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Wilmington* Delaware 19898 January 7* 1971
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Raft lour latter of December 17 1970,
As w, 3, Ilnst has indicated, vary few atataa have aat up water pollution regulations, The regulations that have bean passed are concerned primarily with tfea concentration cf toxic metals in effluents. Texas nas passed a regulation
limiting mercury to 3 ppb in effluents* and Illinois hss proposed
a regulation limiting mercury to 3.5 ppb in offIntacta (this la below the ambient level of about 3 ppb found in Illinois waters}.
The federal Government is currently gathering information on the amount and types of materials likely to find thair way into Anariean watara. A questionnaire hat baan sent to 19*000 plants asking for information on the amount of fourteen different heavy metals* phenols* amines* chlorinated biphenyls ad cyandiea peasant to easts affluents. Baaed on this survey and other pertinent information* it is expected that aoaa sort of water pollution legislation will be introduced to toe 92nd Congress.
Although it is difficult to predict exactly what type of legislation will be passed* acme general guidelines sen be set down based on what we now knows
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X, Mercury - Currant regulations and public opinion dictate that m do not ns* ammwry in our products is any tor*, unless it it absolutely necessary, Mercury it currently used only it preservative, X would suggest that less toxic preservatives be used if and when they become available.
XX, lead - Xt appears that
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United to a maximum of XjT le.a.*d, "Th*is essentitcialllyy says that
m should avoid lead-containing pigments since they tat give
as much as 85* lead baaed on solldeiji the finished product,
Small amounts of lead as driers would not be affected if tbs
maximum stays at l, Sines that* is always tbs possibility
of aors stringent regulations, use of lead-free drier* should
bo considered first to avoid possible reformulation at * later
data.
m. XV,
Cadmium and Arsenic - .Along with mercury and lead, these two natala have aone under increasing pressure for regulation. I believe we use cadmium and arsenic only in pigments. It
slble, pigments containing these natal* should be avoided
rfuture formulations.
Other heavy metals - Xafematlsn has been requested by the federal government on the use of Antimony, Barium, Beryllium, Bismuth, Chromium, Cobalt, Copper, Kenganese, nickel, Selenium, thallium and Sine In waste effluents. Me do not use many of the more tonic metals (Beryllium, Thallium, etc.). zt is doubtful that regulations will appear to limit the use of products containing the am commonly used metals (Cobalt, Copper, Manganese, Pick#!, etc.). However, it is possible that we will have to limit the concentration of many of the metals in our
waste effluents during the jftfWllfltflfft of our products.
V, Phenols The drinking water standard for "phenols* is O.&Vhg/l in potable water. This limit was set because of the undesirable taste often resulting from chlorination of water containing extremely low concentrations of phenols, A letter from the Department of Semlth, Sdueation end Melfare state#, "It (the Standard) is intended to Include all those compounds capable of yielding distasteful products whin chlorinated i intended to include all ring hydroxylated aromatic
Thus, the standard would not apply to phenols used in epoxy resin manufacture (bisphenol A, bisphesol F, ate.) since they arc not readily chlorinated. As far as X know, tha only material we uaa that la affected by thie standard would ba tho preserv ative, pentachlorophenol.
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Xu uoeing from organic to octer-tweed finiehe*, m Mm to oo awore of too veto* pollution problem that might to X her* tried to outline too typee Of ootoriolo t Oelioeo bk mit likely to to Important is future uoter pollute legislation,
Oy following piuing nator lotion yoyte wM materiaia leoet likely to esuee mater pollution problems* 1 feel we eexi eubetaufcially reduce total pollution control problem by
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