Document x12YKdx2mYMe5nwXbO7DBZpMJ
Monsanto
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E.PNOM 'NAME A LOCATION! M. Potter - General Offices - B2NK
OAt* VN/tCT
TO :
August\29, 1973 AROCLOR TANK CARS
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W. B. Papageorge - BlNA
H. S. Bergen - B2SL
W. R. Corey
- B2SL
T. L. Gossage - B2SL
A. E. Leisy
- 1740
C. \ Paton
- B2SC
J. R.j Sayage - B2SL
B. R.l Williams - 1740
c. B.1 Williams - B1MC
On July 2, you wrote requesting information on procedures we follow to assure that the tank cars we have in PCB service are not used for any other product by anyone.
I am attaching to your copy a pencilled note from Bailey Williams and a memo from J. C. Smith indicating that the PCS fleet is carefully controlled and is used for nothing
but the Aroclor service.
You are familiar with and have a copy of the labelling
.
procedure used by the plant on tank cars of Aroclor.
Ibis clearly marks the cars as Aroclor cars. The personnel
are instructed repeatedly on the control of PCB cars so
that they are only in PCB service. In addition, they
have very specific instructions on the procedures for
washing cars to prevent contamination of the environment.
Also, a washed car is never put into any other service
until it has been adequately rinsed with biphenyl to assure
that there is no detectable residual PCB's in the car.
Here in the General Offices Mr. Williams' group follows the movement of each loaded car in the fleet from the
time it leaves the plant until it arrives at the customer's location. They follow the empty car after it is released by the customer until it arrives at our plant. They would therefore detect any movement of the car to an unauthorized location.
From the time the car enters the customer's plant until
the time he releases it it is not under Monsanto's control. During this period I cannot assure you that the customer could not use it for some other purpose. I am sure in my own mind that this will not happen because they are aware of their responsibility and we have a hold-harmless
agreement. I am sure, therefore, that they would control the cars within their plant location.
With that exception I am convinced that our controls are stringent and adequate to assure that wa_do not use the cars for any purpose other than PCB's Ana always have them under the best possible control.j /
BMP/er Attachments
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E. M. Potter HONS 028688