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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF NEW YORK
STATE OF NEW YORK,
Plaintiff, (
-against- (
ALLIED CORPORATION, et al..
Defendants and Third-Party Plaintiffs,
-against-
CARRIER CORPORATION, R.E. DIETZ COMPANY.NORWICH EATON PHARMACEUTICALS, INC., andSMITH CORONA CORPORATION,
Third-Party Defendants.
EXAMINATION BEFORE TRIAL OF ARCHIE
MUMBLO. held pursuant to Notice, before DAWN M.
PICARAZZI, a Shorthand Reporter and Notary
Public in and for the State of New York, held at
the General Electric plant, 381 Upper Broadway,
Fort Edward, New York, on September 26, 1991, at
4:00 p.m.
DAWN M. PICARAZZI (518) 899 - 7170
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APPEARANCES:
COVINGTON & BURLING, ESQS.Attorneys for IBM Corporation1201 Pennsylvania Avenue, N.W.P.O. Box 7566Washington, D.C. 20044JACKSON R. SHARMAN, III, ESQ.. of Counsel
WHITEMAN, OSTERMAN & HANNA, ESQS.Attorneys for General Electric1700 Liberty BuildingBuffalo, New York 14202DONALD S. STEFANSKI. ESQ., of Counsel
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S T I P U L A T I O N S
It is hereby stipulated and agreed by and
between the attorneys for the respective parties
hereto that the signing and filing of the Notary's
oath be waived; that the formal filing of the
transcript of testimony with the Clerk of the
Court be waived; that the examining party will
furnish the party examined one copy of the
testimony as taken without charge; that all
objections to questions except as to the form
thereof be specifically reserved to the time of
trial: that the testimony, when transcribed, may
be read by the deponent and signed and sworn to
before any Notary Public or other officer
authorized to administer oaths.
DAWN M. PICARAZZI (518) 899 - 7170
f •
1 ARCHIE MUMBLO,
2 called as a witness, having been first duly sworn,
3 was examined and testified as follows:
4 EXAMINATION
5 BY MR. SHARMAN:
6 Q Good afternoon, Mr. Mumblo. My name is Jack
7 Sharman. I'm a lawyer with the law firm of Covington and
8 Burling in Washington. We represent International
9 Business Machines Corporation, IBM. in a matter in which
10 General Electric is also involved and I very much
11 appreciate your taking time to come here today. I'm
12 going to ask you a number of questions this afternoon.
13 Most of them will focus on questions of chemical usage,
14 chemical transportation, chemical waste, and chemical
15 waste disposal at General Electric's Fort Edward and
16 Hudson Falls facilities from about 1964 to about 1974. I
17 know that some of those questions may stretch your memory
18 quite a bit and I appreciate that fact. For the benefit
19 of the court reporter, please allow me to finish my
20 question completely and then respond so that she can make
21 a clear record.
22 A Right.
23 Q If for any reason you are unclear about a
DAWN M. PICARAZZI (518) 899 - 7170
1 question, please ask me to rephrase it and I'll be happy
2 to do so. I'm not here to throw trick questions at you
3 or anything.
4 A I just want you to speak up a little bit because
5 my hearing isn't top notch.
6 Q Certainly. I'll be happy to do that. I'll speak
7 up or rephrase any question you are not certain about.
8 A Right.
9 Q Similarly, if at any time you want to take a
10 break, get up, get a drink of water, please let me or Mr.
11 Stefanski know and we can do that.
12 MR. SHARMAN: Counsel, my understanding
13 is that all objections except those as to form are
14 reserved until trial?
15 MR. STEFANSKI: Yes.
16 MR. SHARMAN: I also understand that
17 reading and signature of the transcript has not
18 been waived?
19 MR. STEFANSKI: That's right.
20 MR. SHARMAN: Thank you.
21 BY MR. SHARMAN:
22 Q Sir, could you please state your name for the
23 record?
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A
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Q
•6
Mumblo . Archie L.
Where do you live, Mr. Mumblo?
What is your address actually?
How long have you lived there?
Have you ever testified under oath before?
No.
Could you just briefly summarize for me your
educational background, please?
A
than
such
Q
A
Q
Not much, about eight years grammar school, other
that, hard knocks in the army and law enforcement,
as that.
Are you currently employed?
No, retired.
Was there a time during which you were employed by
General Electric?
A
Q
A
Q
Thirty years, '51 on through '81.
So, you worked for GE from 1951 until 1981?
Right.
Did you work for General Electric continuously
throughout that period?
DAWN M. PICARAZZI (518) 899 - 7170
1 A Right.
2 Q What position or job did you hold when you first
3 started with General Electric, if you recall?
4 A When I first started I worked in treat for a
5 matter of a couple of months and then I went driving
6 truck and I drove truck since.«»
7 Q Okay. So, you worked in the treat function for
8 less than a year?
9 A Oh, yeah, it was just a matter of a couple months
10 Q And then sometime in 1951 you began to drive a
11 truck?
12 A I drove truck, right. In fact, it had to be
13 around somewhere in May or June I started in.
14 Q Was that in a particular department or function?
15 A Well, it was transportation and shipping.
16 Q And, if I understood you correctly, did you stay
17 in transportation and shipping throughout the rest of
18 your career?
19 A Right.
20 Q I know this is a very long time ago, but if you
21 could focus for a moment on the period from about 1964
22 until about 1974, starting in about 1964 you were still
23 driving a truck within the transportation department?
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A Right.
Q What materials or items were you carrying in your
truck when you were driving?
A Well, that would cover a lot of territory because
we hauled a lot of production material, scrap to the dump
and stuff like that. If GE had it, we hauled it.
Q Starting in 1964, if you recall, were you working
at Hudson Falls or Fort Edward or both?
A Both.
Q Were you basically going back and forth between
the two facilities or were you going to other facilities
as well?
A We were doing both but the interplant was the
majority of it at that time.
Q Can you recall the items that you and your
colleagues carried during the time period, for example, I
believe you mentioned finished product or —
A It was both, it was finished product and it was
raw material.
Q
A
Q
A
Do you recall any of the raw materials?
Are you referring to the oils we were hauling?
Well, any that you were hauling, sir.
Pyranol or what they call PT Pyranol, pump oil,
DAWN M. PICARAZZI (518) 899 - 7170
1 such as that, all size capacitors. When they were made
2 up and the waste come up, we would haul them to the dump.
3 Q When you say when the waste would come off, where
4 would they come off from?
5 A Throughout. As far as we were concerned, it all
6 got gathered up on the dock and we would take it from the
7 dock to the dump. Some of it would be just paper and
8 foil and others would be capacitors that didn't meet
9 their specs or whatever and that all goes to the dump.
10 Q Let me step back just a second. When you say the
11 dock, that's at which facility now?
12 A Pardon?
13 Q When you say the dock, is that the dock at Hudson
14 Falls?
15 A The loading docks.
16 Q At Hudson Falls?
17 A Both.
18 Q I apologize, I think I got behind you. Can you
19 tell me again what kind of waste you were referring to
20 when you said you picked them up off the dock? I believe
21 you said capacitors that didn't meet specifications was
22 one?
23 A Right. There were capacitors, paper, foil,
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1 sweepings, anything and everything that went out, you
2 know, the old garbage bucket, everything went in.
3 Q If you recall, did you and your collegues have a
4 schedule to pick up these materials or did someone call
5 you or instruct you?
6 A That was a routine. I covered that job probably
7 for 12 years right on the scrap. That's all I did was
8 just haul scrap, that was an all day job.
9 Q Though when were those 12 years, if you recall?
10 Was that the 12 years beginning in 1964?
11 A Yeah, it would be back in there because in the
12 later years I was more on production.
13 Q So, if I understood you correctly, from "64 to
14 about '74 you were largely assigned to transport scrap?
15 A Right.
16 Q And these various wastes that you just mentioned
17 such as bad capacitors, sweepings and so forth, where did
18 you or your colleagues take them or what did you do with
19 them once you picked them up from the loading docks?
20 A Well, we take them to the dump. We had various
21 dumps we went at, first one was Fort Edward Dump and then
22 we went to Hudson Falls Dump and then went to the Fort
23 Miller Dump, that is where the majority of it went.
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1 Q Forgive my New York geography, is Fort Miller a
2 town?
3 A Just below Fort Edward, about eight miles down
4 from here. I believe that's what it is, if I remember
5 right.
6 Q When you or your colleagues were engaged in that
7 activity of picking up scrap or waste from the loading
8 docks do you recall if that waste also included waste
9 chemicals and by that I mean chemicals that were spent or
10 no longer suitable for use?
11 A Yeah, mostly everything, even stuff from the lab.
12 Sometimes we get a truckload of lab material and take it
13 all down.
14 Q Do you have any recollection of what kind of
15 materials came in these truckloads from the lab?
16 A No, I would have no idea at all.
17 Q Do you recall picking up such materials not from
18 the lab but from the production process or that were the
19 result of the production process?
20 A None other than what I just mentioned. Anything
21 beyond that, I wouldn't know. To me a barrel of scrap
22 oil is a barrel of scrap oil, you know.
23 Q Do you remember picking up drums of scrap oil from
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1 the loading docks?
2 A Oh, yeah, got it from the loading docks, some from
3 in the yard. In the yard is something that would be more
4 in the storage bit and just clean up the yard, you know.
5 Q Do you recall any other liquid waste or liquid
6 scrap besides waste oils?
7 A No. Well, unless you're talking about stuff out
8 of paint booths and stuff. I mean, they cleaned them
9 out, it all went into barrels and after that instead of
10 oil it would be more water because they would wash it out
11 and it would all go into barrels and that would go to the
12 dump.
13 Q So, the material that you just described from the
14 paint booths was put into drums and then you recall these
15 were taken along with the other materials to the dump?
16 A Right.
17 Q Okay. Do you recall during this time period
18 picking up drums of a material called trichloroethylene
19 or being told what you were picking up was
20 trichloroethylene?
21 A I tell you, it would be pretty hard for me to say
22 right now. When you say ethylene, there was some kind of
23 ethylene we took but it seems to me it was out of the
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paint booth. It doesn't necessarily have to be, I just
don't remember. Trichloroethylene?
Q Well, perhaps trichlor or TCE.
A I wouldn't remember that.
Q During this same time period that we have been
talking about from '64 to '74 when you were involved in
picking up these scrap materials, if you can recall, can
you tell me approximately how many drums of the liquid
waste that we have been discussing you or your colleagues
would pick up on a weekly or a monthly basis? Do you
have any recollection of that?
A No. You're talking about drums? It's pretty hard
now to separate because we used to figure somewhere
around 11 loads a day to go to the dump and that's a lot
of scrap to remember.
Q Of that 11 loads was both liquid and non-liquid
waste; is that correct?
A Right. Most of that would have been something
like, it would be, like, units, small capacitors, you
know, that were dumped. We had a whole bunch of them.
Q A moment ago I believe you mentioned something
about cleaning up the yard, can you tell me what you
meant by that?
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1 A Well, stuff would be gathered in there, broken
2 pallets and some old drums, some that didn't work, some
3 that leaked out or stuff like that, so then we would have
4 to clean all that up.
5 Q Where was this yard to which you are referring?
6 A Well, you would find it over here at the lower end
7 of the parking lot in Fort Edward and in Hudson Falls, a
8 lot of it was by the live test building, between there
9 and Sumpter Street. I don't know what the heck they got
10 in there now. I bet they got another building in there.
11 We used to be there, in there, we used to store a lot of
12 stuff. Are you with GE?
13 MR. STEFANSKI: Yes.
14 THE WITNESS: Do you remember these
15 places? Do you have any recollection of them?
16 MR. STEFANSKI: No.
17 THE WITNESS: No?
18 MR. STEFANSKI: No.
19 BY MR. SHARMAN:
20 Q In these two yards that you have described at the
21 Fort Edward facility and also Hudson Falls do you recall
22 if drums of spent or waste chemicals were stored in these
23 yards?
DAWN M. PICARAZZI (518) 899 - 7170
' 15
1 A No, I couldn't pinpoint anything like that, but,
2 like I say, when we got a barrel of scrap oil, it was a
3 barrel of scrap oil. Whatever it was, it didn't mean
4 much to us, just like the capacitors, we haul them down,
5 you're hauling like the big, what is it, 50 KVs, a big
6 oil, a lot of oil in them, dump them.
7 Q And, just so I understand what you said earlier
8 clearly, the only liquid waste that you recall picking up
9 were waste oils and materials taken from the paint
10 booths; is that correct, or do you remember any other
11 liquid material?
12 A Well, no, the paint booth was the one that had the
13 water and the others were drums of oil that we would take
14 down and dump.
15 Q Was the water from the paint booths also in drums?
16 A Yeah, the whole thing was dumped right in the old
17 paint and the water and it would all be in the drum.
18 Q So, besides those two things, the waste oil and
19 the paint booth water, do you recall any other liquid
20 waste at all? I know it's a long time ago, but if you do
21 recall any.
22 A Like I said, you never pinpointed it when you take
23 it. You just throw it and dump it.
DAWN M. PICARAZZI (518) 899 - 7170
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1 Q Did you ever know anybody named Tony Metevier?
2 A Yeah, I knew him good.
3 Q Who was or is Mr. Metevier?
4 A Well, he was in charge of the salvage and I
5 believe he's with the main one for getting rid of the
6 salvage, selling the iron and copper and whatever.
7 Q Was he located at Hudson Falls or Fort Edward?
8 A Well, mainly in Hudson Falls down in Building 8
9 down at the bottom. I used to haul a lot of stuff in
10 there down to him and he would separate it all out. Al
11 Alkeers used to come over and buy it up from there.
12 Q I'm sorry, who did you say?
13 A Al.
14 Q Al?
15 A Al Alkeers, he's a local junkie or was. I don't
16 know if he is even living anymore.
17 Q Is that A-L-K-E-E-R-S, is that what you're saying?
18 A Close enough for me.
19 Q And your recollection is that Mr. Alkeers would
20 buy scrap material, waste material from Mr. Metevier?
21 A Right.
22 Q When you refered to him as a junkie, do you mean
23 that he bought scrap or he had a substance dependency?
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1 A No, buying up scrap. He buy it not only from GE
2 but various mills and people around. You bring it in, he
3 would buy it.
4 Q Okay. Do you have any idea where Mr. Alkeers is
5 today?
6 A No, not really, probably in the cemetary
7 somewhere.
8 Q In this same time period we have been talking
9 about did you know a gentleman named Zillis, Z-I-L-L-I-S,
10 Bill Zillis?
11 A No, can't recall him anyway, not that name.
12 What was he supposed to be?
13 Q I'm not certain. If you don't recall, that's
14 alright. Do you recall anyone who worked with Mr.
15 Metevier in this, in his scrap or salvage operation?
16 A Not living. I guess that's what you want?
17 Q Yes, sir.
18 A No, I can't. I can't think of any names.
19 Q I suppose, just for the record, can you recall who
20 the deceased persons are who worked with him?
21 A Pardon?
22 Q Just for the record, can you recall who the
23 persons you mentioned who are deceased who worked with
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1 him?
2 A Let's see, what the heck was his name there? Old
3 Louie — no, I guess I couldn't.
4 Q Louie?
5 A I can remember Louie but I can't remember his last
6 name. It's an Italian name.
7 Q During this time period do you recall if you were
8 ever instructed to take any liquid wastes to places other
9 than the various dumps that you have mentioned?
10 A No, not scrap oils, no.
11 Q Do you recall if the Fort Edward and the Hudson
12 Falls facilities used the services of chemical waste
13 vendors, and by that I mean individuals or firms who came
14 into the facilities and took spent or scrap chemical
15 materials either for disposal or for recycling of some
16 sort?
17 A No, not back then, because everything we took we
18 dumped and back, like, the time you're talking about I
19 guess we were still burning it because we would dump a
20 load and burn it, touch it off, you know, so I don't
21 recall. I don't see how anybody could have went down to
22 get the stuff out of there to recycle. Some of this oil
23 was sent out to different places for putting on roads and
DAWN M. PICARAZZI (518) 899 - 7170
c
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1 stuff, but I don't know what kind of oil that was either,
2 but they used to come in and get it right from the plant.
3 Q Do you recall anyone who came to the Hudson Falls
4 facility, for example, to take spent or used PCBs?
5 A Oh, God, no. There was one outfit in New
6 Hampshire, a paint company, they would come in and drew
7 some oil, draw some of the drums up themselves, but I
8 can't elaborate on that either because I can't remember.
9 I just recall there was one there from New Hampshire.
10 Q That was a paint company you recall?
11 A Yeah. The name slipped my mind. I can't
12 remember it now.
13 Q How do you know that the paint company did that?
14 In other words, did you see them, for example?
15 A Just talking to the guy when he would be loading
16 up or something. I mean, you pull up, you talk to him,
17 that was about it, not knowing names or nothing else.
18 Q Can you recall any other companies or any other
19 drivers, for example, who came in and picked up things,
20 either at Hudson Falls or Fort Edward?
21 A You know, I can't. One other guy asked me about
22 him too and I said I recall talking to him but I can't
23 place a name, I don't even remember the truck. I just
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remember they picked it up.
Q I'm sorry, this was, you're speaking of the paint
company from New Hampshire or another company?
A New Hampshire paint company. Caputo ' s truck
used to come in and get the stuff out of Hudson Falls
where
Q
A
Q
A
Q
A
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A
would
he dumped it over in Hudson Falls.
What was the name?
Caputo 's Dump, over in there.
How do you spell that?
There you go again, don't ask me to spell nothing.
Okay.
That's why I only went to eighth grade.
Caputo?
Yeah, Caputo.
What did Mr. Caputo pick up, if you remember?
Well, it was just drums of oil. I remember it
go out the back door from Tony Metevier and zippo
it would go, it was the major disposing of the barrels of
oil.
Q
Did Mr
did he
A
I just want to be clear on what you said earlier.
. Caputo himself do something with this material or
, in turn
He would have a truck come in and they loaded the
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1 truck up as scrap and they take it over and dump it on
2 the pile over there. If you're working on that, that you
3 must know about that because that's what they said raised
4 heck with the Glens Falls water over there, so you must
5 be into that one. They went in and cleaned it up, so
6 somebody had to be into it.
7 Q So, the paint company from New Hampshire and Mr.
8 Caputo both came to Hudson Falls?
9 A Right.
10 Q Do you recall any such individuals or companies
11 coming to Fort Edward to do similar pick ups?
12 A I don't remember if they went to Fort Edward or
13 Hudson Falls to pick it up, the Connecticut. We were
14 back and forth and back and forth and it was quite awhile
15 ago.
16 Q I'm sorry, that was a Connecticut outfit that you
17 said?
18 A Yeah. What did I tell you before, New Hampshire?
19 Q Yes, sir, you said New Hampshire before.
20 A I'm not sure now myself whether it was New
21 Hampshire or Connecticut. You're getting me taxed back
22 too far, I can't remember what I'm talking about.i
23 Q I understand it's a very long time ago and I know
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it's difficult to sum it up, your recollection, and I
appreciate it. I really do.
A My memory ain't that, quite up to what it used to
be. It's pretty hard to remember some of this.
Q Do you recall ever meeting or speaking with a man
named Thomas Galloway or maybe Tom Galloway?
A Not offhand I don't. What's he supposed to be?
Q He may have been a person who drove a truck, for
example.
A Oh.
Q But you don't recall any —
A No, no. I couldn't even tell you what your name
is right now. I mean, I don't remember those names.
Now, you're the one from D.C. I got the call from?
Q Yes, exactly. I'm Jack Sharman, I'm from IBM.
A And you're GE?
MR. STEFANSKI: Representative of GE.
THE WITNESS: Are you with the girl
called Rood?
MR. STEFANSKI: Yes. Rood. I work
with her.
THE WITNESS: Then there's another one,
I can't recall his name, from Boston.
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MR. STEFANSKI: That may be something
totally different from this.
THE WITNESS: He's covering Connecticut,
that is where the paint thing comes in, that paint
company.
MR. STEFANSKI: That's completely
different from what we're asking you today.
THE WITNESS: I'm getting half a dozen
phone calls in and half the time I don't know who
they are.
MR. STEFANSKI: Sure, I understand.
THE WITNESS: Well, you're not the one
I talked to down here a couple weeks ago?
MR. STEFANSKI: No.
THE WITNESS: I talked to one guy here.
He was very, as far as I was concerned,
unconcerned about it. He said, "They'll probably
never call you again." He said let them know if
you get anymore calls, let me know their name and
phone numbers and I'll advise you. I said, "I
ain't here looking for advice, I'm here to find
out what the hell is going on."
MR. STEFANSKI: That may be something
DAWN M. PICARAZZI (518) 899 - 7170
24
1 completely different than what we are talking
2 about.
3 MR. SHARMAN: Mr. Stefanski is right,
4 it's probably something completely different.
5 BY MR. SHARMAN:
6 Q Do you recall the name of these people that called
7 you a half dozen times that you referred to?
8 A I got a call from you and that girl there, she's
9 called three or four times herself, and then the other
10 one from New Hampshire, he's from Boston, but he's
11 covering for New Hampshire or something like that. I got
12 his card, but I don't have it with me.
13 (Discussion held off the record.)
14 BY MR. SHARMAN:
15 Q Mr. Mumblo, in this same time period that we have
16 been discussing, do you recall any events such as a spill
17 of chemical material that required someone from the
18 outside be qualified to come in and collect it and take
19 it off site? Do you recall such an event?
20 A Not really. Most trucks I see used to go to
21 Buffalo with it, I guess they were hauling it to Buffalo,
22 and I think a lot of it was sent down to Jersey, at least
23 this is what they say when they came in after it, it was
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1 going down there. Other than that, I wouldn't know what
2 it was or what they were getting.
3 Q I'm sorry, I may have missed a point. Which
4 trucks were going to Buffalo and down to Jersey?
5 A Outside vendors. They would be outside vendors,
6 not ours.
7 Q Do you recall the names of any of those vendors
8 that were going to Buffalo or Jersey?
9 A No. No.
10 Q Were they picking up waste material or other kinds
11 of material?
12 A Waste material in barrels. Just what it was — I
13 know a lot of it was units and, I mean, other than that,
14 I don't know.
15 Q When you say units, you mean —
16 A Capacitors, right.
17 Q In addition to the bad capacitors do you recall if
18 those trucks also took barrels of liquid material?
19 A I wouldn't know that. No, all I could see were
20 they were barrels.
21 Q Do you recall a structure or an area at the Fort
22 Edward facility called the oil house?
23 A Yep.
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1 Q What was or is the oil house?
2 A Pardon?
3 Q What was the oil house or is the oil house?
4 A Well, that was just outside the boiler room down
5 there. That is the Fort Edward side and they had all
6 kinds of oil in there. I wouldn't know what it was,
7 barrels of oil.
8 Q Do you recall if that was waste oil or new oil?
9 A I think most of that was good oil. I think that
10 was good.
11 Q Do you recall a barrel storage area near the oil
12 house?
13 A Yeah, yeah.
14 Q In this time period we have been talking about
15 from '64 to '74 you recall that?
16 A Well, they had that there as long as I know of.
17 mean, they always had an oil storage down there like
18 that.
19 Q And did they also always have a barrel storage
20 area outside the oil house?
21 A Oh, yeah.
22 Q I know this is a difficult question, but during
23 the time that we have been talking about can you recall
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the approximate number of barrels in that yard or area?
A Oh, no, that would be impossible because there
were an awful lot of them around. I mean, it would be
pretty hard to even say there's so many barrels out there
if you're looking at it. There were a lot of barrels
there.
Q Was it more than a hundred, for example?
A I would say so, probably at times, yeah.
Q If you recall, more than five hundred?
A Well, I'd have to know what five hundred barrels
looked like together. No, I couldn't say on that.
It's like asking how many peanuts in a can.
Q Did you and your colleagues in transportation also
ship virgin or new chemicals back and forth between the
facilities? Do you recall that?
A No, not really. Usually we were hauling back and
forth to Pittsfield. My main job then was hauling these
big housings and I didn't get into the production part of
it too much.
Q Do you recall the name of anyone at Fort Edward
who would have been or who was Mr. Metevier's equivalent
at Fort Edward, in other words, someone who was in charge
of scrap disposition?
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1 A Well, he kind of covered both plants because we
2 used to pick up a lot of stuff and bring it up there and
3 he would take care of it there.
4 Q Do you remember who took Mr. Metevier's place
5 after he ceased his employment?
6 A No, that kind of took place — Ray O'Donnellv
7 worked with him a lot. You asked me who worked with him?
8 Q Yes, sir.
9 A Ray O'Donnell worked in there for years. Louie
10 Rudlow was the other one I was trying to think of, he was
11 in there for years. They worked with him for years in
12 there, but they're both gone now. By the way, have you
13 talked to Ed Barnham yet?
14 Q Yes, sir.
15 A You have, okay.
16 Q Do you know Mr. Barnham?
17 A I worked for him for pretty much all the time I
18 was here, him and Jack Doyle. They were supervisors
19 here. Bruce Harvey, does he still work here?
20 MR. STEFANSKI: I don't know.
21 BY MR. SHARMAN:
22 Q Did Mr. Harvey work with Mr. Metevier?
23 A He worked over there in the salvage area, not for
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1 Metevier. He was upstairs and would load the truck that
2 was going to Buffalo, that area, he was the one that
3 would load the barrels on the truck.
4 Q He loaded barrels at Hudson Falls?
5 A At Hudson Falls, yeah, scrap units and stuff, I
6 told you they went out toward Buffalo way. Bruce Harvey<».
7 worked quite awhile there in that job.
8 Q Do you know where Mr. Harvey is today?
9 A I haven't got the foggiest. That's why I asked if
10 he was still here or not. I didn't know if you contacted
11 him or not. He was kind of a young guy back then, he
12 would probably remember a lot more than I would. I don't
13 know if he's still working here or not.
14 Q Do you recall if GE employees ever visited either
15 the paint company that you mentioned which took PCBs or
16 Mr. Caputo's facilities or operations?
17 A I have no idea on that.
18 Q When you and your colleagues took wastes to these
19 dumps that you described did you keep records or
20 paperwork of any sort on the materials taken?
21 A No. No, we didn't have no idea what was what.
22 Q Do you recognize the term trichloroethylene? I
23 may have asked you that earlier, I'm sorry.
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A Yeah, I think you did, and I said it sounds
familiar but I couldn't elaborate on it.
Q Okay. Do you know what a degreaser does?
A Pardon?
Q
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Do you know what a degreaser does?
A degreaser?
Yes, sir.
Yes.
Q What does a degreaser do?
A It degreases the units. Is that what you're
talking about? Yeah.
Q In the time period that we have been talking about
do you remember if the degreasers that you just referred
to produced waste or spent material?
A Why, yeah, you would have your waste, waste oil,
that would go through it, but I don't know. It was
gathered anyway and put into barrels and such, but I
don't know, I couldn't say where it went.
Q You don't know if you or your collegues took those
barrels anywhere?
A No, I wouldn't know. Barrel of oil, barrel of
paint, you know, how do you know?
Q Were the barrels that you and your colleagues
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1 picked up marked in any fashion at all that you remember?
2 A Some were marked but I don't remember them. I
3 don't remember them, but some were marked, I remember
4 that.
5 Q Do you recall their color or any similar
6 identification?
7 A Most barrels were black, if that's what you're
8 referring to, the barrels and most of them were black.
9 Some were blue, but it usually put some kind of stencil
10 on the side of them, but I just don't see them, I mean,
11 it don't register what it was.
12 Q During this time period do you recall if Fort
13 Edward or Hudson Falls facilities purchased empty
14 barrels?
15 A Oh, yeah. Yeah, they used to buy empty barrels.
16 I remember a truck used to come in with them and they
17 would load them right up. Sometimes we would get stuck
18 unloading them, you don't forget those, but most of them
19 were open-topped barrels and that's what they used to
20 throw all the old capacitors in, the old ones.
21 Q Do you recall the name of the company that
22 supplied these empty barrels?
23 A No, I wouldn't know.
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Q Do you remember if those barrels were new or
reconditioned barrels or both?
A Well, I'd have to say both, because I have seen
both and most of them barrels come in up to 9-2 and they
were the ones that were shipped back to Buffalo with the
capacitors in them, that was the main purpose of them
barrels.
Q
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What is 9-2?
Pardon?
Q What is 9-2?
A That was the building number, 9-2.
Q At Hudson Falls?
A Yeah, Hudson Falls. Don't look for the building,
that ain't there either.
Q How were barrels of waste material gotten from the
loading dock onto the trucks?
A With a fork truck, that's what Bruce Harvey did,
was load.
Q Do you recall ever being assisted in that loading
process by people who were not General Electric
employees, that is outside people?
A No, I don't remember them, no.
Q Do you ever recall, again in this same time
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1 period, meeting with or speaking with anybody named Dale
2 Hough, H-O-U-G-H?
3 A No, I don't think so.
4 Q Did the traffic department at this time only have
5 intraplant duties or did you and your colleagues have to
6 go other places as well?
7 A Yeah, we'd go other places. We would deliver,
8 like, finished products that would be going somewhere, we
9 would deliver them. I'd go to, like, Pennsylvania, New
10 Jersey, Ohio. I know we had some trips to Indiana,
11 different places like that, they were few and far in
12 between. The main runs we had, other than intraplant,
13 would be, like, going to Schenectady or Massachusetts.
14 Q And what kind of transportation or what materials
15 were involved in those kinds of runs?
16 A Well, like I tell you, my driving to Pittsfield
17 was the big housings they used to make and we used to
18 have a production run where they would haul cans and
19 units and stuff like that back and forth, but they were
20 all in a loaded trailer box so you would just pick up the
21 trailer and move it, you know.
22 Q Do you remember if you or any of your colleagues
23 took scrap or wast£ materials to another General Electric
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1 facility for subsequent disposition?
2 A No, not that I know of, not that it couldn't
3 happen, but I don't know of any.
4 Q If you remember, how did the three outside
5 entities that you mentioned, that is the paint company
6 from New Hampshire, Mr. Caputo, and the trucks that went
7 to Buffalo and Jersey, how did they know to come to GE
8 and make a pickup?
9 A Oh, I wouldn't have no idea. I went down —
10 that went up in the upper end, I worked the lower end.
11 Q Do you recall ever being present when those trucks
12 that went, for example, to Buffalo or Jersey were being
13 loaded?
14 A Oh, yeah, like I say, over at 9-2 dock, because I
15 used to haul in and out of there and a lot of times I'd
16 have to wait for them to get out of the way so I could
17 get in, things like that. They were tractor trailers.
18 Q Do you recall seeing any documents change hands in
19 those transactions?
20 A No, I would not see that.
21 Q Have you ever heard of an outfit called Triple
22 Cities Barrel Company or maybe Tri-Cities Barrel?
23 A' Not that I recall.
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1 Q Do you recall meeting or speaking with a man named
2 Gary Warner?
3 A No. Like I told you, my memory on names is very
4 limited.
5 Q What about an entity called Solvent Savers, have
6 you ever heard of Solvent Savers?
7 A No.
8 Q Have you ever been to a place called Lincklaen,
9 New York?
10 A No. Lincklaen?
11 Q I have been asking you questions about your
12 colleagues, can you tell me who some of your colleagues
13 were in the traffic department during this time period?
14 A Okay. At that time I was working for Ed Barnham
15 and then there was Ock Bunker, then we had Ed Porter, Len
16 Benson, Herb Myers, and myself, Archie Mumblo, and let's
17 see, in that period of time we also had another fellow,
18 Ernie Benson, and who else? Charlie Gordon. We had the
19 mechanics there, it was Charlie Lafoy and Bob
20 Littlefield, let's see, just can't think of the other's
21 names. How soon we forget.
22 Q Was Mr. Porter a driver also?
23 A He was a driver, right. '
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1 Q What was Mr. Len Benson's job?
2 A He was a driver. They're all drivers.
3 Q Among people who are still living who do you
4 believe would have the most extensive knowledge about the
5 disposition of liquid scrap materials or liquid wastes?
6 A Well, I think you talked to the main man already
7 and that would have been Ed Barnham. Last time I talked
8 to Ed he still kind of remembered pretty well and, like I
9 say, Bruce Harvey, he's the one that unloaded the
10 trailers and come to think about the others, it kind of
11 leaves me lost because most of them ain't here no more.
12 Q Do you recall whose responsibility it was to get
13 the drums to the docks prior to the time that you picked
14 them up?
15 A No, I wouldn't really know because each department
16 had their own problem, you know. Like Mickey Rosati, he
17 had that for quite awhile over here, and, like, Building
18 1 would send the stuff out on the dock, he had shipping,
19 you probably already know that. I feel stupid double
20 talking here, you know.
21 Q That's alright, just your best recollection is
22 fine.
23 A One thing about it, when I had my problems, it was
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either Ed Barnham that got them or Jack Doyle. So, I
mean, they were the two foremen.
Q Mr. Mumblo, I appreciate your time this afternoon.
I have no further questions at this time.
MR. STEFANSKI: I don't have any.
(Whereupon, the Examination BeforeV
Trial of ARCHIE MUMBLO was concluded.)
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STATE OF NEW YORK )
SS;
COUNTY OF
I, ARCHIE MUMBLO , HAVE READ the foregoing record
of my testimony taken at the time and place noted hereof,
and I do hereby acknowledge it to be a true and correct
transcript of same.
ARCHIE MUMBLO
Sworn to before me this
_day of , 1991
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STATE OF NEW YORK
COUNTY OF SARATOGA
I, DAWN M. PICARAZZI, a Shorthand
Reporter and Notary Public in and for the State of
New York, do hereby certify that the foregoing is
a true and accurate transcription, to the best of
my ability, of the stenographic notes and as taken
by me of the aforesaid proceeding.
DAWN M. PICARAZZI
DAWN M. PICARAZZI (518) 899 - 7170
