14 59:2 67:1 86:1 119:17 produced 100:13 102:18 potential primary 43:7 44:7 77:4 87:16 90:6 pncb 147:16 169:21 170:8 39:5,14 producing 100:20 103:1 105:19 110:8 potter prior 132:10 pnp 2:2 190:8 product 35:14 pounds priority 8:18 25:14 26:11 27:2,4 pnpt 73:7 145:2 161:21 118:21 119:8 129:22 43:13 46:13 48:4 54:3,5,10 20:7,22 21:11 ppb 136:22 58:18,1860:9,11,1364:15 point 179:19,22 180:1,7,8 186:5 probably 66:9,11,15 72:15 73:13,15 19:2 57:5 75:15 105:10 ppbs 4:22 20:7 24:13 32:20 42:8 74:2 75:1,13,21 76:20 106:17 123:15 125:21 176:18 55:1859:1667:8 118:15 94:19 104:8 105:22 109:17 127:5 131:15 136:6 148:22 practice 121:11 128:10 136:16 109:19,19 113:10 137:14 154:8 157:17 158:3,4 155:5 190:9 137:6 148:13 163:2 174:16 137:20 142:5 145:22 170:6 163:10 164:6 165:7 168:14 preaching 176:5 193:13 200:7 172:21 187:4 181:18 192:14 163:14 probe production pointed precisely 123:12 13:14,21 19:9 21:1924:17 123:13 187:6 32:22 37:16 42:17 45:11,14 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010142 [production - reads] production (cont.) projects (cont.) purge quite 45:18,20 46:1,10 47:21 104:18 105:1 106:22 188:19,20 189:1,2 25:4 39:13 40:20 44:13 48:16,18,19,20 49:11 50:14 128:10 136:9 147:4 155:22 purification 50:16 67:21 68:20 97:9 51:6,14 52:2 58:7 62:3 70:2 182:15,16 183:2 184:1 109:6 114:22 116:4 132:10 70:12,16 77:21 78:18,21 189:11 195:6 197:19 purports 145:19 79:10 93:8 97:17 98:1,7,10 199:19 118:13 quote 98:19 106:16,20 108:2 promoted purpose 131:3 131:16 133:10,19 137:22 14:6 16:5,9 85:5 86:3 138:2 139:18 147:1,2 pronounce 153:15,18 154:7,11 156:14 100:18 177:18 pronounced productivity 15:8 19:21 20:10,16 proper products 156:10 5:22 6:2,5,17,19,21 20:11 properly 23:7 35:18,20 46:13 96:8,9 68:13 155:11 110:9 112:15,16,22 113:3,4 properties 115:10 136:19 137:8,11,21 142:17 132:13 137:15 169:14 r pursuant 1:17 rain 74:10 140:13 pursue raising 34:21 purview 46:12 48:1 88:6,17 89:4,9 96:4 107:5 113:2 145:14 put 201:15 ran 55:10 60:4 64:2 68:12 113:14 133:22 raney 27:1931:5 60:1,1061:4 72:18,22 63:4 66:11 69:20 76:6 92:2 137:22,22 138:2 139:4 property professor 159:20 115:5,11 144:17 proportionate profit 43:5 44:11 146:21 proportionately program 42:19 102:5 120:22 121:4 127:5 proportions 128:4 130:9,19 131:2,13,14 187:7 141:11,19 148:10 151:5 proposal 163:5,6 177:20 182:11 21:21,22 188:6 191:12 195:15 propose programs 21:20 121:8,17 123:22 130:19 proprietary 135:1,5,8,9,14,18,22 136:5 65:3 93:22 136:14 148:4 protecto progression 167:9 22:13 protectoseal project 167:6 20:19 28:16,16 29:6 30:5,7 provide 30:22 31:8 44:9,12 89:17 30:14 82:17 141:21 147:8 91:21 97:13,15 98:20 99:7 provided 101:16 102:8,21,22 103:3,4 142:3 155:6 103:14,16 107:2,3 122:13 public 127:3 128:5,7 131:14 1:20 80:9 160:17 142:11 147:13,14 156:4 publicity 158:7,9,10 168:14,15,16,22 181:8 169:1 178:14 189:2,19 published 191:11 196:10 197:10 115:5 139:8 198:3 199:4,13 pull projects 136:13 19:21 20:9,1421:10,12,16 pump 22:2 24:10,14,16,17,18,18 60:17 24:18,20 28:20,20 30:10 pumped 34:2,5 37:14 38:16,19,20 65:17 73:13 41:22 42:3,13,15,21 43:3 pumps 44:13 78:12 79:12 89:15,20 76:16 91:19 92:21 93:2,11,12 punitive 97:2,7,11 101:9,14 103:2,5 181:7 128:18,20 137:21 140:14 141:15 154:22 169:17 179:21 189:7 192:15,19 putting 123:12 182:21 192:21 pyrex 90:9 q 176:17 180:11,14 raptors 115:8 119:18 rasmussen 139:16,17 rate 42:20 125:10 raw qualifying 20:20 21:2 43:4 44:10 48:4 171:11 59:20 65:22 70:13 72:14 quantities 75:22 102:3,6 103:13,21 145:11 145:19,20 quantity ray 87:17 124:16 quarter reach 13:7 93:8 36:11 41:16 quebec reached 113:13 57:5 110:19 138:11 168:14 queeny reaching 6:8 13:1,3 14:12,14,22 170:12 17:11,17 18:22 19:1222:4 react 86:16 107:11 108:5,6,7,8 65:13 108:19 109:1,3,16,18,22 reaction 110:17 111:2,8,13 113:9,19 27:3 35:19 60:9 104:3,5 115:18 116:11 124:11 read 134:17 11:1549:1796:10,13 question 115:14,15,21 116:18 29:10 38:15 74:4 117:5 155:15 159:2 160:16 129:12 130:18 132:7 138:7 161:14 162:15,17 185:1,5 145:18 149:1 169:2 172:9 200:19 179:1 180:3 183:9 184:7 readily 186:8 196:5 197:16 200:22 90:12 146:8 201:2,15 reading questions 115:3 161:1 174:16 8:14 10:4,6 114:21 117:16 reads 118:20 137:7 165:10 119:20 169:20 186:3 quickly 197:20 199:5 70:1 181:3,9 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010143 [real - remains] real received (cont.) 55:12 184:13 187:16 194:9 really 198:13 56:8 72:22 96:18 117:8 receiving 132:14 152:11 163:6 16:17 165:15 171:10,11 176:6 recess 177:12,15 184:4 42:10 117:10 163:15 reason recessed 11:22 28:10 50:6 73:10 83:22 135:21 146:2 149:13 recipient 159:16 164:17 168:6 181:2 28:9 118:4 186:14 188:5 202:11 recipients reasonably 146:13 122:1 reclaimed reasons 150:17 26:15 193:14 recognize rebuilding 47:3 78:3,6 88:1 154:1 68:11 recognized recall 144:10,12 6:18 7:139:10 19:22 21:9 recollection 22:1,2,10,14 23:5 24:10,15 82:6 88:5 89:12 109:11 25:16,20 27:8,21 28:13,20 162:10 166:22 174:5 30:5,22 32:11,18 34:1 35:5 183:17 187:22 193:10 36:17,21 38:19 39:1 43:12 197:15 198:2 44:6,17,22 46:21 47:2 48:6 recommendations 51:5,17,19 53:15 57:7 58:6 62:6,10 173:13 58:10,14 59:8 62:9 63:7 recommended 66:16 67:15 68:18 69:4,16 173:15 69:17 70:15 73:20 74:12,19 reconvene 75:8 76:8 77:3,15,17 78:11 202:15 79:4,16 80:4,8,11 81:11 reconvened 82:2,8,11,22 83:3,9,19 83:22 85:11 86:5 87:11 89:14 record 92:10 95:14,16 97:1,6 98:1 10:3 13:15,16 50:1 83:20 98:10 99:16 100:5,8,10,21 96:13 105:16 117:14 101:8,14,22 102:11,21 130:15 154:14 185:16 104:18,22 106:10,21 108:4 186:3 187:10,11 196:3 114:8,14 115:11,14 116:6 198:8 117:2 118:17 121:19 records 127:13 135:4 136:13 142:8 175:9 143:13 145:18 147:21 recover 148:8 149:10 150:19 153:7 26:1 45:5 73:14,18 111:3 156:13 160:8 162:2,14 recovered 163:9,14 167:16 170:2,5,7 73:15 170:11 171:4,8 172:1,5,6 recovering 173:15 176:2,20 177:8 66:13 92:3 178:2,7,14 184:1 186:8,10 recovery 186:14 187:5 188:5,12 102:5 189:21 190:18 196:21 rectangular 197:3,4,9 199:13,19 200:9 40:20 201:2,10,15,18 202:2,7 recycle receive 39:20 41:6 128:14 154:5 168:1 recycled received 73:4 95:5 12:9 32:19 39:3 48:20 recycling 152:10 169:3 179:2 183:10 92:4 redistill refresh 143:3 82:6 88:4 89:12 162:10 reduce 166:21 183:17 187:22 70:16 147:4 181:13 197:14 198:2 reduced regard 20:20 62:10 89:15 101:9,15 reducing 102:22 127:1,18 182:13 20:10 42:22 149:4 183:19 regarding 184:3 46:22 97:7 98:6,11 105:1 reduction 118:8 152:14 20:13,15 43:5 44:11 regular refer 33:5 128:3 23:15 57:14 58:3 131:9,13 regularly 143:9 152:2,13,17 163:18 163:1 164:4 167:12 171:1 174:18 regulation 182:22 188:9 191:11 193:9 181:4,7 reference regulatory 53:20 155:18 161:8 167:11 133:3,4,7 149:12 175:13 168:8 170:20 175:13 181:17201:5 179:22 185:22 187:19 reject 188:11,19 192:7 193:8 111:4 200:14 relate referenced 4:135:86:127:11 11:12 57:19 180:9 20:9 130:19 references related 56:3 129:16 159:6 186:1 5:2,14 8:14 9:7 19:21 21:10 189:10,14 195:5 200:16 21:13 24:22 42:3,22 43:3 referred 44:14 78:12 80:14 93:2,11 31:10 38:9 78:5 168:18 93:13 97:13 135:22 136:18 183:4 200:1 148:13 175:5 193:12 referring relating 40:14 51:13,19 58:4 76:19 4:11 10:21 11:2,5 24:11 89:1 109:8,20,20 133:2 37:14 38:16 42:13 45:3 144:1,2,4 196:15 92:21 97:2 104:18 126:2 refers 135:18 193:20 17:3 110:18 131:4 132:14 relations 140:11 141:1 148:11,15 160:17 153:5,13 161:15 167:12,14 relationship 192:3,14 193:22 195:13,19 33:11 112:20 114:4,9 126:1 200:5 158:2 refined relatively 72:15 121:15 123:9,11 75:1 89:21 103:5 137:16 released refining 145:11,16 104:8 releases reflected 125:2,14 127:10 128:2 155:12 reliability reflecting 24:19 90:6,14,22 153:10 reliable reflects 121:7,14,20 123:18,21 168:22 186:14 124:6 reformulated remain 137:19 186:4 reformulation remains 137:8,10 61:11 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010144 [remarkable - ring] remarkable repeating required responsibility (cont.) 187:4 197:1 201:20 165:17201:14 59:22 65:21 128:6 132:4 148:12 193:20 remediation rephrase 149:2 150:21 158:19 responsible 149:5 197:4 192:20 5:20 45:14 47:13 48:14 remember repiping requirement 52:11 70:12 81:12 93:7 5:7,13,22 7:7,16 8:2 18:8 140:1,6,8 149:8 96:1997:10 112:13 20:8 32:3 33:14 38:12 40:7 replace requirements rest 40:11 44:8 47:4,5,19 48:12 70:21 85:5 90:16 101:19 133:4 182:10 35:12 68:12 170:4 191:4 55:19 57:9,12 58:9 59:15 124:16 194:13 requires result 60:6 63:10 64:7 66:8 67:18 replaced 87:17 104:3 173:16 69:12 74:11,15 75:5,12 45:1968:15 154:12 171:18 research resulted 77:13 78:14,17 79:1,9 83:2 196:22 24:6 52:6,10,17 107:20 26:16 43:5 44:10 123:7 86:7,11 95:21,22 97:5,11 replacement 117:1,3 129:5 133:15 results 97:13 99:10,11,20 101:12 38:20 92:1 192:22 199:20 148:20,21 155:16 161:13 110:4 123:5,10 102:7,19 105:6 107:3,7 replacements residence resumed 108:10 109:13 111:17 139:1,3 158:19 84:4 114:11,12,16 115:9 116:14 replacing residential retention 116:15 125:21 128:9 188:20 82:3 175:9 132:11 133:9 134:3 135:7 report residual retired 135:10 139:17,19,20 140:9 17:13 19:4 33:8,1045:17 61:15 62:20 16:14 142:4 147:14,20 149:7,12 46:6 84:16 85:2 114:3 residue retirement 153:21 156:18,20 161:1 118:1,14,15 120:10,16,17 25:2,10,14,20 26:1,9,20 16:4 162:8,13,18 164:2 167:4 125:17 126:5,10 127:9,12 27:1,4,22 45:9 54:6,8 56:22 returns 171:6,15,18,22 172:4,11,18 128:18,21 130:21 131:7 57:5,15,19,20 58:11 97:14 156:7 172:21 173:9 174:8 177:1,3 144:3 154:17 155:1,4,8,10 97:18 104:1,14 109:3,4,7 review 177:7 178:6 183:5,7,21,22 169:14,15,18 174:7 175:20 109:14,21 111:16 146:8 162:10 163:5,5 184:4 188:4,8 189:2,19 184:15,19 185:15,19 156:5,8,22 reviewed 190:4,6 191:4 195:2,18,22 190:22,22 194:18 residues 49:21 51:2 117:22 155:4 196:20 197:2,8 198:4 reported 20:10 58:14 66:6 73:20 159:4 160:19 163:1 166:12 200:20 18:4,6 33:6 46:21 47:8,17 76:2 95:10 98:6,22 104:15 reviews remind 48:6 85:12 87:4,5 99:17 109:8,12 111:12,20 157:1 128:3 150:8,11 105:11 107:19 112:10,19 157:11 rework reminded 114:6 118:9 126:4 174:5,7 resistant 142:11 143:13 195:8 150:10 175:21 176:3 201:14 68:22 137:13 reworking removal reporter resolution 195:9 148:15 10:4 74:6 96:13 160:14 richard remove reporting resolve 129:4 60:8 75:19 103:12 141:9 19:2 33:4 84:13 85:6 118:2 28:10 rid removed 121:11 126:1 130:22 resolved 39:16 77:14 57:16 131:17 185:13 194:17 6:22 9:14 81:16 159:11 ridge removing reports respect 37:2,4,15,18 191:21 118:7,18 128:14,17,19 108:15 110:19 115:2 117:6 right reorganization 154:20 155:2,7 161:14 149:11 150:7 166:4 188:6 7:4 13:19 14:9 15:7,12 15:14 105:10 113:12 169:16 173:20 176:4 202:4 16:13 25:16 26:12,18 28:5 repair 184:17,21,22 respective 36:16 40:3 42:2 47:5 50:21 38:19 198:3,3 199:20 represent 1:21 54:13 56:1,5,20 59:7 66:2 repaired 4:9 responded 68:17 71:9 74:7 77:1,2 196:12,19,22 representative 148:4 79:20 80:1,3 96:21 107:12 repairing 122:8 123:16 168:18 201:7 response 111:10 118:6 123:16 91:9 representatives 10:5 105:15,16 159:13 124:13 127:6 131:11 141:3 repairs 201:7,10,11 responsibilities 153:16 158:13 167:10 190:17 197:21 request 78:17,19 87:9 108:15 112:4 168:10 174:15 176:17 repeat 98:17 152:14 182:12 194:19,21 199:2 200:7 14:17 requested responsibility ring repeated 96:13 38:17 46:3,16 48:18 78:21 89:12 200:14 121:5 124:2 131:19 138:2 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010145 [rip - separation] rip rupture sax section 190:14,14 195:12 140:1,5__________________ 11:15 159:2 160:16201:4 rise borough s saying sediment 115:5,12 116:20 rise borough's safety 11:1262:6,983:1791:4 118:16 165:5,7 says 151:8 seeing 117:6 119:11,18 144:17 rises sake 10:3 131:8 132:8 139:12,12 124:8 171:18 145:1 148:3,18,20 162:11 seen 66:12 river salary 22:13 162:17 167:3,15 175:15 179:16 188:20 191:15 53:3 self 92:17 rivers 145:1 152:3,8 161:22 sale 110:13 196:11 schedule 16:21 sell 129:19 roadway salicylic 49:12 schedules 29:20 72:22 selling 85:13 robinson 52:4,6 rock 20:2 21:11 salt 64:13,16,22 65:8 71:13,17 72:2,5 94:16,18 95:20 152:10 48:19,21 school 10:10,11 science 138:19,20 semester 111:11 semicontinuous 70:4,6 95:20 171:3 190:10 rodel 85:15 roger sample 122:3,4,8,10,11 123:2,4,15 10:19 122:11 scientific 123:16,19 129:10 136:5 200:21 119:11 scientist 161:8 semiknowledgeable 165:10 seminars 99:18 100:15 rogers 184:5 188:1,7 190:13 191:2 role 51:7,10 52:8,15 82:19 130:9 roller 99:11 rolling sampled 144:16 samples 122:22 123:6 156:7 196:11 200:15,18,21 201:12,16 sampling 121:13 122:1 123:9,11,13 123:18 136:2,6 141:11 144:13 145:9 146:1 151:5 16:18 roman 139:22 141:19 rosenberg 30:7,8 rotten 151:13 177:10,20 186:16 188:6 sanitary 92:12 santobrite 113:17 81:14 roughly 105:22 round santofin 170:5,5,6 santowax 72:15 30:2 116:1 scientists 116:6,9 scope 103:16 scott 85:13 scrap 195:8 scraped 61:4 scrubber 59:10,12,13 63:12 64:2 141:16 scrubbing 141:13 scrutiny 127:22 se 12:10 send 128:22 129:3 154:19 166:18 174:2 sending 154:18 156:5,22 167:12,16 169:14 194:18 sensible 98:20 sensitive 142:18 170:15 sent 34:22 72:7 73:15,18 156:7 156:15 157:2,11,15,20 166:14 167:1 169:18 173:20 179:5 184:8 191:7,7 191:11 196:6 197:17 198:16 sentence 49:9 route sarcasm 166:1 93:13 95:2,5 seal 57:15 148:20 169:20 180:16 191:21 199:5 92:18 routine sarcastic 165:13 147:17 167:9 second 200:19 separate 49:8,9 143:21 153:14,18 satisfied 31:8 52:3 87:1 125:3 130:2 39:22 40:1 48:9,12 64:21 174:2 195:14 200:15,21 rubber 112:14 139:3 saturated 131:6 143:14 150:9,12 65:12,15 72:8 87:12 89:3 158:21 165:9 166:17 169:8 99:21 108:12 110:20 134:12 172:12,15,17 run 71:19 sauget 7:15 13:19 25:6 59:18 60:4 152:4 161:20 176:14 183:13 188:17 195:4 196:9 199:3,10 secondary 128:14 130:19 158:7,9 188:9 193:12 separated 66:22 91:2 139:6 156:9 190:15 running 57:2 runoff savage 1:13,16 3:3,7 4:3,8 42:12 39:5,20 secondhand 49:14,15,17 50:18 84:3,8 87:19,21 117:11,16 163:18 159:22 160:2 181:20 secretary 187:12,15 194:5,9 196:1,5 128:20 169:16 94:12 111:3 separating 23:19 separation 110:13 111:1,5 74:10 140:13 197:12 198:6,12 202:18 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010146 [September - somebody] September sewer (cont.) similar small (cont.) 144:20 166:9 167:6,20 197:21,22 198:3 199:5,13 7:14 22:20 39:13 62:7 94:7 67:8 78:10 96:7,9 103:2,5 198:9,10,12 200:6,9,18 95:1,22 123:6,7 136:4,4,8 104:6 105:4,5 107:18,20 sequence sewered 136:10,10 169:16 109:15 110:12 111:6 111:19 131:22 132:9 141:20 147:5 simple 113:14 122:5 133:15 sequential 148:10,16200:15 31:18 33:17 59:20 75:13 141:11 150:3 50:7 164:7 sewers 179:1 184:7 smaller sequentially 36:13,14,18,19,22 37:1,4,5 simpler 94:8 56:19 37:18 38:2,13,16,17 63:18 95:2 smell series 74:9 92:7,8,10,12,16,21 simply 81:14 50:16 86:15 93:2,11,13 102:10,12,15 9:8 28:9 34:13 60:7 66:11 smelled serious 119:1,3 132:5 144:16 145:9 118:21 123:4,19 125:11 26:22 80:3 76:10 164:18 165:2 172:11 149:4 151:22 176:21 177:1 136:21 141:12 142:19 smith served 177:4,12,21 178:3 183:15 163:13 164:17 166:6 1:18 202:3 188:10,11 196:11,18,21 186:12 192:15,16,20 snow service 197:6 200:22 201:14 37:8,19,21 63:19 67:5 77:1 23:11,14 84:11 99:22 shared single snow's 134:16 143:6 168:13,20 47:17 146:19 186:18 5:6 128:20 169:17 37:8 serviced sheen sir soaked 190:16 61:9 10:10 170:20 171:4,9,12,13,14 services sheets site soda 14:7,16,18 17:16 18:3 49:10 24:6 25:1 114:7 146:21 64:16,20 94:16,19,20 session shift 149:5 158:3 sodium 84:1 24:7,7 48:21 sites 35:9,14 64:13,16,18 65:9 set shiny 119:2 174:6 65:13,14,15,20 66:1 67:13 21:4 30:14 101:18 124:21 61:12 situation 72:9 94:5 95:18 113:16 173:12 193:6 ship 29:12 33:16 122:15 131:1 soil sets 87:17 137:4 144:4 146:18 154:20 12:6,7,12,1440:641:11 179:13 shipped 166:4 173:4 175:19 176:9 63:9 80:6 172:2 setting 75:21 111:8 179:21 181:22 182:2,5 sold 48:19,20 180:13 shipping 184:13 185:12 191:4 5:22 6:17 74:2 75:11 settled 43:21 54:16 55:7,8,10 59:5 situations 132:12 137:15200:3 39:15 140:18 63:4 104:16 190:15 171:20 solid settler short six 39:14 43:7,11 44:6 66:8 39:5,5,7,14,20 41:1773:8 101:4 113:15 16:4,14 82:10 84:12 85:11 67:21 74:1,12,13 122:7,9 settles shortly 124:18 solidify 39:8 7:6 size 61:3 settling show 128:6,8,10 182:15 solids 140:14,18,20 141:1 191:22 196:12 197:15 sized 61:2 122:6 seventh shut 25:8 31:7 soluble 2:10 69:7,21,22 138:6 skipped 35:10 148:15 severe shutdowns 134:5 solution 29:2 133:4 164:20 70:20 slight 25:6 32:17 33:17 94:16 severson side 91:2 103:11 132:15 157:7 47:17 37:4,5,15,17,18 40:2,21,21 slightly solutions sewer 52:21 94:20 158:11 169:7 110:6 21:21 36:15 38:19,19 40:18 59:12 sign slow solve 67:3,4 76:13,22 129:7,10 98:20 16:7 136:10 129:16,21 131:8 139:8 signature sludge solvent 140:22 141:13,14,18 163:19 39:4,6,16,21 95:16 161:8 138:1 166:18 143:15,19,21 144:2,6,11,21 significance 161:11,15,17 191:21 192:2 solving 145:5,16 146:10 147:17 86:13 146:4 small 23:3 193:13 153:14 161:20 176:15 significant 6:7 21:1223:11,14,16,17 somebody 177:3,4 183:15 185:21 58:9 89:22 90:13 103:6 27:5,6 29:3 39:21 42:3,13 33:10,12 72:21 79:1 116:22 186:5,9,11 187:20 188:6,9 significantly 43:12,15 44:15,19 48:8 150:13 152:12 168:17 188:10,12,13,13 191:20 20:19 43:4 162:19 56:10,15,15 59:3 60:1,8 176:6 182:18 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010147 [someplace - sufficient] someplace speed startup strange 5:18 183:8 157:18 104:11 118:12 somewhat spell state stream 112:18 163:17 167:19 8:21 85:14 1:2 83:18 201:20 202:10 20:21 37:8 92:3,4 95:5 soon spend statement 102:2,9 109:17,19,19,22 139:3 62:4 132:18 134:22 135:8 186:3 111:5 123:4,12,14,15 sooner spent states 141:17 148:16 77:18 72:3 73:16 76:4 95:12 50:17 158:18 161:21 164:9 streams sophisticated 124:19 150:17 165:9 167:5 169:9 179:18 102:17 104:19 105:1 111:4 166:7 spill 180:16,17 183:14 190:12 street sorry 147:16 170:17 statistics 1:182:4,11 5:4 9:1 16:7 29:5 95:8 spilled 10:19 strike 185:10 60:19 69:1 status 11:1822:1,7,21 25:1651:5 sort spiller 119:21 125:18 81:4 82:6 98:11 107:8 9:3 74:15 156:19 99:18 100:15 stay 130:1 143:19 146:16 158:8 sounds spills 13:3,13 104:8 172:5 184:20 195:14 60:15,1861:7,11,1468:18 staying stripping source 74:19 76:8 90:19,21 147:10 146:12 103:12 151:12 169:21 170:8,11 steam strong sources sponsor 64:7,8 91:7 18:14,17 128:5 136:7,8 178:12 156:4 step structure south spot 58:16 59:11,17 60:6,6,13 18:12 110:6 152:18 153:1 172:19,20 41:17 64:1 75:18 103:12 106:2 study southern square 109:6 111:2 133:1 141:7,8 21:19 178:2 5:17 2:9 141:9 studying speak St Stephen 49:2 124:20 186:16 150:5 153:20 6:8 13:1 25:5 30:9,12,19 2:7 4:8 studz speaking 33:10,12,13 35:2 48:20 stepped 79:3,7 90:22 135:18 137:18 52:7 79:3 116:13 150:4 132:19 studz's 150:19 161:7 steps 79:11 speaks stable 45:3 54:2 59:18 70:15 stuff 170:4 110:19 187:2 125:18 181:20 special stacks stewart subject 15:15 61:20 63:1 68:21 164:11 165:12 105:7 194:10,13,15 7:14 12:10,11 90:10 110:3 72:19 150:1 200:15,18,21 stage stills 117:18 119:20 125:2,14 201:2 104:8 54:1,16 55:16,21 56:11 126:5 135:5,9,16 150:20 specialize stagger 57:2 155:14 170:7 175:8 190:2 17:6 68:13 stone submerged specialty stamp 171:17,17 41:1 6:19,21 111:2 112:16,22 164:6 stood subsequent 113:3,10 150:3 stand 118:22 131:1 18:22 155:2 specific 84:4 stop subsequently 11:13 19:8 44:22 51:17 standard 29:4 141:2 85:2 62:12 75:5 100:4 101:12,14 3:9 50:2,8,9 51:8 53:7,8,13 stopped subset 107:2 112:12 133:5 153:5 173:12 70:2 138:19,20 48:3 163:9 170:13 173:18 175:9 standpoint storage substantial 202:11 126:10 29:1 31:9,16,18,21 76:16 91:8 95:17 121:16 122:11 specifically start 157:18 189:12,22 190:2,5 succeeded 12:11 20:14 38:12 98:8 20:19 24:6,8 25:8 33:3,3,5 store 106:15,19 107:7 115:8 122:14 133:2 34:16 118:8 135:13 87:17 succeeding 147:14 155:4 161:1 196:10 started stories 121:13 200:1 24:7 36:8 86:14 91:15 160:21 161:1 successful speculate 103:3 119:6 157:17 storm 77:10 101:5 35:21 151:17 188:8 starting 196:11,18 197:22 198:3 sufficient speeches 10:10 17:1259:20 64:19 strafmeyer 192:15 182:4 84:9 124:16 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010148 [sulfate - think] sulfate 95:18,19 sulfur 27:2,9,10 sum 16:18 summarize 154:21 summarized 139:8 summary 182:20 sump 169:21 170:8 superficially 94:7 110:5 superintendent 14:6,16,18 17:16 84:18 85:6,7 86:4 88:12 93:1,3,4 93:6 107:15 114:8 125:8 130:11 133:20 134:7,8,10 134:16 139:19 147:1,2 superintendents 114:5 125:7 193:5 superior 1:1 supervised 46:15 supervising 14:2 84:9 85:1 86:1 87:6 88:7,18 89:7,16 91:18 92:20 93:15 96:16 97:1 105:8 supervision 45:16 supervisor 13:14,22 21:19 24:7 32:17 32:18,22 33:7 37:16 45:11 45:14,20 46:1,10 47:21 48:16 50:14 51:6,14 58:8 66:10 70:12,16,19 77:21 78:18,22 79:10 97:17 98:1 98:8,10,19 106:16 131:16 154:7,11 156:14 supplier 73:18 supply 77:11 suppose 16:21 32:4 58:3 70:11 74:10 92:18 124:6 140:21 186:14 191:19 sure 10:1 26:4 47:15 54:22 55:19 64:9 74:3 79:1 87:3 101:11 108:11 112:13 sure (cont.) talked (cont.) tenure 116:14 121:6 124:17 129:5 111:14 116:22 117:3,5 70:16 78:9 88:2 126:7 129:12 134:12 135:6 125:6,13 154:18 181:17 term 136:22 139:13,19 148:11 195:9 17:1 25:10 72:19 89:10 152:11 154:3 155:10,15 talking 92:13,14 103:5 110:18 164:2,3 170:16 174:6 181:5 57:20 79:9 131:2 135:11 141:5,6 143:12 161:15 191:17 163:3 172:16 180:10 171:2 surety 195:20 196:10 terminal 1:9 talks 184:5 188:1,7 surface 57:15 185:21 191:21 terminology 67:1 171:17 tank 88:22 surprise 29:1 31:9,17,18 32:2 58:5 terms 202:1 60:1 65:12,17 69:18 72:17 124:4 177:2 surprised 77:16 141:4,6,12,16 147:10 terphenyl 114:11 116:16 185:3,5 157:18 165:5 189:3,4,7,8 59:21 72:14,16,16 73:1,3 202:9 190:16 testified surprising tanks 4:5,17 9:16,18 84:5 181:18 174:1,3 66:20 72:5 76:16 testify survived tar 7:2 182:2 18:14 44:3 testimony suspect target 143:8 146:3 177:18 153:11 162:8 testing suspected tarry 121:19,22 161:7 187:3 59:4 tetrachlorobenzene suspended team 106:9 65:6 33:3 62:3 185:15 texas swimming teams 113:11 153:8 62:8 173:5,7 therminol switched technical 192:7,8,12 195:16,19,21 96:16 124:10 14:6,16,18 17:16 18:3,8,11 thing sworn 23:11,14 84:11 93:8 99:22 20:17 56:7 61:17 70:9,18 4:4 84:4 108:8 130:12 134:16 72:11 83:15,17 89:10 96:12 system 168:13,20 98:15 123:3 127:11 143:21 8:7 9:5,6 25:8 30:14 31:7 technically 155:15 156:19 159:21 36:15 45:3,4 58:4 64:22 94:3 165:8 172:8 174:2 187:8 65:1,3,18 71:4 72:3 73:17 technicians 189:20 86:16,19 91:2,6 92:2 97:20 107:19 things 99:8 177:4 188:10 technology 44:19 76:14 78:16 80:10 systems 16:22 17:1,4,7 90:8 88:11 95:9 109:2,5 112:2 64:21 65:15 192:20 telephone 123:17 131:19 136:16,17 t table 52:19 53:2 tafey 84:17 85:3,4,4 taken 10:14,17,21 11:2,5 12:5 13:13 54:16,18 55:1 56:22 58:11 70:15 73:13 104:15 108:19 109:12 111:21 122:4,8 123:2,6 133:6 144:14 talk 127:3 128:4 185:12 talked 29:9 33:19 97:3 99:2 175:15,18 telex 30:20 tell 5:1 26:19 116:5 117:21 171:19 188:22 telling 166:6 182:19 temperature 158:19 tended 61:3 tends 122:7 tentative 50:2 136:20 137:8 141:10 155:10 159:22 164:16 171:18 173:9 181:14 think 4:20 5:6 13:3 18:19 20:7 28:12,22 31:10 47:5 55:2,3 55:5,15,1859:1062:15,15 81:17 82:3,10 86:8,11 88:10 93:12 97:9 98:4 99:19 102:13,19 107:16 115:17,20 116:14 120:20 121:9 124:16 126:15 127:15 133:11,19,22 134:7 134:11,15 138:12 141:7 148:1 151:18 152:4,18 155:8 157:16,17 163:12 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010149 [think - type] think (cont.) time (cont.) town trenching 164:15,17,20 166:1,5 118:19,21 119:7 121:11 191:14 189:12 170:13 175:6 178:11,16 122:17,21 125:5,20 127:15 toxic trend 181:18 186:13 191:13 130:11 131:1 132:3,22 26:21 90:15 193:13 194:15,15 195:2,11 133:5 134:8,11,13 135:7,10 toxicity trichlorobenzene 200:4,5 201:22 136:3,17,18 137:3,6,20 11:6,12,13 106:9 third 138:5,12,13,17 139:18,21 toxicological tried 7:19,20 158:22 185:20,22 144:5,7,9,11 146:9 150:12 193:8,15,18,21 185:6 200:13 151:4 153:17 154:9,11 track trivial thirty 157:10,10,14,22 158:19 120:22 136:6,15,21 177:11 66:4 142:21 2:10 160:8,11 166:3 167:2,17 178:12 190:14,14 195:12 trouble thought 170:14 171:20 172:21 tracking 75:2 26:17 28:19 29:9 58:10 175:19 177:4 180:17,21 128:5 troublesome 97:18 103:19 116:3 121:15 184:2 187:8 189:20 190:8 trade 76:10 122:18 141:4 162:14 194:16 195:1 196:19,22 29:22 72:22 75:10 192:12 trucks 164:15 173:13 197:5 199:15,21 200:3,11 201:13 tradition 188:3 thousand times 61:19 true 32:3 4:19,20 27:21 32:7 63:21 trailers 67:21 108:9 thousands 94:2 139:18 172:13 177:5 190:13,13 191:2 trust 182:22 tippee training 2:3 three 114:16 12:10 try 4:14,20 6:6 15:2 22:17 titanium transfer 10:7 13:1944:1462:19 23:17 24:13 45:22 56:8 90:11,16 16:22 17:1,6 113:9 132:12 70:20 136:6,11 147:17 62:5 66:19,19 103:9 107:14 title 132:16 138:21 142:6,7 trying 110:5 127:20 128:14,17 12:22 13:12 14:1548:17 143:5 160:5 192:13,17,19 118:22 133:11 136:18 142:12 157:21 174:5 52:18 125:21 transferred 172:18 173:12 178:18 thrown titled 13:6 14:1,11 15:4 16:8 85:4 179:21 95:13 120:10,16 144:1 transferring tsd time titles 17:4 14:8,15 17:19 18:1323:17 4:21 6:20 7:5,19,20 8:14 18:8 transformers 23:19,22 33:6,7 49:4 84:12 10:6,8 12:2,21 16:1 17:12 today 142:16 84:18 85:1,5,7 93:1,4,4,10 18:4 19:14,1821:1,1022:3 4:13 124:5 translation 96:3,17 99:17 107:11 109:1 22:7,14 23:6,10 24:2,12 token 155:12 124:11 130:6,11 133:22 27:21 28:4,13,17 29:7,13 62:7 transmit 145:15 148:4 154:9 29:22 30:10 31:21 32:6,21 told 199:10 tubes 33:1 34:2,5 35:6 37:13 82:21 107:10 transmitted 90:9 38:20 41:13,22 42:1,8,16 tolerate 184:14 198:20,21 tuesday 43:4,8,15 44:7,18 45:1,17 70:14 91:9 transportation 1:15 46:14 47:3,11,21 49:2,18 tolerated 8:11 turbinol 50:13 52:9 53:12 55:17 69:3 treat 8:20 56:19 57:3 58:7,12 59:9,13 tom 66:4 turn 59:16,1660:15,1561:20 47:1 133:19 treated 52:3,19 53:16 57:13 117:19 63:2,8,15,22 64:2,12 65:5 tony 72:5 131:6 144:19 158:21 161:6 68:19 69:5,8,8,13 72:12 99:18 101:1 105:9 139:17 treatment 161:19 167:20 169:19 73:16,16 77:9,19 78:14,17 tool 34:11,14,15,21 35:4 36:2,6 179:8 184:11 185:18 195:4 78:21 79:5,7,10,20 80:18 150:1,3 36:7,11 37:11 39:1,3,5,10 196:9 197:19 199:3 81:21 84:8,20 85:7,19 87:3 top 39:11,19 40:1,5,14 42:4,6 turned 87:6 88:6,7,9 89:17 90:11 50:21 53:20 70:5 123:15 42:14,19 43:10 60:12 71:21 9:13 33:17 90:16,19,20 91:15 92:15 134:14 167:21 174:21 71:22 75:18 76:3 79:8,13 twice 93:9 95:3,9,20,21 96:2,11 197:20 79:15,18 80:2,6 92:18 137:20 96:22 97:10,13 98:2,8 99:5 torn 152:1,3,6 161:18 186:4 type 101:10,17,19,22 103:9,18 95:9 191:22 192:4,4 17:7 28:21 30:15 56:7 104:20 105:2,7 106:11,12 total trench 57:20 61:17 78:21 83:14,17 106:14,16 107:6 108:12,14 22:15 107:21 153:11 151:18 189:21 190:1 89:14 98:15 101:8 102:21 109:1 112:8,10 113:1,1,15 177:16 trenches 151:8 159:21 161:17 162:3 114:19,20 115:3,18 117:7 140:10,12 164:13 187:8 202:4 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010150 [typewritten - water] typewritten unreacted various (cont.) volumes 153:13 103:13,19 104:1,6 55:20 71:4 93:20 108:2 56:13 typical unrelated 114:2,19 118:22 119:2 voluntarily 156:8 170:6 128:2 132:13 135:1,1,4,5,6 181:5 typically unreliability 135:8,17 136:13,14 139:18 voluntary 20:12 55:21 61:9 63:5 122:14 123:1 173:11 177:5 181:13 67:11 77:7 123:12 192:21 unreliable velocity w u uh 170:1 unacceptable 121:12 122:19,20 unresolved 169:22 unusual 123:13,14 vendors 75:12 vent waiting 77:17 wales 113:6,20 25:4 undergraduate 10:20 underlines 179:11 understand 64:17 158:18 185:3 200:22 29:1,2 31:9,13 upstream vented 31:19 123:13 136:6 31:16 urgent venters 114:22 118:21 119:8 134:2,3 use venting walk 171:15 want 26:2 127:5 139:6 wanted 70:14 81:20 124:21,21 10:6 129:12 143:8 157:10 understanding 17:1 21:6 25:10 66:14 90:9 33:16 127:4 138:20,21 142:5,15 vents 170:15201:16 warm 5:21 86:12 105:20 124:4 132:3,22 138:10 143:18,20 145:4,8,15 180:20 186:18 142:19 143:4 149:22 150:16 192:17 useful 189:15 191:10 understood 111:3 uses 34:9 65:22 105:17 126:11 undertake 128:1 184:20 undertaken 28:16 73:5 110:10,11 142:22 usual 32:16 usually 21:18 25:14 44:19 48:21 164:11 venture 113:15 verb 190:1 verbal 10:5 98:17 105:16 versions 86:8 vessel 90:8 wash 66:18,22 67:2,7,9,17 washed 188:3 190:13 Washington 181:18,22 waste 20:13,15,21 34:9,11,12,13 34:18,19,21 35:4 36:1,6,7 undertaking 183:18 underway 89:18 undesirable 91:7 102:7 undesired 57:3 62:3,18 80:3 91:1 109:7 122:5 128:19 185:1 192:20 utilities 178:20__________________ v vacuum 74:16 vi 142:11 village 152:4,18 187:19 188:6,9,13 188:13 192:3 Vincent 36:11 37:3,10 39:2,3,4,10 39:11,15,22 40:5,14,16 41:1 42:4,6,14,18 43:6,10 43:12 44:11 53:4,6 66:8,11 67:21 68:2 74:11 76:4 79:8 79:12,15,17 80:2,6 91:19 92:14 97:2 98:22 101:21 104:11 undoubtedly 142:6 uneconomically 110:12 unit 31:4 75:11 113:14 161:15 192:7,8 195:16,19 united 158:18 45:3,4 64:7 91:3 valid 116:3,5 117:9 121:17,18 validity 117:5 valley 27:18,20 valuable 66:14 146:21 values 133:21,22 Virginia 4:16 virtue 9:4 viscous 61:2 visible 35:9 69:20 88:13 visit 102:2,17 104:19,19 105:1,1 111:9 114:18 161:18 wastes 20:11 22:5 35:5 36:5,10 41:6 43:1,7,9,10 44:6 58:14 59:8 63:11,12 64:3 66:6,16 73:20 74:13 95:10 97:2 105:13,21 108:18 wastewater 92:1,5 97:4 102:6,7,9,12 units 161:9,11 universities 115:6 university 10:13 11:14 115:11 73:19 valve 69:18 74:17 vapor 31:22 32:1 67:1 164:18 165:1,4 61:22 visited 62:13 201:6,6 202:12 122:5 water 151:8 179:14 163:1,2 172:12 visiting 201:11 volatile 12:6,7,12,14 24:18 34:4 35:7,8,10 37:21 40:6 41:11 41:21 59:10,11,1363:9,12 63:13,14 64:22 65:14 66:18 unlimited 180:17 varied 137:5 165:5 volume 66:22 67:2,7,9,10,14,17 75:15 76:1 80:6 90:10 92:3 unloading various 56:9,15,15 57:11 114:21 115:1 122:2,3,6 152:9 18:13 19:8 23:4 50:17 129:18 140:15,16 151:8 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010151 [water - young] water (cont.) wondering y 170:12,18 175:16 176:9 148:8 yapp 201:8 woody 85:16 wauwatosa 98:3 yard 10:11 wayne word 37:20 63:19 77:17 13:13 49:18,18 58:2 90:21 yeah 154:7,11 127:4,5 132:18 171:13 8:18 39:9 ways work year 122:21 141:13 15:21 18:2 21:15,1832:16 7:20 13:4 14:4 22:14 46:3 weather 32:19 33:20 37:14 38:16 61:1668:1,10,1685:19 27:19 41:21 42:7,21 46:16,18 91:16 113:11 121:16 Wednesday 47:16,18,1949:1,462:18 174:16 202:15 weeks 84:14 91:18 92:20,21 93:8 years 97:16 98:5,18,19 103:7 4:22 13:9 15:2,10,16 22:17 16:4,14 106:20 108:8 116:3 117:9 24:13 45:22 53:9 54:21 welge 119:11,12,18 124:8 125:22 58:15 71:5 86:18 96:4 2:8 130:12 136:5,7 144:17 112:5,18 137:3 186:11 went 148:18,22 161:12,14 13:11 16:11 36:9 37:3,7,21 worked 187:7 yield 40:1741:2 43:1959:12 20:2,19 21:9 23:5,22 24:11 19:21 20:10,12,16,20 24:16 60:3 61:18 63:18 66:22 24:13,21 25:4,7 28:19,21 43:3,4 44:10 90:1 103:18 67:2,4 71:20 75:15,18 29:6 30:5 34:4 35:1,3 42:13 145:21 146:5 76:22 92:16 95:4 102:10 44:9 70:18 79:2,7 89:15 yields 104:14 106:20 109:3 96:20 97:7 99:7 101:3,4,9 146:1 187:2 111:12 138:3 151:22 178:3 102:22 105:4,7,9 125:4 young 188:13 191:18200:4 126:3 127:17 173:11 154:2,3 west 177:13 4:16 8:4 82:4 150:3 workers wet 29:3 32:8,11 48:21 97:19 90:6,7,7,9,14 91:1,5 95:1 97:21 98:13 we've working 41:17 56:2 202:13 24:7 30:11 34:1 78:11 79:8 wgk 97:1,12,19 104:18,22 105:8 148:18 190:14 106:10,21 135:2,5,9 136:2 wheel 139:1 148:21 154:9 160:6 61:21 175:7 185:14 188:15 white 194:15 25:3 26:16 27:6,18 works wide 117:6 40:22 66:20 wound wildlife 104:9 129:20 159:21 wright williams 78:3,5,14 176:6 47:9 48:8 114:16 146:13 write 147:1 176:5 98:18,19 Wilmington writer 1:142:5 16:7 Wisconsin writing 5:17 10:12,13 11:10,15 49:1,4 119:5 164:2 169:7 wise 169:11 163:18 written witness 21:18 121:10 153:9 3:2 4:4 38:6 49:21 50:8 wrong 51:2 117:22 120:6,10 132:8 118:14 120:5,8 159:4 160:19 166:12 wrote 163:22 168:4 Savage, James (Aroclor Dept employee) in AETNA (1) HARTOLDMON0010152