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LAW OiFFIiCIES SHOOK,HARDY&BAcON Pµi818/u1-SS/I ONE HJdJSASLITY'PLACE OT/ER~E5: WILLT THE%14GYM SH9MSC bCIXIP.,11^ ATE'WJOOS 1200 MAINISTiAEET OVEF4HOPMK WW&~5 /~P/WI~/E0.9MPHCWOMG PR'JFE5901NL MISSOUAl164105-2118. KANSFS CI'M WRPoM114Y/9 . 190UGVNGHNIiW1E (016) 474-6550 ~owi. E~ ~ March 16, 1993 N1QR 11 1993 FEDERAL EXPRESS Ms. Clare C. Purcell Philip Morris Management Corp. 412;01 Commerce Road,, Door 17 Richmond, Virginia 23234 Dear. Clare: Prop~ 65'.: We have some additional prelliminary input concerning Section 131 of the Emergency Planning and Community Right-to-Know Act (also known as Title III)I of the. Superfund Amendments and Reauthorization Act.(SARA)' of 1986 (IPublic Law 99-499) requires EPA to establish an inventory of toxic chemical emissions from certain facilities. Certain facilities must report to the U.S. Environmental Protection Agency routine and. accidental releases of toxic chemicals to the. environment. The reporting requirement applies to owners and operators of facilities that have 10 or more full-time employees, that are in Standard Industrial Classification (SIC) codes 20 through 39 (i.e., manufacturing facilities) and that manufacture (including importing) , process or otherwise use a listed toxic'chemical in excess of specified.threshold quantities. These. reports are compiled into a, database known as the Toxic Release Inventory (TRI). The 1987-1989 report'year records were searched for names and locations of California industrial facilities emitting chemicals that also appear on California's 'Proposition 65' Liist,as of1990~. Figure 1 shows approximate locations (centroid of zip code zone) of several of these facilities throughout the state of'California, for'report

SFNJOIi.HARDY&$E,OON Ms. Clare C'.. Purcell March 16, 19,93. Page 2 years 1987-1989. Figure 2 shows a San Francisco Bay Area closeup of the same locations. Table 1 is the complete listing of the facility records retrieved from TRI 1i987-1989. This represents companies in Caliifornia who reported to EPA, the routine or accidental emission of chemicals that also appear on the 'Proposition 65' list of chemicals. Table 2 is a complete listingiof'ALL substances appearing on both of these two lists, TRI and Proposition 6,5y as of 19,90(source is Chemical List ofLists,. Officee of Hazardous Materials Data Management, California Office of Environmental Protection, 19'90. Some common follows: Prop 65 Carcinogen Acetaldehyde Acrylamide Acrylonitrile Aniline Asbestos Benzene Bienz o ( ai) pyrene Carbon tetrachloride Chliordane Chloroform sources of Prop 65 chemicals are listed as Sources adhesives, cosmetics, hobbies, combustion outdoor air, drinking;water furnishings, apparel, outdoor air, drinking water hobbies buildiing materials (e.g., ceilings, roofing, material, pipe. wrapping), brake linings, drinking water gasoline, paints, drinking water, outdoor air combustion,, garages, outdoor air, drinking water cleaners,, waxes, furnishings, apparel, solvents, drinking water pesticides,, drinking water outdoor air, drinkiing,water; chlorine bleach, chlorine scouring powder

SHOOKHAR.UY&BACON Ms. Clare C. Purcell March 16, 19,93'. Page 3 p-Dichlorobenzene Methylene chloride Formaldehyde Polychlorinated biphenyls T'richloroethylene Urethane Vinyl chloride moth crystals, air fresheners, toilet deodorizers, drinking water cleaners, painting supplies,.hobbies, solvents, drinking water plywoods, particle boards, insulation, carpetingiadhesives appliances, drinking water, power supplies4 solvents, drinking,: water,, outdbor air, cosme!tics,, secretarial aids building materials furnishings, apparel, outdbor air,, drinking water,automobile interiors. We may have other, additional information. Sincerel , Leo .'D eyer LPD/tks Enclosures cc:, Denise: F. Keane, Esq. (:w/encl.) Dr. RobertA. Pages (:w/enc.L..)i 110701989 ~ N 0 .J ~ ~ ~ N CD N