vvEPA
            United States
            Environmental Protection
            Agency
             Office of Pollution
             Prevention and Toxics
             TS-792A
February 1992
EPA's 33/50 Program
Second Progress Report

Reducing Risks Through Voluntary Action
                                       Printed on Recycled Paper

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                                 SUMMARY
       EPA's 33/50 Program is a year old, and one year closer to its goals of
reducing toxic chemical pollution through voluntary, direct action by industry.
Company participation in the 33/50 Program has increased more than three-fold
since the issuance of the Program's first Progress Report in July of 1991. As of
February 1992, 734 companies had written to EPA expressing commitments to
reduce voluntarily their releases and transfers of toxic chemicals, up from 236
company commitments in July. The actual reductions pledged by these
companies also has risen significantly during the past six months, from 201 million
pounds in July to 304 million pounds in February.

       The 33/50 Program seeks to reduce the generation of high-priority industrial
toxic wastes by 50% by 1995, with an interim goal of a 33% reduction by 1992.
Marking its first anniversary, this report examines progress in achieving the
Program's ambitious goals and reviews the activities conducted over the past
year to bring about this progress. In addition, the report provides an overview of
the universe of toxic chemical releases and transfers addressed by the 33/50
Program. And finally, anniversaries also offer a time for looking forward, to  assess
the challenges — and potential pitfalls — ahead in forging a voluntary pollution
prevention partnership among governments at all levels, communities, and
industries.
            Number of
           Commitments
    800-
            Jul.  Feb.
            •91   '92
1995 Pledged
 Reductions
                                        _ 800
 Jul.  Feb.
 •91  '92
       Rgure 1.  Progress of the 33/50 Program.
17 CHEMICALS OF THE 33/50
	PROGRAM	

       BENZENE
CADMIUM & COMPOUNDS
 CARBON TETRACHLORIDE
    CHLOROFORM
CHROMIUM & COMPOUNDS
      CYANIDES
  LEAD & COMPOUNDS
MERCURY & COMPOUNDS
  METHYL ETHYL KETONE
 METHYL ISOBUTYL KETONE
  METHYLENE CHLORIDE
  NICKEL & COMPOUNDS
  TETRACHLOROETHYLENE
       TOLUENE
   TRICHLOROETHANE
  TRICHLOROETHYLENE
       XYLENES

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               THE 33/50 PROGRAM: A ONE-YEAR PROGRESS REPORT

             REDUCING TOXIC RISKS THROUGH VOLUNTARY DIRECT ACTION
THE 33/50 PROGRAM

      EPA's 33/50 Program is a year old — one year closer to its goals for reducing toxic
chemical pollution through voluntary, direct action by industry. The 33/50 Program seeks
to reduce the generation of 17 high-priority industrial toxic wastes by 50% by 1995, with an
interim goal of a 33% reduction by 1992. The Program was formally announced in February
1991, and the first 33/50 Progress Report was released  in July 1991.  This report examines the
progress of the 33/50 Program at its first anniversary, and looks ahead to the progress —
and potential pitfalls — of the next few years.
      GOALS AND APPROACH

      The 33/50 Program is an ambitious EPA initiative designed to reduce toxic waste
generation from industrial sources quickly and with an unprecedented degree of flexibility.
Industry participation in the 33/50 Program is voluntary, the Program aims to demonstrate
that voluntary reduction programs can augment the Agency's traditional regulatory
approach by achieving targeted reductions more quickly than would regulations alone.
      The 33/50 Program derives its name
from the overall goals — an interim goal of a
33% reduction by 1992 with an ultimate goal
of a 50% reduction by 1995 in environmental
releases and off-site transfers of 17 high-
priority toxic chemicals, using 1988 as a
baseline year. In 1988, almost 6,000
companies reported to the Toxic Release
Inventory (TRI) that 1.4 billion pounds of the
33/50 chemicals were either released to the
environment or transferred off-site to waste
management facilities.  The aim of the 33/50
Program is to  reduce this 1.4 billion pounds of
wastes by at least 50%, or 700 million pounds,
by 1995.

      The 33/50 Program is part of a broad
EPA thrust to encourage pollution prevention
as the best means of reducing risk to human
health and the environment. Pollution
prevention moves the focus  on toxic
Industry Embracing Voluntary
Reduction Goals

The 33/50 Program's challenge to
American industry to voluntarily reduce
toxic chemical releases is being
embraced by a wide spectrum of
companies, ranging from Fortune 500
firms such as AT&T and Du Pont to small
and midsized companies like Magee
Carpet of Bloomsburg, Pennsylvania and
Ultra Forge of Cuyahoga Falls, Ohio. For
a description of the reduction programs
being implemented by these and other
companies, see "33/50 Activities - What
Industry Is Doing." A complete list of all
companies participating in the 33/50
Program is included in Appendix A.
                                         -1-

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 chemicals upstream, away from managing wastes after they have been generated,
 towards an approach that avoids the generation of wastes wherever possible through
 toxics use reduction, equipment and process changes, improved handling and
 operations, and so on.  Although the goal of EPA's 33/50 Program is expressed as a 50%
 reduction in TRI environmental releases and transfers by 1995, a goal chosen to allow for
 progress to be measured with readily available data, the central theme of the program is
 to promote continuous environmental improvement through pollution prevention.
 Therefore,  EPA urges companies to use pollution prevention as the preferred means of
 achieving  their reductions. Moreover, EPA hopes that by emphasizing pollution
 prevention, companies will instill a new management ethic that will achieve even greater
 environmental benefits, expanding their reduction efforts beyond the chemicals, targets,
 and time frames established for the 33/50 Program.

      The  goal of the 33/50 Program includes the reduction of both direct releases to the
 environment (1,134 million pounds) and off-site transfers of waste materials to sewage
 treatment plants or commercial waste management facilities (297 million pounds). While it
 is important to understand the difference between direct releases to the environment and
 off-site transfers of wastes, both are included in our measures of progress because the
 central theme of the 33/50 Program is to promote pollution prevention. Thus, EPA has
 included all waste materials, regardless of whether they are released or transferred, to
 encourage industry to consider all waste generation when reviewing their pollution
 prevention options.
       33/50 AND THE TOXICS RELEASE INVENTORY

       The chemicals included in the 33/50 Program are 17 high-priority toxic chemicals
that are among the more than 320 chemicals reported annually to the Toxics Release
Inventory (TRI).  These chemicals were selected for
attention by the 33/50 Program not only because of toxicity
concerns, but because they are all commonly used in high
volumes by industry, and they all have high potential for
reduction through pollution prevention.
      In 1988, the baseline year for the 33/50 Program,
these 17 chemicals accounted for 22% of the total
quantities reported to TRI (1.4 out of 6.4 billion pounds).
Another reason for targeting these particular chemicals in
the 33/50 Program is that they are handled by a significant
portion of the facilities required to report under TRI. More
than 12,000 facilities associated with almost 6,000
companies reported releasing and/or transferring one or
more of the 33/50 chemicals in  1988.  This represents 57% of
the more than 21,000 TRI facilities that reported in  1988.
(See Figure 2.)
EPA'S 33/50 PROGRAM:
THE 17 CHEMICALS TARGETED FOR
REDUCTIONS
BENZENE
CADMIUM & COMPOUNDS
CARBON TETRACHLORIDE
CHLOROFORM
CHROMIUM & COMPOUNDS
CYANIDES
LEAD & COMPOUNDS
MERCURY & COMPOUNDS
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
METHYLENE CHLORIDE
NICKEL & COMPOUNDS
TETRACHLOROETHYLENE
TOLUENE
TRICHLOROETHANE
TRICHLOROETHYLENE
XYLENES
                                     -2-

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                Number of
                Chemicals
        Associated with 33/50 Chemicals
Releases
  and
Transfers
Number of
 Facilities
   Associated with All Other TRI Chemicals
Figure 2. Total TRI and 33/50 Program Universe, 1988.


      Pollution prevention benefits resulting from the Program could potentially extend to
a substantial portion of the entire TRI universe, since companies are encouraged to
consider reduction commitments beyond the goals of the 33/50 Program.


      IMPLEMENTING THE 33/50 PROGRAM: EPA'S APPROACH

      To achieve 33/50's goals, EPA developed a program consisting of four major
elements:  outreach to companies to encourage commitments; public recognition of
companies for their commitments, pollution prevention efforts, and achievements;
technical assistance to help companies overcome barriers and achieve commitments
through pollution prevention practices; and evaluation of the effectiveness of both
industry and government efforts in a voluntary- cooperative program.

      Outreach: Perhaps the major challenge for the 33/50 Program is reaching out to
the thousands of companies and over ten thousand facilities that can play a role in
reducing toxic wastes. Letters to the heads of companies can be effective, but they are
also easily overlooked by busy corporate executives with many priorities. There is also
history and culture to contend with. The 33/50 Program is building a new type of
relationship between government, communities and industry. Many companies, used to
dealing with EPA or the public only in an adversarial relationship, are hesitant to embrace
an EPA-sponsored voluntary program, no matter how sensible it might seem on paper. In
order to make the most of our communications, EPA employed the following strategy:
                                         -3-

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       A first round of intensive contacts with the "Top 600"' companies. This entailed not
 only letters from the Administrator to company heads, but a series of about a dozen
 meetings with top executives from different industrial manufacturing sectors: chemicals;
 transportation related; machinery and electrical equipment; iron, steel, and primary
 metals; pulp and  paper; petroleum refining; Pharmaceuticals; wood and metal furniture;
 rubber and. related products; and metal finishings and coatings. Trade associations, such
 as the Chemical Manufacturers Association, were instrumental in helping arrange these
 sessions. Program communications with individual company managers have also
 occurred through meetings with EPA Regional Administrators and staff and regional
 workshops with State program participation. Face to face contacts were invaluable in
 identifying issues,  addressing questions, and providing assurances as to how the Program
 would and would not operate.

       A second round of contacts involved not only letters to the heads of thousands of
 additional companies, but many direct meetings between EPA's Regional Offices and
 industries within their States. As many as a thousand additional companies will be
 contacted as new companies report to TRI for the first time, or as corporate affiliations
 change through sales, purchases, restructuring, and the like.

       Continuing our outreach efforts, 33/50 Program staff have addressed conferences,
 provided information to the press, written articles, and circulated information about the
 Program wherever opportunities presented themselves. In this way, we can reach not only
 industry, but environmental groups, community organizations, organized labor, and the
 general public. The 33/50 Program is also independently reported on in the annual
 National Report released by the TRI Program. In addition, EPA routinely contacts
 companies that have not yet joined 33/50 to make certain they are aware of the Program,
 and to solicit their participation.

      Public Recognition:  EPA's release in  1989 of the first year of TRI data greatly
 increased public awareness about toxic pollution and industrial awareness of the depth of
 community concern about toxic wastes. The 33/50 Program provides industry a means of
 having its progress towards pollution prevention recognized through a formal EPA program
 that receives broad public attention. At the same time,   ^^^^^^^^^^^^^^^^
 the commitment information submitted to 33/50 provides
the public with access to information beyond that
supplied in TRI reports.
                                                         Want to find out more
      In order to foster public awareness of industry's
reduction efforts, the 33/50 Program publicizes company
participation through Program publications, press releases,
and in speeches and other routine federal and State
communications.  Companies submitting reduction
commitments receive a formal certificate of participation      call/ visit'or writ@i
from EPA.  This year's Administrator's Awards Program,
                                                         More About 33/50...
about EPA's 33/50
Program? See the back
page of this report for
what's available, who to
contact, and where to
1  Nearly 600 companies accounted for more than 75% of the total 1988 releases/transfers of 33/50 chemicals.
                                     -4-

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highlighting outstanding achievements in pollution prevention, is being coordinated with
the 33/50 Program. Next year, 33/50 envisions having its own awards program to
recognize company efforts in reducing wastes, including those that go beyond the goals
set by 33/50, creating effective pollution prevention programs, communicating with and
involving the public, and in other areas warranting special recognition. In addition, we are
developing a compilation of 33/50 Company Progress Reports which will highlight effective
company approaches to identifying pollution prevention opportunities and follow them
through implementation.

      Technical Assistance and Technology Transfer. The 33/50 Program is working closely
with EPA's Office of Research and Development to help companies implement pollution
prevention through information collection, coordination, and exchange. To date, there
are five components to the 33/50 Program's technology assistance and transfer efforts:

      1) The 33/50 Program is conducting a series of workshops across the country with
         industry to exchange information on pollution prevention theory and practices
         to aid in achieving reductions of the 17 chemicals.

      2) EPA is expanding its Pollution Prevention Information Exchange System, a free
         computer bulletin board associated with EPA's Pollution Prevention Information
         Clearinghouse.  The Bulletin Board and Clearinghouse contain technical, policy,
         programmatic, legislative, and financial information on pollution prevention, in
         general, and the 33/50 Program, in particular.

      3) EPA is preparing a series of bibliographic reports on pollution prevention and
         recycling techniques applicable to the major industries which release the 17
         targeted chemicals.

      4) EPA is publishing an expanded pollution prevention resource guide. Pollution
         Prevention Resources and Training Opportunities in 1992, which identifies key
         pollution prevention documents, industry specific guidance manuals, fact
         sheets, and videos. The guide also identifies federal, state, university, and other
         pollution prevention programs across the country. For example, the guide
         contains a complete listing of State programs that offer technical assistance on
         pollution prevention and waste minimization to businesses and industry.

      5) EPA is identifying areas where new research efforts could lead to beneficial and
         readily transferable pollution prevention alternatives.  As part of this effort, EPA
         will identify successful and innovative pollution prevention practices companies
         have implemented as part of the 33/50 Program and then share this information
         with other companies and other interested parties.

      Program Evaluation: How well is the 33/50 Program working? Are reductions being
achieved through pollution prevention? Do EPA regulatory programs or other barriers
inhibit companies from making voluntary reduction commitments? Would reductions
occur anyway without 33/50? These are important questions that need to be answered in
order to determine ffthe 33/50 approach works, why it is working, and whaf it is
                                         -5-

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 accomplishing. We are examining potential regulatory obstacles to pollution prevention in
 order to identify areas where EPA can remove obstacles without undercutting statutory
 mandates or environmental progress.  Detailed company progress reports, prepared as
 part of program outreach, are focussing on incentives and obstacles to pollution
 prevention; they will allow independent validation of pollution prevention successes. A
 particular concern is documenting the extent to which reductions come about through
 true pollution prevention measures. As a result of passage of the Pollution Prevention Act
 of 1990, newTRI information on pollution prevention practices and the impact they are
 having will become available to EPA and to the public. Some companies are also
 providing additional information in their progress reports to the 33/50 Program.  This
 information will provide invaluable insights towards evaluating the effectiveness of the
 Program.


       33/50 AND OTHER FEDERAL, STATE, AND INTERNATIONAL PROGRAMS

       The 33/50 Program is only one of the many pollution prevention activities underway
 at EPA, in the States, and elsewhere. Our activities are coordinated closely with other
 programs, wherever possible, so that there is a maximum impact with a minimum of
 overlap.  Some of the cooperative efforts are described in the following paragraphs.

       Other EPA Pollution Prevention Programs: Recent reorganizations at EPA have
 brought the 33/50 Program and the Pollution Prevention Division institutionally closer as a
 means of coordinating activities. EPA's new Office of Pollution Prevention and Toxics
 provides a central location for the Agency's pollution prevention activities. The 33/50
 Program is becoming a key source of information for the Pollution Prevention Information
 Clearinghouse. We work closely with the early reductions program established by the
 Clean Air Act Amendments of 1990 to coordinate efforts to reduce industrial discharges of
 toxic chemicals prior to legislatively mandated schedules. The 33/50 Program is being
 looked to as a possible model as the Agency conducts a broad review of major regulatory
 activities, with the aim of further promoting pollution prevention. For example, the
 voluntary, direct action approach is proving successful not only in 33/50, but in  EPA's
 energy conservation/pollution prevention initiative. The Green Lights Program.

       Other Federal Programs: 33/50 also is being considered as a potential model for a
 broad Federal Sector initiative, focussing on federal government facilities as generators of
 toxic releases. It would build on existing pollution prevention activities by setting ambitious
 reduction targets and creating a formal tracking system to measure progress. A large
 number of the Government Owned Contractor Operated facilities of the Department of
 Defense and the Department of  Energy are operated by companies already committed
 to 33/50.  We will continue our discussions with these Departments in order to make
 maximum use of the 33/50 approach for these facilities as well as Government Owned and
 Operated facilities.

      EPA Regional Programs: EPA's Regional Offices play an important role in
communicating Program goals to industry, States, and the community. Major activities
include seeking company participation through individual company contacts and
participation in regional and state meetings, and coordinating the implementation of the
                                     -6-

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Program with State pollution prevention and toxic use reduction initiatives. Through these
activities, EPA seeks to minimize the potential for conflict with State programs and to
develop cooperative efforts with industry. States, and the community.

      EPA Region VII, with the participation of Region V, has taken a very innovative
approach to the 33/60 Program.  Working with the TRI list of the top 100 counties nationally
for releases and transfers of the targeted 33/50 chemicals, Region VII selected the five
counties and three metropolitan  areas in Its region that ranked highest (see Map A). By
the end of 1991, the Regions, in cooperation with State agency and department officials,
met with business and civic leaders and company representatives in each of these
counties and metropolitan areas to encourage voluntary, community-wide reduction
goals for all reported TRI chemical releases and transfers, They asked these communities
for a separate focus on the 17 targeted 33/50 chemicals. A key distinction from the
national 33/50 Program is that the geographic-oriented program targets groups of facilities
in selected  areas, as opposed to parent companies.

      Through this effort in Region VII, a group of representatives from 26 companies and
McConnell  Air Force Base has announced its plan to reduce Sedgwick County TRI wastes
by more than 90% by 1995.  This is a reduction of 142 million pounds compared to the 1988
total of 151  million pounds in the county. The group also plans to reduce all TRI wastes by
31% (47 million pounds) by 1992.  Other community-wide meetings have resulted in the
formation of groups or steering committees to obtain similar commitments to achieve the
33/50 Program goals.
                  Nebraska
                                           Iowa
|D*» Molnn
                                  Linioln
                    Kansas
                               Lawr*nc»^0fK«nMa City
                                           M*tro Arc*
                               IWIchiU
                                             Missouri
Map A. Geographic Voluntary Emissions Reduction Program, Communities in EPA Regions VII and V.
                                         -7-

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       States: Pollution prevention has been a priority in many States for some time. The
 33/50 Program has been a direct benefactor and is building onto the foundation
 established by these State initiatives. Many States have taken a strong interest in the 33/50
 Program and are using it to their advantage to foster pollution prevention. States like
 California, Florida, Maryland, and North Carolina have written to companies encouraging
 participation in the Program. Other States such as Louisiana and New York are tracking
 reductions in the 33/50 Program chemicals as part of their State Toxics Programs.  New York
 has already reported a sizable reduction, from 69 million pounds in  1988 to 36 million
 pounds in 1990, which will no doubt increase as the 33/50 Program  builds momentum.

       Yet other States like Colorado, Delaware, and  Minnesota have their own voluntary
 reduction initiatives either in process or in place. For instance, Minnesota has launched
 the Minnesota 50 Project which sets a statewide 50% reduction goal for 1995 for the same
 chemicals included in 33/50. Minnesota 50 will reach many individual facilities in the State
 that would not otherwise be contacted by EPA, thus expanding the scope and potential
 impact of the voluntary reductions approach.

       Several States (such as Connecticut, Massachusetts, Pennsylvania, and Rhode
 Island) are holding pollution prevention and technical assistance conferences that include
 discussions of 33/50 and disseminate information about the technologies that can be
 applied to reduce or eliminate the use of 33/50 and other hazardous chemicals. Activities
 such as the Northeast Waste Management Officials Association's distribution of a brochure
 describing the 33/50 Program and the technical assistance available in New England
 States also aid the 33/50 Program. Overall, Federal/State partnerships are forming to foster
 source reduction not only for the 33/50 chemicals, but for other hazardous chemicals as
 well, promoting a pollution prevention ethic within the respective States.

      International: The 33/50 Program is seen as a possible model for voluntary reduction
 efforts in the international arena. EPA has been working with Environment Canada, the
 International Joint Commission, and  others on a Pollution Prevention Initiative for the Great
 Lakes that incorporates 33/50 goals for reducing toxic discharges to these international
waterways. Pollution prevention initiatives have been included in the Mexico-United States
Plan to protect the border environment.  For example, American corporations will be
encouraged to make commitments to the Program for their facilities across the border.
                                     -8-

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INDUSTRY'S PARTICIPATION IN THE 33/50 PROGRAM

      Nearly 6,000 companies — operating more than 12,000 facilities nationwide —
submitted TRI reports to EPA for the year 1988 on one or more of the 33/50 chemicals.  This
is more than  half of all facilities that reported to TRI. All told, these companies reported 1.4
billion pounds of releases and transfers of the seventeen chemicals in 1988, the baseline
year for the 33/50 Program. All 5,747 companies have been invited to participate in the
33/50 Program (see Table 1).

      The bulk of releases and transfersof these chemicals reported to TRI came from
relatively few companies.  Five hundred and fifty-five of the 5,747 companies accounted
for more than three quarters (1.1 billion pounds) of the total for the 33/50 chemicals. This
group of companies (often referred to as the "Top 600" companies) were sent letters by
EPA in February 1991 inviting them to join the 33/50 Program. As reported in the first
Progress Report, more than one-third (236 companies) had responded with a commitment
to the program by July  1991. Since then 39 more of these companies have joined the
TABLE 1. 33/50 PROGRAM COMMITMENT STATUS OVERVIEW
                                    "TOP 600"
                                  AS REPORTED
                                     IN JULY
                TOP 600"
               AS REPORTED
                 IN THIS
                                PROGRESS REPORT    PROGRESS REPORT
              REMAINING
              COMPANIES
             CONTACTED IN
              JULY, 1991
                                             TOTAL
NUMBERS OF COMPANIES

   Companies Contacted by EPA                555

   Companies Committing To 33/50 Program         236

   Companies Providing Quantifiable Commitments     140
                   555

                   275

                   228
                5,192


                  459


                  334
          5,747


           734


           562
TRI RELEASE/TRANSFER QUANTITIES
FOR THE 17 33/50 CHEMICALS
(in millions of pounds, 1988)

   Total for 33/50 Chemicals

   Total from Companies
   Committing to 33/50 Program

   Total from Companies
   Providing Quantifiable Commitments
1,050
 389
1,050
                   640
 514
                  381
                  104
85
          1,431
           744
599
REDUCTION COMMITMENT QUANTITIES,
1988 T01995 (in millions of pounds)

   Amount of Reductions in TRI Release
   and Transfers Pledged by Companies
   Providing Quantifiable Commitments
 201
 260
44
304
                                            -9-

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 Program. To date, almost half of the "Top 600' — 275 companies — have voluntarily
 submitted reduction commitments to the 33/50 Program. These 275 companies represent
 45% (640 million out of 1.4 billion pounds) of the wastes targeted by the 33/50 Program for
 reductions.

      In July 1991, EPA sent letters to the remaining 5,192 companies that reported use of
 33/50 chemicals to TRI in 1988, asking them to respond by November 1991. Of this second
 group of companies, 459 have thus far committed to participating in 33/50, accounting for
 an additional 104 million of the 1.4 billion pounds of 1988 33/50 releases and transfers. We
 recognize that this second round of companies have had less time to consider their
 participation in 33/50, and some may not have the level of resources available to many of
 the larger companies.  Nonetheless, their participation is crucial to the success of the 33/50
 Program, not only in terms of meeting our numerical goals but, in a broader sense, for fully
 promoting the pollution prevention culture throughout the industrial sector.

      Across the two groups of companies, a total of 734 companies have indicated their
 willingness to reduce voluntarily their releases and transfers of the 33/50 chemicals a more
 than three fold increase since July (see Figure 3). All are listed in Appendix A.  Together
 these 734 committed companies released  and/or transferred 744 million pounds of the
 total 1.4 billion pounds associated with the 17 chemicals.

      Of the 734 companies that have committed to the Program, 562 (77%) have
 responded with readily quantifiable reduction goals: 228 of these were from the "Top 600"
 and 334 from the second group.  These goals lend themselves to numerical calculations of
 how much of its releases and transfers a company plans to reduce by 1995. By looking at
 these 562 companies with quantifiable commitments, we are able to determine the level
 of commitment that has been made as of this progress report. Of the 599 million pounds of
 releases and transfers of 33/50 chemicals associated with these companies, firms have
 committed to a reduction of 304 million pounds by  1995 (260 million pounds from the "Top
 600"; 44 million from the rest). This pledged reduction of 304 million pounds represents an
 increase of 51% from the 201 million pounds commited to as of July, 1991, and 43% of the
 national goal of 700 million pounds (see Figure 4). Although individual company
 commitments vary considerably in amount, reduction pledges are averaging 50% per firm
 (304 million pounds of pledged reductions out of the 599 million pounds of 33/50 chemical
 releases and transfers reported by this group in 1988).

      The 304 million pound national reduction commitment actually represents a lower
 bound in assessing the 33/50 Program's progress to date. This estimate is based only on a
 portion of the 734 company commitments received to date — the 562 commitments that
 can be quantified on a company-wide basis.  Additional reductions have been pledged
 by companies on a chemical-,  medium-, or facility-specific basis, requiring further analysis
 by EPA before their contributions toward the national goals can be accurately assessed.
Other companies that have committed to the 33/50 Program have yet to specify their
numerical goals.  In some instances, these companies have indicated that they need to
analyze their industrial processes before determining the level of reduction they can
achieve.
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  BOO
  600
  4CO
  200
    Number of Companies
        First Progress
          Report
             'Top 600'
             Companies
 Second Progress
    Report

• All other
  Compsnlss
                    1,600
                                           1,400
                        Millions of pound*
Tolsl 33/60
  In 1988
60% Reduction
 Qosl by 1996
 Reduction
Commitments
E22 First Progress
   Report
      I Second Progress
       Report
Figure 3. Companies Committing to the 33/50
Program.
                  Figure 4. Releases and Transfers of 33/50 Chemicals.
      On the other hand, a number of companies have submitted quite detailed
reduction commitments. One example is the commitment provided by LTV Steel
Company, planning an overall 80% reduction by 1995 that is broken down by individual
chemical (see Table 2). In another example, Honda of America supplied EPA with specific
details of the planning needed to achieve their reduction goals (see Table 3).

      The 33/50 Program's national goal of 700 million pounds reduction by 1995 is based
upon achieving a 50% reduction in the 1.4 billion pounds of the 33/50 chemicals that were
released and/or transferred in 1988. One way to achieve this goal is for every one of the
5,747 companies to commit to the Program with a 50% reduction in their releases and
transfers. Realistically, however, some companies will choose not to participate in the
Program and of those that do, some will make commitments amounting to less than a  50%
reduction. Therefore, if the overall goal of a 700 million pound reduction is to be achieved,
many companies will  need to make commitments to reducing their releases and transfers
of the 17 chemicals by greater than 50% and, indeed, some already have,

      While there is much to  be excited about with the level of voluntary commitment we
are seeing by companies responding to the 33/50 Program, we clearly have a long way to
go if we are to meet our national goal.  EPA has planned follow-up activities involving
those companies who did not respond or who responded expressing an interest in, but not
a commitment to, the 33/50 Program.
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 TABLE 2. SAMPLE COMPANY REDUCTION GOALS (LTV STEEL)
                                  1988
                         % REDUCTION
                     1995
 SOLVENTS
     Methytene Chloride
     Methyl Isobutyl Keytone
     Tetrachloroethylene
     1,1,1-Trichloroethane
      Subtotal

 COKE PLANT CHEMICALS
     Benzene
     Toluene
     Xylene
      Subtotal

 METAL COMPOUNDS
     Chromium Compounds
     Cyanide Compounds
     Nickel Compounds
      Subtotal

 GRAND TOTAL
 100,895
    170
 313,200
 600,000
1,014,265
1,282,698
  28,200
 150,000
1,460,898
 318,712
   9,256
  11,743
 339,711

2,814,874
100
 0
100
100
100
 67
 50
 84
 0
 0
 0
 0

 80
    0
   170
    0
    0
   170
142,400
 9,420
 75,710
227,530
318,712
 9,256
 11,743
339,711

567,411
       INDUSTRY FEEDBACK ON THE 33/50 PROGRAM

       Why are companies voluntarily agreeing to cut back their toxic discharges? Many
of the companies committing to 33/50 reductions have indicated their reasons for doing
so. Among the most common are:

       •  Companies are already pursuing reduction efforts and welcome the opportunity
          for formal recognition of their efforts.

       •  33/50 goals and Total Quality Management principles correspond well to
          voluntary industry efforts such as The Responsible Care Program organized by
          the Chemical Manufacturers Association.

       •  Pollution prevention deserves a higher priority both in industry and at EPA and
          can best be promoted through a voluntary program such as 33/50.

       •  Companies recognize their responsibilities as corporate citizens and welcome
          the focus that 33/50 provides to reduce releases beyond regulatory
          requirements.

       At the same time, it is important for the success of a program such as 33/50 to
understand the reasons why companies have elected nof to participate. The reasons
most often cited by companies that have been hesitant to join 33/50 are:
                                       -12-

-------
      •  The vagaries of the business cycle or of company operations make predictions
         about future waste generation next to impossible.

      •  Companies are already devoting maximum possible resources to deal with
         existing environmental requirements and cannot adopt additional
         environmental goals.

      •  Concern over possible conflicts between 33/50 endeavors and goals established
         by other federal or state environmental programs, such as reduction goals
         established under the Clean Air Act Amendments of 1990.
TABLE 3. SAMPLE COMPANY REDUCTION PLAN (HONDA OF AMERICA).
ALTERNATE
PROCESS TECHNOLOGY REQUIRED TECHNOLOGY GENERAL SCHEDULE ESTIMATED
CONFIRMED COST
•92 '93 '94 '95 '96
Weld surface
cleaning
Part
degreasing
Spec change
Paint system
cleaning
Paint process
modification
Paint system
cleaning
solvent
Paint process
modification
Bumper
pro-treatment
Waterbome
technology
Alternate cleaning process to
replace 1 ,1 ,1 Trictoroethane
without harming quality or creating
associate safety concerns
Vapor degreaser - driveshaft
cold cleaner - valve bodies
eliminate 12/91
Painting spec change
Addition of air/solvent
purge equipment
Modification of coating
specifications
Replacement of existing cleaning
solvent with alternative
Reformulation of coatings to
reduce usage of ITP chemicals
Replacement of current 1,1,1
Trichloroethane system with
alternative system (may also
reguire bumper substrate
modification and painting
system modification)
Further replacement of sotvent-
bome coatings with waterborne
No
No
Yes
No
Yes
No
No
No
In
process
I I I ' I I I I I
MY94 MY95 MY96
• *M
Selection/testing of alternative processes
• *•
Development of alternative process
Ongoing trials for '92 model year
• kB

Ongoing trials for '92 model year

• 	 Westing and evaluation
Impact analysis • — »•
^^ 	 , 	 , 	 , 	 ,_ M 	
• 	 ^Testing and evaluation
coatings online

Research and development of att. technology
- plasma cleaning system
- substrate modification with water borne
pre-treatment system
- substrate modification/poser wash pro-treat
alternate coating system

Implementation goal - end of 1996
Unknown
$150.000-
$220,000
To be determined
$31 ,000 capital
$40,000 - $50,000
/yr expense
$265,000-
$1,750,000tyr
expense
Unknown
$24 million
$75 - $200 million
           | Target date for implementation
                                        -13-

-------
       •  Constraints imposed by customers, such as military specifications for the types of
         chemicals and processes required to fulfill government contracts.

       •  Mandatory federal, state, and local permitting processes are extremely
         cumbersome, and the company is unwilling to pursue permit modifications that
         may be needed to implement 33/50 Program objectives.

       EPA is examining these obstacles to learn where there is opportunity to make more
companies interested in participating in 33/50. As the Program has stressed from its outset,
33/50 is not intended as a substitute for EPA's regulatory programs, and the Agency
cannot relax regulatory oversight or enforcement as a means of encouraging
participation. However, 33/50 is working carefully in concert with EPA's other programs,
and with other federal agencies such as the Department of Defense, to insure maximum
coordination and flexibility.

       Some companies also wrote indicating that, as a holding company, partnership, or
other financial arrangement with limited oversight of day-to-day operations or diverse
business units, they were not the appropriate entity to decide environmental policy. The
33/50 Program is in the process of redirecting requests for participation to the individual
business units at these companies.


       33/50 ACTIVITIES — WHAT INDUSTRY IS DOING

      A number of companies that have committed to the 33/50 Program have provided
EPA with reports of their progress in meeting their reduction targets. A few of the "Top 600"
company reports are summarized below. (Note: Information is this section was taken
directly from company reports and has not been independently verified.)

       •  AT&T (New York, New York) reports that the corporation has already achieved a
         66% reduction of its 33/50 chemicals, from 6.4 million pounds of releases and
         transfers in 1988, to 2.1 million in 1990. The reductions were achieved through a
         combination of techniques, chiefly chemical substitutions and process
         modifications, with an emphasis on pollution prevention. Some of the reductions
         were also due to decreased production levels at several of the company's
         plants.  AT&T has set additional reduction targets for all its facilities worldwide.
        These include: (a) 95% elimination of toxic chemical air emissions (of all TRI
         chemicals) by 1995, striving for 100% elimination by 2000; (b) 100% phaseout of
        CFC's by 1994; and (c) reducing total manufacturing  process waste 25% by 1994
        (see Figure 5).

      • BF GOODRICH (Akron, Ohio) reports a 32% reduction in 33/50 chemicals
        between 1988 and 1990, and anticipates exceeding its reduction target of 50%
        by 1995.
                                     -14-

-------
       Millions of Pounds
          88
89
90
91       92       93

Actual  	1	Goals
94
95
Figure 5. AT&T Reduction Goals (or All Plants and Achievements to Date.


      •  DOW CHEMICAL'S (Midland, Michigan) participation in the 33/50 Program
         includes not only the seventeen 33/50 chemicals, but all 121 TRI chemicals
         reported by company facilities, targeting overall reductions of 50% by 1995.
         Dow has reduced  overall TRI quantities from 23.2 to 16.2 million pounds from 1988
         to 1990, a reduction of 30%.

      •  DU PONT (Wilmington, Delaware) has created an internal corporate data base
         to manage information from 80 facilities in order to track progress towards its
         33/50 goal of 50% reduction by 1995, as well as several other corporate goals:
         60% reduction of air toxics from 1987 to 1993; 90% reduction of carcinogenic air
         emissions by 2000;  eliminate toxic discharges to land by 2000.  Between 1988 and
         1990, Du Pont has reduced TRI totals of the 33/50 chemicals from 20,2 to 17.7
         million pounds, a reduction of 12%.

      •  ILLINOIS TOOL WORKS (Glenview, Illinois), which operates  130 facilities in 20 states,
         has reduced its use of 33/50 chemicals by 33% between 1988 and 1990, with a
         consequent reduction in waste generation,

      •  REPUBLIC ENGINEERED STEELS (Massillon, Ohio) provided technical update
         information on  its activities, including: installation of steam cleaning equipment
         to replace the  use of trichloroethane, thus eliminating 40,000 pounds of releases;
         modifying capture hoods and Increasing baghouse (filter) efficiencies to
                                         -15-

-------
         capture greater amounts of metallic dusts, which the company hopes to be
         able to reuse; creating a task force to explore means of eliminating landfilling of
         electric arc furnace slag.

      These large companies are not alone in making reduction commitments and in
keeping the 33/50 Program (and the public) up to date. Among the smaller companies
that have reported on their progress are:

      •  MAGEE CARPET (Magee Industrial Enterprises of Bloomsburg, Pennsylvania) has
         eliminated their use of trichloroethane, thereby eliminating 340,000 pounds of
         releases of this chemical.

      •  PINES TRAILER LIMITED PARTNERSHIP (Chicago, Illinois) has achieved reductions
         from 1988 to 1990 for the two 33/50 chemicals it reports: 48% reduction for
         xylene, and a 37% reduction for methyl isobutyl ketone, and anticipates overall
         reductions of at least 50% by 1995.

      •  ULTRA FORGE (Cuyahoga  Falls, Ohio) has been replacing its solvent-based vapor
         degreasers with spray wash equipment, thereby eliminating more than 80,000
         pounds of releases of trichloroethane and tetrachloroethylene; the company
         anticipates total elimination of these two chemicals in 1992.
                                    -16-

-------
RELEASE/TRANSFER PROFILE FOR 33/50 COMMITMENT COMPANIES

      At this time in the 33/50 Program's development, the information submitted to EPA
by companies participating in the Program is not detailed enough to enable us to analyze
fully the nature or impact of the reduction commitments themselves. We can determine,
as reported above, that the quantifiable commitments made by 562 companies to date
amount to a nationwide pledge of 304 million pounds of reduced toxic chemical releases
and transfers by 1995. But we are not yet in a position to determine the impacts of these
reduction commitments on a geographic-, medium-, chemical-, or industry-specific basis.

      By and large, companies have set reduction goals to be achieved on a company-
wide basis, in many instances spanning operations at facilities dispersed throughout the
nation and in a variety of industrial sectors. The details of how and where these reductions
actually will be achieved are still being flushed out at the plant or production process
level.  Until more companies have completed their internal reduction plans and
communicated them to EPA, further analyses of the impacts of the reduction
commitments must be put on hold.

      While we cannot yet analyze the impacts of companies' reduction commitments,
we can describe the TRI release/transfer profiles of the companies which have committed
to the 33/50 Program. This section of the report presents a series of analyses comparing
the releases and offsite transfers of 33/50 chemicals by the 734 companies committing to
the 33/50 Program to the total 33/50 release/transfer universe in the 1988 baseline year.

      The analyses identify the potential impacts of companies' reduction commitments.
Readers are cautioned that the reduction efforts eventually implemented by companies
may result in a distribution of release/transfer reductions that differs markedly from the
distribution of the companies' overall releases and transfers.  For example, a company with
identical facilities in Oregon and Tennessee could achieve a 40% company-wide
reduction goal in a variety of ways: by reducing releases at each facility by 40%; by
reducing by 60% percent at one facility and only 20% at the other; or, achieve its
corporate goal entirely by concentrating reduction efforts to achieve an 80% reduction at
one facility, leaving releases and transfers at the other facility unchanged for the time
being. Accordingly, the release/transfer profiles presented below are not intended to
represent the reductions that will be observed in companies' future TRI reports.

      As indicated in Table 1 above, facilities associated with the 734 companies making
33/50 Program commitments reported 744 million pounds of 33/50 chemical releases and
transfers in the Program's baseline year. Although the participating companies overall
account for approximately one half of the 1.4 billion pounds of 33/50 releases and transfers
in 1988, the analyses of these committed companies' releases and transfers presented
below do not reflect an even distribution from sector to sector.
                                        -17-

-------
       STATE/EPA REGIONAL DISTRIBUTIONS

       The state-by-state and EPA Regional distributions of company participation in the
 33/50 Program and associated releases and transfers of the seventeen 33/50 chemicals
 are shown in Tables 4 and 5. The number of 33/50 companies with their headquarters
 located in each state or reporting jurisdiction differs considerably, ranging from zero in
 Alaska and the Virgin Islands to 498 in Illinois (see Table 4).  The company participation rate
 also varies ranging from a level of no participation (Montana. Nevada, New Mexico, North
 Dakota, South Dakota, Vermont, Wyoming, District of Columbia, and Puerto Rico) to a high
 of 33% in Hawaii and 23% in both Delaware and Oregon.

      The five states with the largest amounts of 33/50 releases and transfers in 1988 were
 Ohio, Texas, Indiana, Pennsylvania, and Michigan (see Table 5).  Each accounted for over
 85 million pounds and together they represented almost one-third of the 33/50 national
 total. In looking at the releases and transfers of facilities belonging to the committed
 companies, we see that the top five states were the same, but in a slightly different order:
 Texas, Pennsylvania, Indiana, Michigan, and Ohio. (Note that releases and  transfers are
 assigned to the state in which facilities are located, not the state in which their parent
 company headquarters are located.)  The percentages varied among the  states from less
 than 5% of the total represented by committed companies to greater than  90%. However,
 it should be noted that the extremes were associated with states with the smallest number
 of TRI facilities, so that one company has a large impact on such a percentage
 calculation. The percentages among the top five states were closer, ranging from 49% of
 the total represented by facilities of committed companies in Ohio to 58% in Pennsylvania.


      MEDIA/DESTINATION DISTRIBUTION

      Companies must report to TRI the amounts of a chemical that are released on site
 and/or transferred off site. Releases consist of air emissions (fugitive and point source),
 surface water discharges, on-site releases to land, and discharges to underground
 injection wells. Transfers are either to Publicly Owned Treatment Works (POTWs) or to off-
 site treatment, storage, and disposal facilities. While the releases of a chemical to a
 particular medium are clear, TRI data do not show the medium or geographic location to
 which transfers are eventually released or the quantities of those releases.

      For example, a chemical that is transferred to a POTW may end up being
 discharged to surface water or sent in sewage sludge to a landfill (or released to the air
 through vaporization).  The chemical wastes sent off-site to a treatment, storage, and
 disposal facility end up at a different geographic location and may be treated and
 reduced in amount by methods varying widely from chemical to chemical, and facility to
 facility. These differences should be kept in mind when looking at the amount of releases
 to the various media.

      The distribution of releases and transfers by media/transfer destination for
committed companies and other 33/50 companies can be seen in Figure 6  and Table 6.
As shown, the 33/50 releases and transfers of committed companies differ significantly on
a percentage basis between media and transfer destination.  For example,  in 1988 the 33/
                                     -18-

-------
TABLE 4. COMPANY PARTICIPATION IN 33/50 PROGRAM, BY STATE AND EPA REGION
STATE
REGION 1
Connecticut
Maine
Massachusetts
Now Hampshire
Rhode Island
Vermont
Region Total
REGION II
New Jersey
NewYoik
Puerto Rico
Virgin Islands
Region Total
REGION III
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region Total
REGION IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region Total
REGION V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region Total
REGION VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region Total
REGION VII
Iowa
Kansas
Missouri
Nebraska
Region Total
REGION VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region Total
REGION IX
Arizona
California
Hawaii
Nevada
Region Total
REGION X
Alaska
Idaho
Oregon
Washington
Region Total
OUTSIDE U.S. OWNERSHIP
TOTAL
NUMBER OF
COMPANIES
IN 33/SO UNIVERSE
(Number)

215
17
253
SO
84
10
629

325
443
24
0
792

22
8
35
332
113
13
523

73
99
101
63
35
134
63
89
568

498
197
260
116
426
224
1,721

26
31
4
44
274
379

61
37
161
28
287

49
3
6
6
21
1
86

50
460
3
6
519

0
6
60
86
152
2
5,747
NUMBER OF
COMPANIES MAKING
33/50 COMMITMENTS
(Number)

32
1
16
7
3
0
59

44
69
0
0
113

5
0
4
55
15
2
81

8
8
14
7
4
14
6
8
69

61
26
42
18
SB
32
247

4
4
0
7
35
50

4
1
15
1
21

5
0
0
0
3
0
8

4
56
1
0
61

0
1
14
10
25
0
734
NUMBER OF COMPANIES MAKING
33/50 COMMITMENTS AS PERCENT OF TOTAL
IN STATE/REGION
(Percent)

14.88
5.88
632
14.00
3.57
0.00


13.54
15.58
0.00
—


2273
0.00
1143
16.57
13.27
15.38


10.96
8.08
13.86
11.11
11.43
10.45
9.52
8.99


12.25
13.20
16.15
15.52
15.96
14.29


15.38
1290
0.00
15.91
12.77


656
2.70
9.32
3.57


10.20
000
000
0.00
14.29
0.00


BOO
12.17
33.33
0.00


—
1667
23.33
11.63

0.00
12.77







9.38





1427







15.49









12.15







14.35






13.19





7.32







9.30





11.75





16.45



-------
TABLE 5. RELEASES AND TRANSFERS OF 33/50 CHEMICALS, BY STATE AND EPA REGION, 1988
STATE
REGION I
Connecticut
Maim
Massachusetts
New Hampshire
Rhode bland
Vermont
Region total
REGION II
New Jersey
New York
Puerto Rico
Virgin Island*
Region total
REGION III
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region total
REGION IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region total
REGION V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region total
REGION VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region total
REGION VII
Iowa
Kansas
Missouri
Nebraska
Region total
REGION VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region total
REGION IX
Arizona
California
Hawaii
Nevada
Region total
REGION X
Alaska
Idaho
Oregon
Washington
Region total
TOTAL
RELEASES/TRANSFERS RELEASES/TRANSFERS RELEASES/TRANSFERS ASSOCIATED WITH
OF ALL 33/50 ASSOCIATED WITH COMPANIES COMPANIES MAKING 33/50 COMMITMENTS
CHEMICALS MAKING COMMITMENTS AS PERCENT OF STATE/REGIONAL TOTAL
(Pounds) (Pounds) (Percent)

28.761,305
5,866,262
26.469.4C3
9,144,265
6,178,734
1,502,495
77.922,464

40,145,307
70,817,814
9,695,688
1,468,960
122,177,789

3,752,990
0
9,676,045
67,644,154
38,529,040
12,794,018
152,596,247

36,758,750
17,248,263
38,148,497
30.693,456
31,009,064
61,896,442
28,152,948
40,701,783
284,609,203

71,617,104
92,013,726
84,873,345
40,118,538
96,392,100
35,164,828
420,179,641

22,582,184
23,309,971
1,890,219
17,484,903
93,665,640
158,932,917

25,246,654
13,339,907
44,085,040
9,829,564
92,601,165

6,375.774
2,856,257
798,622
1,561,978
9,089,633
953,940
21,636,204

11.867,813
63,291,813
390,357
696,020
76,248,003

336,555
1,024,902
8.526,830
14,536,710
24,424,997
1,431,178,630

11,774,886
3.904,154
14,374,124
4.772,812
1,306,084
202,386


19,168,291
42,416,031
8.810,397
0


2,235,556
0
5,435,313
50,948,249
19,988,619
8,290,712


23,258,269
6,388,575
18,920,634
13,529,034
12,886,751
25,490,977
14,766,375
15,392,654


23,843,367
50,552,011
48,372,378
30,706,931
46,978,964
11.024,548


8,644,790
17,527,678
444,873
6,193,305
52,695,978


14,473,219
7,690,789
24,898,011
6.654,764


3,231,059
2.659,345
241,436
995,370
7,386,116
676,595


7.211,582
30,603.202
187,562
34,114


13,740
871,438
5,391.129
9,449,016

743,914,193







36,334,446





70,394,719







86,898,449









130,633,269







211,478,199






85.506,624





53,716,783







15,189,921





38,036,460





15,725,323


40.94
66.55
54.30
52.19
21.14
13.47


47.75
59.89
90.87
0.00


59.57
-
56.17
58.00
51.88
64.80


63.27
37.04
49.60
44.08
41.56
41.18
52.45
37.82


33.29
54.94
56.99
7654
48.74
31.35


38.28
75.19
2354
35.42
56.26


57.33
57.65
5648
67.70


50.68
93.11
30.23
63.72
81.26
70.93


60.77
48.35
48.05
4.89


4.08
85.03
63.23
65.00

51.98







46.63





57.64







56.95









45.90







50.33






53.80





58.07







70.21





49.89





64.38


-------
    RELEASES:
         Fugitive Air
     Point Source Air
       Surface Water
               Land
        Underground
   TRANSFERS:
            POTWS
             Off-she
                            100      200      300       400      500
                                  Millions of Pounds Released/Transferred
                        600
700
              Associated with Companies Making
              Commitments to the 33/50 Program
Associated with All Other Companies
Reporting 33/50 Chemicals
Figure 6. Releases and Transfers of 33/50 Chemicals by Media/Transfer Destination, 1988.
TABLE 6. RELEASES AND TRANSFERS OF 33/50 CHEMICALS BY MEDIA/TRANSFER DESTINATION, 1988




MEDIA/TRANSFER
DESTINATION

Total Air Releases
Fugitive
Point Source
Surface Water Discharges
Land Releases
Underground Injection
Total Releases
Transfers to POTWS
Other Off-site Transfers
Total Transfers
Total Releases/Transfers


RELEASES/
TRANSFERS OF
ALL 33/50
CHEMICALS
(Pounds)
1,044,819,113
386,587,300
658,231,813
4.000,323
75,606,883
9,344,343
1.133,770,662
20,892,597
276,515,371
297,407,968
1,431,178,630


RELEASES/TRANSFERS
ASSOCIATED WITH
COMPANIES MAKING
COMMITMENTS
(Pounds)
536,933,395
189,110,023
347,823,372
3,086,128
42,493,826
7.595,544
590,108.893
14,229,849
139,575.451
153,805,300
743,914,193
RELEASES/TRANSFERS
ASSOCIATED WITH
COMPANIES MAKING
COMMITMENTS AS
PERCENT OF MEDIA/
TRANSFER TOTAL
(Percent)
51.39
48.92
52.84
77.15
56.20
81.28
52.05
68.11
50.48
51.72
51.98
                                               -21-

-------
 50 discharges to underground injection wells of facilities of committed companies
 represented 81% of all 33/50 discharges to such wells.  In contrast, the 33/50 fugitive air
 emissions of committed companies accounted for 49% of total 33/50 fugitive air emissions.


       INDUSTRY SECTOR DISTRIBUTION

       The seventeen 33/50 chemicals are used by facilities manufacturing a wide range
 of goods, from the chemicals themselves to electronic equipment, paper, plastics, food,
 and furniture. Each of the industrial sectors that are required to report to TRI (the
 manufacturing Standard Industrial Classification (SIC) codes 20 through 39) have reported
 releases and transfers of the 33/50 chemicals. The distribution of companies' 33/50
 Program participation rates across major industrial sectors are presented in Figure 7 and
 Table 7. The distribution of TRI-reported releases and transfers of 33/50 chemicals by
 facilities associated with these companies is presented in Figure 8 and Table 8.  (The
 category called "multiple" represents individual facilities that use the chemical in the
 manufacture of products in more than one of the industrial sectors listed.) The amounts of
 releases and transfers are assigned to an industry sector according to how the chemical is
 used at an individual facility, which may in some cases be different than the primary
 industrial sector for the company as a whole.

Food (20)
Tobacco (21)
Textiles (22)
Apparel (23)
Lumber (24)
Furniture (25)
Paper (26) I
Printing (27)
Phdmiralc- t3&\
Inorganic
Synthetics ~
Drugs _,
Soaps
Paints j
Organic ~
Agricultural ~
Miscellaneous
Multiple
Petroleum (29)
Plastics (30)
Leather (31)
Stone/Clay (32)
Primary Metals (33)
Fabr. Metals: (34)
Containers/Equip
Metal Services
Machinery (35)
Electrical (36)
Transportation (37)
Measure./Photo. (38)
Miscellaneous (39)
Multiple codes 20-39 ~
No codes 20-39
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0 200 400 600 800 1,000 1,200
Number of Companies
B Companies Making Commitments to the 33/50 Program El All Other Companies in 33/50 Universe
Figure 7 . Company Participation in 33/50 Program, by Industry Sector.
                                      -22-

-------
      The number of companies associated with 33/50 chemicals per industry sector
ranged from a low of six in the tobacco industry to a high of 1,001 in the fabricated metals
industry. The chemical sector had the second largest number of potential 33/50
companies with a total of 835. Together, the fabricated metals and the chemical
industries accounted for approximately one-third of all potential 33/50 companies.
(Subdivisions within these two industry sectors are shown.) The participation rate differed
from sector to sector ranging from a low of approximately 2% for the "multiple codes"
sector to 37% for drug/pharmaceutical manufacturers, a subdivision within the chemical
sector (see Figure 7 and Table 7).
TABLE 7. COMPANY PARTICIPATION IN 33/50 PROGRAM, BY INDUSTRY SECTOR
SIC
CODE INDUSTRY SECTOR
20
21
22
23
24
25
26
27
28









29
30
31
32
33
34


35
36
37
38
39


Food
Tobacco
Textiles
Apparel
Lumber
Furniture
Paper
Printing
Chemicals
Industrial Inorganic Chemicals
Plastic Materials/Synthetics
Drugs
Soaps/Cleaners
Paints
Industrial Organic Chemicals
Agricultural Chemicals
Miscellaneous Chemicals
Multiple Chemical Products
Petroleum Refining
Rubber/Plastic Products
Leather
Stone/Clay/Glass
Primary Metals
Fabricated Metals
Metal Containers/Equipment/Others
Metal Services
Machinery, except Electrical
Electrical/Electronic Equipment
Transportation Equipment
Measuring/Photographic Equipment
Miscellaneous Manufacturing
Multiple Manufacturing Products
Other (non-manufacturing)
NUMBER OF
COMPANIES
IN 33/50
UNIVERSE
(Number)
51
6
117
23
242
212
139
102
835
73
82
61
104
262
75
26
142
10
102
313
54
125
462
1,001
597
404
468
373
263
132
148
45
534
NUMBER OF
COMPANIES
MAKING 33/50
COMMITMENTS
(Number)
6
2
16
4
17
22
35
7
143
14
20
23
15
29
19
9
13
1
18
47
6
13
59
92
51
41
65
57
37
19
16
1
52
NUMBER OF
COMPANIES MAKING
33/50 COMMITMENTS
AS PERCENT OF TOTAL
(Percent)
11.76
33.33
13.68
17.39
7.02
10.38
25.18
6.86
17.13
19.18
24.39
37.70
14.42
11.07
25.33
34.62
9.15
10.00
17.65
15.02
11.11
10.40
12.77
9.19
8.54
10.15
13.89
15.28
14.07
14.39
10.81
2.22
9.74
TOTAL
5,747
734
12.77
                                         -23-

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        While the uses of 33/50 chemicals by the chemical and transportation equipment
 sectors were associated with the largest releases and transfers, the highest percentages of
 a sector's releases and transfers that were associated with committed companies came
 from the drug/pharmaceutical manufacturers and the food industry (over 81%). On the
 other hand, the printing and metal services industries had the lowest proportion (less than
 10%) of their releases and transfers associated with committed companies. (See Figure 8
 and Table 8.)
 TABLE 8. 33/50 PROGRAM RELEASES AND TRANSFERS, BY INDUSTRY SECTOR, 1988
SIC
CODE INDUSTRY SECTOR
20
21
22
23
24
25
26
27
28









29
30
31
32
33
34


35
36
37
38
39


Food
Tobacco
Textiles
Apparel
Lumber
Furniture
Paper
Printing
Chemicals
Industrial Inorganic Chemicals
Plastic Material/Synthetics
Drugs
Soaps/Cleaners
Paints
Industrial Organic Chemicals
Agricultural Chemicals
Miscellaneous Chemicals
Multiple Chemical Products
Petroleum Refining
Rubber/Plastic Products
Leather
Stone/Clay/Glass
Primary Metals
Fabricated Metals
Metal Containers/Equipment/Other
Metal Services
Machinery, except Electrical
Electrical/Electronic Equipment
Transportation Equipment
Measuring/Photographic Equipment
Miscellaneous Manufacturing
Multiple Manufacturing Products
Other (non-manufacturing)
RELEASES/
TRANSFERS OF
ALL 33/50
CHEMICALS
(Pounds)
6,966,684
262,226
31,319,873
1,051,544
20,359,743
46,114,984
82,431,820
60,187,632
271,096,114
25,171,688
27,929,058
39,462,007
1,910,691
36,129,326
42,948,898
5,407,499
11,599,140
80,537,807
37,718,098
99,349,626
11,051,613
17,280,661
133,958,316
101,269,676
78,221,021
23,048,655
49,683,360
96,525,335
153,086,367
38,183,002
28,091,881
138,934,411
6,255,664
RELEASES/TRANSFERS
RELEASES/TRANSFERS ASSOCIATED WITH
ASSOCIATED WITH COMPANIES MAKING 33/50
COMPANIES MAKING COMMITMENTS AS PERCENT
COMMITMENTS OF SECTOR TOTAL
(Pounds) (Percent)
5,649,713
0
10,569,999
308,458
7,785,785
12,323,456
50,677,929
5,603,890
190,284,148
9,954,080
21,117,580
35,690,927
694,347
20,109,698
30,645,749
3,605,472
3,976,690
64,489,605
26,102,758
35,139,571
3,655,424
8,988,425
76,618,761
24,048,780
22,013,831
2,034,949
15,038,035
54,115,545
93,756,375
29,489,127
6,402,492
86,026,076
1,329,446
81.10
—
33.75
29.33
38.24
26.72
61.48
9.31
70.19
39.54
75.61
90.44
36.34
55.66
71.35
66.68
34.28
80.07
69.20
35.37
33.08
52.01
57.20
23.75
28.14
8.83
30.27
56.06
61.24
77.23
22.79
61.92
21.25
TOTAL
1,431,178,630
743,914,193
51.98
                                      -24-

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Food 20
Tobacco 21
Textiles 22
Apparel 23
Lumber (24
Furniture 1 25
Paper (26
Printing (27
Chemicals: (28
Inorganic
Synthetics
Drugs
Soaps
Paints
Organic
Agricuttura
Miscellaneous
Multiple
Petroleum 29
Plastics 30
Leather 31
Stone/Clay 32
Primary Metals 33
Fabr. Metals: 34
Containers/Equif
Metal Service!
Machinery (35
Electrical (36
Transportation (37
Measure./Photo. (38
Miscellaneous (39
Multiple codes 20-3<
No codes 20-3!
B Associate
33/50 Pro

.
.
.
I
P
•ran 	 1
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inv • • '

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I:


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mHIIIIIBIIIIIfllBBg':'-':'''''- :-:':'••••••••- •;•:•:•:-;•:•:•:••
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i
0 50 100 150 200 250 300
Millions of Pounds Released/Transferred
d with Companies Making Commitments to the 03 Associated with All Other Companies Reporting 33/50
gram Chemicals
Figure 8. Releases and Transfers of 33/50 Chemicals, by Industry Sector, 1988.
      CHEMICAL DISTRIBUTION

      Analysis of TRI-reported releases and transfers on a chemical-specific basis also
reveals varying levels of "coverage" by companies currently participating in the 33/50
Program, ranging from a high of nearly 93% for mercury and its compounds to a low of just
over 40% for chromium and related compounds (see Figure 9 and Table 9). Ubiquitous
chemicals with larger volumes of TRI releases and transfers, such as toluene (almost twice
as large as any of the others) and trichloroethane, have lower portions of their total
volume associated with companies participating in the 33/50 Program, highlighting the
need to continue program outreach efforts aimed at bringing the numerous smaller users
and manufacturers into the Program.
                                         -25-

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                     Benzene
      Cadmium and compounds
           Carbon tetrachloride
                   Chloroform
      Chromium and compounds
                     Cyanides
          Lead and compounds
        Mercury and compounds
            Methyl ethyl ketone
          Methyl isobutyl ketone
             Methylene chloride
         Nickel and compounds
           Tetrachloroethylene
                     Toluene
               Trichloroethane
              Trichloroethylene
                     Xylenes
                                        50        100       150        200       250
                                                 Millions of Pound* Released/Transferred
                                                    300
                                          350
         I Associated with Companies Making Commitments to
          the 33/50 Program
                   I Associated with All Other Companies Reporting 33/50
                    Chemicals
 Figure 9. Releases and Transfers of 33/50 Chemicals, by Chemical, 1988.
 TABLE 9. RELEASES AND TRANSFERS OF 33/50 CHEMICALS, BY CHEMICAL, 1988
          CHEMICAL
   RELEASES/
TRANSFERS OF
   ALL 33/50
  CHEMICALS
    (Pounds)
RELEASES/TRANSFERS
  ASSOCIATED WITH
 COMPANIES MAKING
    COMMITMENTS
       (Pounds)
  RELEASES/TRANSFERS
    ASSOCIATED WITH
 COMPANIES MAKING 33/50
COMMITMENTS AS PERCENT
 OF TOTAL FOR CHEMICAL
         (Percent)
 Benzene
 Cadmium and compounds
 Carbon tetrachloride
 Chloroform
 Chromium and compounds
 Cyanides
 Lead and compounds
 Mercury and compounds
 Methyl ethyl ketone
 Methyl isobutyl ketone
 Methylene chloride
 Nickel and compounds
 Tetrachloroethylene
 Toluene
Trichloroethane
Trichloroethylene
Xylenes

TOTAL
   32,240,533
    1,928,819
    5,029,696
   26,882,013
   68,793,835
   11,787,893
   60,774,417
     318,587
  161,203,453
   44,511,920
  155,059,038
   19,289,876
   37,760,219
  349,388,787
  194,137,772
   57,816,129
  204,255,643

1,431,178,630
      23,541,686
        940,346
      4,519,278
      23,708,139
      29,144,969
      9,273,102
      36,188,398
        295,835
      90,182,171
      27,427,490
      95,512,513
      11,388,249
      21.313.079
     157,864.903
      82.928,321
      25,092,853
     104,592,861

     743,914,193
           73.02
           48.75
           89.85
           88.19
           42.37
           78.67
           59.55
           92.86
           55.94
           61.62
           61.60
           59.04
           56.44
           45.18
           42.72
           43.40
           51.21

           51.98
                                                    -26-

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33/50 AFTER ONE YEAR — MAKING PROGRESS?

      After one year of outreach efforts to solicit company commitments, almost half of
the nation's largest releasers of 33/50 chemical wastes have submitted reduction
commitments (275 out of 555 companies). Over 450 companies from the ranks of the 5,192
companies with samller releases and tranfers of 33/50 chemicals have signed on, although
they have had less time to formally consider their participation in the Program.

      Is the 33/50 glass half empty or half full? If all 734 companies that have committed
to the Program were to completely eliminate their TRI discharges of the seventeen 33/50
chemicals by 1995, they would have reduced the nation's waste load by more than 700
million pounds, meeting the 33/50 Program goal of a 50% reduction.

      In fact, most of these companies have agreed to commitments of about 50% by
1995, with the result that the 33/50 Program still has to make substantial inroads on the
generation of toxic pollution if it is to meet its reduction goals. On the encouraging  side is
the early indication that many companies have indicated that they expect to exceed —
often by large amounts — their reduction targets; this has already occurred at AT&T (see
What Industry Is Doing, above). On the other hand, there still remain the hundreds of large
generators, and thousands of smaller ones, who, for whatever reasons, have not yet
elected to participate. Our efforts to bring them on board will continue as the 33/50
Program matures.

33/50: WHAT LIES AHEAD?

      The 33/50 Program has grown substantially in its first year, expanding from its initial
face-to-face meetings with a few dozen companies and targeted contacts with the
"Top 600* companies with the largest reports of 33/50 wastes, to broad outreach —
orchestrated through EPA's ten Regional offices and involving several State agencies as
well — to the thousands of companies who can assist us in achieving the Program's goals.

      In the next few years, as we approach the 1995 target date, the focus of 33/50 will
shift from outreach to evaluation and recognition.  How much reduction has been
achieved? What has been the impact of pollution prevention practices?  One of the keys
for answering these and other questions will be new information provided by the Pollution
Prevention Act of 1990. The Act calls for additional data collection in TRI which will address
the role of pollution prevention, recycling, and treatment in achieving reductions. The Act
will also require all companies — not just 33/50 participants — to project their next two
years' waste generation for the TRI chemicals, a source of data that will allow an early
assessment of expected waste generation trends.  The new pollution prevention data will
first be reported to EPA and the States in July, 1992, covering the 1991 reporting year.

      With this new information and the details that companies are voluntarily providing
to the 33/50 Program, future Progress Reports and other communications will provide a
realistic assessment of how successfully U.S. industry is able to apply pollution prevention to
the reduction of releases and transfers of the seventeen 33/50 chemicals in the context of
a voluntary reduction effort.
                                        -27-

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-28-

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                                 APPENDIX A

                  Companies Committing to the 33/50 Program
                                (February,  1992)
This appendix provides a list of all companies that have indicated to EPA in writing as of
February, 1992, that they intend to participate in the 33/50 Program. In many cases,
subsidiary companies responded in addition to or in place of parent companies. In such
instances, subsidiaries are listed indented underneath their parent company. All subsidiary
companies are also listed in their own alphabetic order, with their parent company
indicated in parentheses. State abbreviations are provided only for parent companies,
indicating the location of their headquarters operations.

-------
 APPENDIX A—Companies Making Commitment* to the 33/50 Program (February, 1992)
 COMPANY                              STATE

 3M CO                                   MN
 ABC COMPOUNDING COMPANY INC             GA
 A B CHANCE CO                            MO
 A J INDUSTRIES INC                         CA
  SARGENT-FLETCHER
 A T CROSS CO                              R|
 A T R WIRE & CABLE CO                      KY
 A W CHESTERTON CO                       MA
 AACCO FOUNDRY INC                       CA
 ABBOTT LABORATORIES                       IL
 ACC HOLDINGS CORP                       PA
  ARISTECH CHEMICAL
 ACME ENGINEERING & MANUFACTURING          OK
 ACME SPONGE & CHAMOIS CO                 FL
 ACME STEEL CO                             IL
 ACTION PLATING CORP                       FL
 ADAC PLASTICS                            Ml
 ADVANCED CIRCUIT TECHNOLOGY              NH
 ADVANCED FRICTION  MATERIALS               Ml
 AERO METAL FINISHING INC                    MO
 AEROFIL TECHNOLOGY INC                    MO
 AEROFORGE CORP                          IN
 AEROTHRUST CORP                         FL
 AEROVOX (COOPER INDUSTRIES)
 AIR PRODUCTS AND CHEMICALS                PA
 AKRON PAINT & VARNISH INC                   OH
 AKZO CHEMICALS (AMERICA AKZO)
 ALABAMA RIVER PULP
 (PARSONS & WHITTEMORE ENTERPRISES)
 ALADDIN INDUSTRIES  INC                      TN
 ALDAN RUBBER CO                          PA
 ALL METAL STAMPINGS INC                    Wl
 ALLEGHENY LUDLUM CORP                    PA
 ALLEN-BRADLEY CO                         OK
 ALLIED MINERAL PRODUCTS INC                OH
 ALLIED-SIGNAL INC                          NJ
 ALUMINUM COMPANY OF AMERICA               PA
 AMERICA AKZO INC                          NY
 AKZO CHEMICALS
 AMERICAN & EFIRD (RUDDICK CORP)
 AMERICAN CAST IRON PIPE CO                 AL
 AMERICAN CYANAMID CO                      NJ
 AMERICAN ELECTRIC COMPONENTS             IN
 AMERICAN PETROFINA HOLDING                TX
 FINA OIL AND CHEMICAL
AMERICAN SAFETY RAZOR (JORDAN GROUP)
AMERICAN STANDARD (KELSO ASI PARTNERS)
AMERICAN SYNTHETIC RUBBER CORP            KY
 COMPANY                              STATE

 AMERICAN TELEPHONE & TELEGRAPH           NY
 AMERICAN TOY AND FURNITURE CO             Wl
 AMERON INC                              CA
 AMITY LEATHER PRODUCTS CO                Wl
 AMOCO CORP                              IL
 AMSTED INDUSTRIES INC                      IL
 AMWAY CORP                              Ml
 ANABOLIC INC                             CA
 ANDERSEN CORP                           MN
 ANDERSON SCREW PRODUCTS INC             NY
 ANHEUSER-BUSCH CO                       MO
 ANOMATIC CORP                           OH
 ARCADIAN CORP                           TN
 ARCHER CO (RJR NABISCO HOLDINGS)
 ARCO PRODUCTS (ATLANTIC RICHFIELD)
 ARISTECH CHEMICAL (ACC HOLDINGS)
 ARKWIN INDUSTRIES INC                     NY
 ARMCO STEEL CO LP                        OH
 ARMORED KNIGHT CORP                      IL
 CFC INTERNATIONAL
 ARMSTRONG WORLD INDUSTRIES              PA
 ARROW ENGINEERING INC                    GA
 ARROW INTERNATIONAL INC                  PA
 ARTISTIC POLISHING & PLATING                CA
 ASARCO INC                               NY
 ASEA BROWN BOVERI INC                     CT
 ASHLAND OIL INC                           KY
 ASSET MANAGEMENT ASSOCIATES              NY
 CHILDERS PRODUCT CO
 ASTRAL INDUSTRIES INC                       IN
 ATLANTIC RICHFIELD CO                      CA
 ARCO PRODUCTS
 ATOCHEM (ELF AQUITAINE)
 AUBURN FOUNDRY INC                        IN
 AUTO-SWAGE PRODUCTS INC                  CT
 AUTOMATA INC                             VA
 AUTOMATIC PLATING OF BRIDGEPORT           CT
 AUTOMATIC WELDING & MANUFACTURING         OH
AUTOMATION PLATING CORP                  CA
AVESTA SANDVIK TUBE AB                    FL
AVON NORTH AMERICA INC                    Ml
 CADILLAC RUBBER & PLASTIC
AVONDALE INDUSTRIES INC                    LA
 B F GOODRICH CO                           OH
 B L DOWNEY CO                             IL
BAIRNCO CORP                            FL
 REINHOLD
                                           -30-

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APPENDIX A—Companto Making Commitment* to the 33/50 Program (February, 1992)
COMPANY

BAKER HUGHES INC
 BGA INTERNATIONAL
BALDOR ELECTRIC CO
BALL SOCKET MANUFACTURING
BARNETT VARNISH (OAK PARTNERS)
BARNHARDT MANUFACTURING CO
BASF CORP
BASS PLATING CO
BASSETT FURNITURE INDUSTRIES
BATH IRON WORKS
BAXTER INTERNATIONAL INC
BAYER USA INC
BAYOU STEEL
BELL & HOWELL CO
BEMIS COMPANY INC
BENJAMIN MOORE & CO
BENNETT MANUFACTURING CO
BENSON MANUFACTURING
BENTON INTERNATIONAL INC
 CIRCUIT WISE
BESLY PRODUCTS CORP
BEST CHAIRS
 FISCHER CHAIR
BETHLEHEM STEEL CORP
BGA INTERNATIONAL (BAKER HUGHES)
BIMAC (CHEMINCON)
BIRD ELECTRONIC CORP
BLACK & DECKER CORP
BLASER DIE CASTING CO
 CONTINENTAL BRASS
BLOOMSBURG MILLS (PENN COLUMBIA)
BLUE CIRCLE AMERICA INC
BLUE RIDGE PRODUCTS CO
BLUE STREAK FINISHERS LTD
BOEHRINGER INGELHEIM
BOEING CO
BOISE CASCADE CORP
BOLLMAN HAT CO
BOMARKO INC
BONDLINEADHESIVES INC
BONIDE PRODUCTS INC
BORDEN INC
BOWATER INC
BP AMERICA INC
BRISTOL-MYERS SQUIBB CO
BROD & MCCLUNG-PACE CO
BRUDERER INC
BRULIN & COMPANY INC
STATE       COMPANY                              STATE

  TX        BUCKSTAFF CO                             Wl
            BULK MOLDING COMPOUNDS INC                 IL
  AR        BURKE MILLS INC                           NC
  CT        BURMAH CASTROL HOLDINGS                  NY
             CHEM-TREND
  NC        BURR-BROWN CORP                         AZ
  NJ        BURRELL-LEDER BELTECH (UNITED SILK MILLS)
  CT        BURROUGHS WELLCOME CO                   NC
  VA        BUSHWICKCAN                             NY
  ME        C F & I STEEL CORP                          CO
   IL        C P G INTERNATIONAL INC                    CA
  PA         CLEARPRINT
  LA        C P INC                                    IN
   IL        C P S CHEMICAL CO                          NJ
  MN        CRLINC                                  IL
  NJ        CAAP CO                                 CT
  NY        CABOT CORP                              MA
  Wl        CADDOCK ELECTRONICS INC                   CA
  CT        CADILLAC RUBBER & PLASTIC
             (AVON NORTH AMERICA)
   IL        CALGON CARBON CORP                      PA
   IN        CALIG STEEL DRUM CO                       PA
            CALSONIC INTERNATIONAL INC                 CA
  PA        CAMEO MARBLE (LOUISVILLE TILE DISTRIBUTORS)
            CANON BUSINESS MACHINES INC               CA
            CAPITAL RESIN CORP                        OH
  OH        CAPITOL PRODUCTS CO                      CT
  MD        CARD PAK INC                             OH
  WA        CARGILL DETROIT CORP                       Ml
            CARPENTER TECHNOLOGY CORP               PA
            CARTER-WALLACE INC                       NY
  GA        CASCADE CABINET CORP                     WA
  NC        CASKET SHELLS INC                         PA
  WA        CASPIAN INC                              CA
  CT       CENTRAL PLASTIC CO                        OK
  WA        CERA-MITE CORP                            Wl
   ID        CERTAINTEED CORP                         PA
  PA        CFC INTERNATIONAL (ARMORED KNIGHT)
   IN        CHAMPION INTERNATIONAL CORP              CT
   IN        CHAMPION PARTS INC                         IL
  NY       CHAPARRAL STEEL (TEXAS INDUSTRIES)
  NY       CHAS H LILLY CO                           OR
  CT       CHEM-TECH LTD                            IA
  OH        CHEM-TECH RUBBER                         CT
  NY       CHEM-TREND (BURMAH CASTROL HOLDINGS)
  OR        CHEMICAL SOLVENTS INC                    OH
   AL       CHEMICAL SYSTEMS INC                      IL
   IN
                                               -31-

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 APPENDIX A—Companies Making Commitments to the 33/50 Program (February, 1992)
 COMPANY                              STATE

 CHEMINCON INC                             Ml
  BIMAC
 CHESTNUT RIDGE FOAM INC                   PA
 CHEVRON CORP                            CA
 CHICAGO ADHESIVE PRODUCTS CO              IL
 CHILDERS PRODUCT
  (ASSET MANAGEMENT ASSOCIATES)
 CIBA-GEIGY CORP                           NY
 CIBRO PETROLEUM BRONX INC                 NY
 CIRCUIT WISE (BENTON INTERNATIONAL)
 CITGO PETROLEUM CORP                     OK
 CITICORP                                 NY
  SYBRON CHEMICALS
 CLARK OIL & REFINING CORP                    IL
 CLEARPRINTfC P G INTERNATIONAL)
 CMC STEEL GROUP (COMMERCIAL METALS)
 COACH & CAR EQUIPMENT CORP                IL
 COATING PLACE INC                         Wl
 COATING SYSTEMS INC                       NH
 COLEMAN OUTDOOR PRODUCTS
  (MACANDREWS FORBES HOLDINGS)
 COLLIS INC                                 IA
 COLORADO PAINT CO                        CO
 COLUMBIA CORRUGATED BOX CO               OR
 COMMERCIAL ENAMELING CO                   CA
 COMMERCIAL METALS CO                     TX
  CMC STEEL GROUP
 COMO PLASTICS (G L INDUSTRIES OF INDIANA)
 CONAGRA INC                              NE
  UNITED AGRI PRODUCTS
 CONDERE CORP                            CT
 CONGOLEUM (HILLSIDE CAPITAL)
 CONTINENTAL BRASS (BLASER DIE CASTING)
 CONTRAN CORP                            TX
 KEYSTONE STEEL & WIRE
 COOPER INDUSTRIES INC                     TX
 COOPER INDUSTRIES INC
 AEROVOX
 CORNING INC                              NY
 CORONET PAPER CORP                       NJ
 CREATIVE FOAM CORP                        Ml
 CRITERION CATALYST LTD PARTNERSHIP          TX
CROMPTON & KNOWLES CORP                  CT
CROWN CORK & S EAL CO                      PA
CROWN METAL FINISHING CO                   NJ
CROWN ROLL LEAF INC                       NJ
CRYSTAL CABINET WORKS INC                  MN
CRYSTAL SPRINGS PRINTWORKS                GA
COMPANY                              STATE

CUSTOM PRODUCTS CORP                    Wl
CYCLOPS INDUSTRIES INC                    PA
D S M CHEMICALS (D S M FINANCE)
D S M FINANCE US                          DE
 D S M CHEMICALS
DALLAS WOODCRAFT (HOME INTERIORS & GIFTS)
DALTON FOUNDRIES INC                      IN
DAVIS & HEMPHILL                          MD
DAY & ZIMMERMAN/BASIL                     PA
DECOR GRAVURE
 (RIVER CAPITAL PARTNERS I)
DEFT INC                                 CA
DEGUSSA CORP                            NJ
DEL-CRAFT (KEY PLASTICS)
DELTA ENGINEERING & MANUFACTURING         OR
DELTA RESINS & REFRACTORIES               Wl
DERBY MANUFACTURING INC                  OH
DESIGN HOUSE                             Wl
DIAL CORP                                AZ
DIEBOLD INC                              OH
DISPLAY PACK INC                           Ml
DISSTON CO                              VA
DITRI ASSOCIATES INC                       CT
 RIDG-U-RACK
DITTLER BROTHERS                         GA
DOCK RESINS CORP                         NJ
DOE RUN CO                              MO
DOFASCO INC                               Ml
 WHITTAR STEEL STRIP
DONALDSON CO                            MN
DORMA DOOR CONTROLS INC                  PA
DOUGLAS & LOMASON CO                     Ml
DOW CHEMICAL CO                           Ml
 DOW CHEMICAL CO
 MARION MERRELL DOW
DU PONT                                 DE
DUKANE CORP                              (L
DUNCAN FINANCIAL CORP                    CA
DUNDEE MILLS INC                          GA
DUNLOP TIRE CORP                         NY
DUO-FAST CORP                             IL
DURACELL INTERNATIONAL INC                 CT
E F HOUGHTON & CO                        PA
E R MOORE CO                              IL
EAGLE CHEMICALS INC                       OH
EAGLE OTTAWA LEATHER
 (SMITH EVERETT INV LTD)
EAGLE-PICHER INDUSTRIES  INC                OH
                                           -32-

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APPENDIX A—Companies Making Commitment* to the 33/50 Program (February, 1992)
COMPANY                              STATE

EAST LIBERTY ELECTROPLATING                PA
EASTMAN KODAK CO                         NY
EASTON FOAM INC                           PA
EATON CORP                               OH
EBONEX INC                                NY
EBONITE INTERNATIONAL INC                   KY
EKLUND METAL TREATING INC                  IL
ELASTOMERIC TECHNOLOGIES INC               PA
ELECTRONIC CHROME CO                     CA
ELECTROTEK CORP                          Wl
ELFAQUITAINEINC                           NY
 ELFAQUITAINEINC
 ATOCHEM
ELI LILLY AND CO                            IN
EUO PRODUCTS INC                         NJ
ELPACO COATINGS CORP                      IN
EMERALD ACQUISITION CORP                   IL
 VISKASE
EMERALD PACKAGING INC                     CA
EMERSON ELECTRIC CO                       MO
ENGELHARD CORP                           NJ
EPEC INC                                  MA
ERDLE PERFORATING CO                      NY
ERICSSON-GE MOBILE COMMUNICATION           NJ
ESAB GROUP INC                            SC
ESSEX (MORGAN STANLEY LEV EQ FUND II)
ETHYL CORP                               VA
EVANITE FIBER (FORSCH LTD)
EXCELL POLJSHING & BUFFI NG CO               OH
EXCELLO SPECIALTY CO                       OH
EXXON CORP                               TX
F C HOLDINGS INC                           VA
 I R INTERNATIONAL
F W WINTER (ZIMMERMAN HOLDINGS)
FABRALLOY (STOLPER INDUSTRIES)
FACILE HOLDINGS INC                        NJ
FARLEY INC                                IL
FARM & INDUSTRIAL CHEMICAL
 (MAYO CHEMICAL)
FASCO INDUSTRIES INC                       IL
FEDERAL PAPER BOARD CO                    NJ
FEDERAL-MOGUL CORP                       Ml
FEIN CONTAINER CORP                       NJ
FERNCO INC                                Ml
FIFTH DIMENSION INC                        NJ
FINA OIL AND CHEMICAL
 (AMERICAN PETROFINA HOLDING)
COMPANY

FINITE INDUSTRIES INC
FIRST CHEMICAL (FIRST MISSISSIPPI)
FIRST MISSISSIPPI CORP
 FIRST CHEMICAL
FISCHER CHAIR (BEST CHAIRS)
FISONS CORP
FLEET AEROSPACE INC
 FLEET AEROSPACE INC
 LANGLEY CORP
FLETCHER PAPER CO
FLEXCON COMPANY INC
FLEXFAB INC
FLEXONICS (ZIMMERMAN HOLDINGS)
FLEXSTEEL INDUSTRIES INC
FMC CORP
FORD MOTOR CO
FORSCH LTD
 EVANITE FIBER
FOTO MARK INC
FOXBORO (SIEBE INC)
FRANKLIN INDUSTRIES INC
FRASER PAPER (NORANDA FINANCE)
FROST PAINT & OIL
FULCRUM III LTD PARTNERSHIP
 WOODSTUFF
FUNK FINECAST INC
G L INDUSTRIES OF INDIANA
 COMO PLASTICS
G T PRODUCTS INC
G W USK CO
GAF CORP
GARDEN STATE TANNING
 (HM ANGLO-AMERICAN)
GARDEN WAY INC
GATES CORP
GAYSTON CORP
GEFINOR (USA)
 SHAEFFER
GENA LABORATORIES INC
GENCORP INC
GENERAL DYNAMICS CORP
GENERAL ELECTRIC CO
GENERAL FILTERS INC
GENERAL METALS POWDER CO
GENERAL MOTORS CORP
GENEVA STEEL
GENTEX CORP
GEORGIA GULF CORP
STATE

   NJ

   MS
  NY
  CA
   Ml
  MA
   Ml

   IA
   IL
   Ml
  GA

  MN

   PA

  MN
   NY

  OH
   IN

   Ml
   NY
   NJ
   NY
   CO
   OH
   NY

   TX
   OH
   MO
   CT
   Ml
   OH
   Ml
   UT
   PA
   GA
                                               -33-

-------
 APPENDIX A—Companto Making Commitnwrta to th* 33/50 Program (February, 1992)
 COMPANY                              STATE

 GEORGIA-PACIFIC CORP                      GA
 GETTERS CORP OF AMERICA                  OH
 GILBERT ENGINEERING (MERRILL LYNCH * CO)
 GILLETTE CO                              MA
 GIVAUDAN CORP                           NJ
 GLASGO PLASTICS INC                       OH
 GLEN RAVEN MILLS INC                      NC
 GLOBE MANUFACTURING CO                  MA
 GOODMAN MANUFACTURING CORP              TX
 GOODYEAR TIRE 4 RUBBER CO                 OH
 GRAVURE PACKAGING INC                    VA
 GREAT WESTERN FOAM PRODUCTS             CA
 GREEN BAY PACKAGING INC                   Wl
 GREENVILLE TECHNOLOGY INC                 OH
 GRIFFITH POLYMERS                        OR
 GRUMMAN CORP                            NY
 GTI CORP                                 CA
 GUARDSMAN PRODUCTS INC                  Ml
 GUNDERSON (JAMES-FURMAN & CO)
 H & N CHEMICAL CO INC                      NJ
 H B IVES (HARROW INDUSTRIES)
 H C C INDUSTRIES                           CA
 HADCO CORP                              NH
 HALSTEAD INDUSTRIES INC                   NC
 HANDY & HARMAN                           NY
 HANDY BUTTON MACHINE CO                   IL
 HANLIN GROUP INC                          NJ
 HARBISON-FISCHER MANUFACTURING CO         TX
 HARROW INDUSTRIES INC                     Ml
 H B IVES
 HARVEY HOLDINGS                          TX
 HARVEY INDUSTRIES
 HARVEY INDUSTRIES (HARVEY HOLDINGS)
 HASTINGS MANUFACTURING CO                 Ml
 HAUNI RICHMOND (KOERBER AG)
 HAWORTH INDUSTRIES INC                    Ml
 HBD INDUSTRIES INC                         OH
 PEERLESS-WINSMITH
 HERCULES ENGINES INC                      OH
 HERCULES INC                              DE
 HERESITE PROTECTIVE COATINGS               Wl
 HEWLETT-PACKARD CO                       CA
 HI-SHEAR INDUSTRIES INC                     NY
HILLSIDE CAPITAL INC                        NY
 CONGOLEUM
HILLYARD ENTERPRISES INC                   MO
HITCHINER MANUFACTURING CO                 NH
 COMPANY

 HM ANGLO-AMERICAN LTD
 GARDEN STATE TANNING
 JADE CORP
 HOECHSTCORP
 HOFFMAN-LA ROCHE
 HOMACO INC
 HOME INTERIORS & GIFTS
 DALLAS WOODCRAFT
 HONDA OF AMERICA
 HONEYWELL INC
 HONOLULU WOOD TREATING CO
 HOOVER SYSTEMS INC
 HOUSE OF PACKAGING INC
 HOWMET (PECHINEY)
 HPMCORP
 HUTCHENS INDUSTRIES INC
 HYDRO ALUMINUM USA INC
 HYDROZO (P C R GROUP)
 I R INTERNATIONAL (F C HOLDINGS)
 IBM
 ICI AMERICAN HOLDINGS
 ICI AMERICAN HOLDINGS
 VYTECH
 IDEAL STENCIL MACHINE & TAPE CO
 ILLINOIS TOOL WORKS INC
 IMC FERTILIZER GROUP INC
 IMCERA GROUP INC
 MALLINCKRODT
 IMPHY ALLOYS INC
 TECHALLOY
 INA BEARING CO
 INCO UNITED STATES INC
 INDAL ALUMINUM (INDAL INC)
 INDAL INC
 INDAL ALUMINUM
 INDIANHEAD PLATING INC
 INDUSTRIAL HARD CHROME LTD
 INGERSOLL-RAND CO
 INLAND STEEL INDUSTRIES INC
 INTEL CORP
 INTERLAKE CORP
 INTERNATIONAL PAPER CO
 IRVING TANNING (VISTA RESOURCES)
 ITEN INDUSTRIES INC
 ITT CORP
 ITT HIGBIE MANUFACTURING
 ITT HIGBIE MANUFACTURING (ITT CORP)
J I CASE(TENNECO)
STATE

  NY
  NJ
  NJ
   IL
  TX

  CA
  MN
   HI
  TX
  CA

  OH
  MO
  FL
  NY
  DE
   IL
   IL
   IL
   IL

  NJ

  SC
  NY

  MS

  Wl
   IL
  NJ
   IL
  CA
   IL
  NY

  OH
  NY
                                           -34-

-------
APPENDIX A—Companies Making Commitments to the 33/50 Program (February, 1992)
COMPANY                              STATE

J T SLOCOMB CO                           CT
J&L SPECIALTY PRODUCTS
 (SPECIALTY MATERIALS)
JACOBSON MANUFACTURING CO               NJ
 PENN JACOBSON CO
JADE CORP (HM ANGLO-AMERICAN)
JAMES RIVER CORP OF VIRGINIA               VA
JAMES-FURMAN & CO                        OR
 GUNDERSON
JAMESTOWN PAINT & VARNISH CO              PA
JEFFERSON SMURFIT (SIBV/MS HOLDINGS)
JMK INTERNATIONAL INC                     TX
JOHNSON & JOHNSON                       NJ
JOHNSON CONTROLS INC                     Wl
JONES & VINING INC                         MA
JORDAN GROUP                           NY
 AMERICAN SAFETY RAZOR
JOYCE INTERNATIONAL INC                   NY
 STREATER
JULIAN LUMBER CO                         OK
K SYSTEMS                               CA
 KAISER ELECTROPRESCISION
KAISER ELECTROPRESCISION (K SYSTEMS)
KALAMA CHEMICAL                          WA
KALCOR COATINGS COMPANY INC              OH
KANTHAL CORP                            CT
KASPAR WIRE WORKS INC                    TX
KELSO ASI PARTNERS L P                     NY
 AMERICAN STANDARD
KENNECOTT (RTZ AMERICA INC)
KENNEDY MANUFACTURING CO                OH
KERN-LIEBERS USA INC                      OH
KERR-MCGEE CORP                         OK
KEY PLASTICS INC                           Ml
 DEL-CRAFT
KEY TRONIC CORP                          WA
KEYSTONE STEEL & WIRE (CONTRAN)
KEYWELL CORP                            MD
KIMBERLY-CLARK CORP                      TX
KITZINGER COOPERAGE CORP                 Wl
KLIPSCH & ASSOCIATES INC                    IN
KNOWLES ELECTRONICS                      IL
KOCH LABEL COMPANY INC                    IN
KOEHLER MANUFACTURING CO                MA
KOERBER AG                              VA
 HAUNI RICHMOND
COMPANY                              STATE

KOLENE CORP                              Ml
KRAFT GENERAL FOODS (PHILIP MORRIS)
LANGLEYCORP (FLEET AEROSPACE)
LECO CORP                                Ml
LECTROMAT INC                             PA
LEHIGH PRESS INC                           NJ
LENMAR CHEMICAL CORP                     GA
LIEBELFLARSHEIMCO                       OH
LINCOLN ELECTRIC CO                       OH
LINCOLN GROUP INC                         SC
LOCKHEED CORP                            CA
LOMAC                                    Ml
LORIN INDUSTRIES INC                        Ml
LOUISIANA-PACIFIC CORP                     OR
LOUISVILLE TILE DISTRIBUTORS                 KY
 CAMEO MARBLE
LTV AEROSPACE (LTV CORP)
LTV CORP                                 TX
 LTV AEROSPACE
 LTV STEEL
LTV STEEL (LTV CORP)
LUBRIZOL CORP                             OH
LUKE ENGINEERING & MANUFACTURING           OH
LUSTRE-CAL NAMEPLATE CORP                 CA
LYONDELL PETROCHEMICAL CO                 TX
M H GRAHAM                               MS
MACLEAN-FOGG CO                          IL
MACANDREWS FORBES HOLDINGS               NY
 COLEMAN OUTDOOR PRODUCTS
MACDONALD CARBIDE CO                      CA
MADIX INC                                 TX
MAGEE INDUSTRIAL ENTERPRISES               PA
MALLINCKRODT (IMCERA GROUP)
MANNER PLASTIC MATERIALS                   CA
MANNING FABRICS INC                        NC
MANSFIELD PAINT CO                        OH
MANVILLE CORP                            CO
MARATHON ELECTRIC MANUFACTURING           Wl
MARION MERRELL DOW (DOW CHEMICAL)
MARKEM CORP                             NH
MARTIN MARIETTA CORP                      MD
MARVIN LUMBER & CEDAR CO                   MN
 MARVIN WINDOWS
MARVIN WINDOWS (MARVIN LUMBER & CEDAR)
MASCO INDUSTRIES INC                      Ml
MASK-OFF CO                              CA
MASON AND HANGER (MASON CO)
                                               -35-

-------
 APPENDIX A—Companies Making Commitments to the 33/50 Program (February, 1992)
 COMPANY                              STATE

 MASON CO                                KY
  MASON AND HANGER
 MASTERMOLD                              Wl
 MAUTZ PAINT CO                            Wl
 MAYO CHEMICAL CO                         GA
  FARM & INDUSTRIAL CHEMICAL
 MCCULLOUGH (SHOP VAC CORP)
 MCDONNELL DOUGLAS CORP                  MO
 MEAD CORP                              OH
 MEADEN SCREW PRODUCTS CO                 IL
 MECHANICAL GALV-PLATING CORP              OH
 MECO INC                                 IL
 MEMOREX CORP                            CA
 MERCER INDUSTRIES                        OR
 MERCK & CO INC                            NJ
 MERRILL LYNCH & CO                         NY
  GILBERT ENGINEERING
 METAL-COTE INC                            Ml
 METALLICS INC                             Wl
 METROMEDIA CO                            NJ
  METROMEDIA TECHNOLOGIES
 METROMEDIA TECHNOLOGIES
  {METROMEDIA CO)
 MICOM CORP                              MN
 MID AMERICA CLUTCH                        IN
 MID-WEST INDUSTRIAL CHEMICAL CO            MO
 MIDDCO TOOL & EQUIPMENT INC                WA
 MIDDLESEX RESEARCH MANUFACTURING         MA
 MILLIKEN & COMPANY                        SC
 MILLIPORE CORP                           MA
 MOBIL CORP                              VA
 MODERN METAL PRODUCTS CO                 IL
 MODINE MANUFACTURING CO                   Wl
 MOLDED FIBER GLASS CO                    OH
 MON-ECO INDUSTRIES INC                     NJ
 MONARCH LITHO INC                        CA
 MONROE EQUIPMENT (TENNECO)
 MONSANTO CO                             MO
 MOORE BUSINESS FORMS                     IL
MORGAN STANLEY LEV EQ FUND II              NY
 ESSEX
MOTOROLA INC                             IL
NABORS MANUFACTURING                    TN
NALGE CO (SYBRON ACQUISITION)
NASHUA CORP                             NH
NATIONAL BANNER CO                       TX
COMPANY                             STATE

NATIONAL CHROMIUM CO                     CT
NATIONAL COOPER & SMELTING
 (NATIONAL TUBE HOLDING)
NATIONAL ELECTRICAL CARBON                SC
NATIONAL MANUFACTURING CO                 IL
NATIONAL METALS INC                       AL
NATIONAL TUBE HOLDING CO                  AL
 NATIONAL COOPER & SMELTING
NAUGATUCK GLASS CO                      CT
NELSON INDUSTRIES INC                     Wl
NEO-WOOD PRODUCTS CO                    OH
NEW DIMENSION PLATING                     MN
NEWELL CO                                IL
NEWPORT ADHESIVES & COMPOSITES            CA
NORANDA FINANCE INC                      TN
 FRASER PAPER
NORDSON CORP                           OH
NORTH AMERICAN PAINT CORP                 NJ
NORTHERN PRECISION CASTING CO             Wl
NORTHROP CORP                           CA
NUPLA CORP                               CA
NUTONE INC                               OH
O'SULUVAN CORP                           VA
OAK PARTNERS INC                           IL
 BARNETT VARNISH
OCCIDENTAL PETROLEUM CORP                CA
OHIO ART CO                              OH
OHLINE CORP                              CA
OLIN CORP                                CT
OPTICAL COATING LABORATORY                CA
ORCON CORPORATION                       CA
OREGON STEEL MILLS INC                     OR
OWENS-CORNING FIBERGLAS CORP             OH
P B & H MOLDING CORP                       NY
P C R GROUP INC                           FL
 HYDROZO
PACIFIC ALLOY CASTINGS                     CA
PACKAGING CORP (TENNECO)
PANEL PROCESSING INC                      Ml
PARKER HANNIFIN CORP                      OH
PARKER PEN USA LTD                        Wl
PARSONS & WHITTEMORE ENTERPRISES          NY
 ALABAMA RIVER PULP
PAULSEN WIRE ROPE CORP                   PA
PECHINEY CORP                           CT
 HOWMET
PEERLESS OF AMERICA INC                     IL
PEERLESS-WINSMITH (HBD INDUSTRIES)
                                          -36-

-------
APPENDIX A—Companies Making Commitments to the 33/50 Program (February, 1992)
COMPANY

PENN COLUMBIA CORP
 BLOOMSBURG MILLS
PENN JACOBSON (JACOBSON MFG)
PENNZOILCO
PERRIGO CO
PERRY & DERRICK CO
PETRO CHEMICAL PRODUCTS INC
PETROLITE CORP
PFISTER CHEMICAL INC
PFIZER INC
PHILIP MORRIS CO
 KRAFT GENERAL FOODS
PHILLIPS PETROLEUM CO
PHILLIPS PLASTICS CORP
PHOENIX HEAT TREATING INC
PHOTOCIRCUITS CORP
PINES TRAILER LTD PARTNERSHIP
PITNEY BOWES INC
PLUMMER PRECISION OPTICS
PLYMOUTH RUBBER COMPANY INC
PMF INDUSTRIES INC
POLAROID CORP
POLY PAK INDUSTRIES INC
POM INC
POTLATCH CORP
POWELL INDUSTRIES INC
PPG INDUSTRIES INC
PQ CORP
PRECISION CASTPARTS CORP
PRECISION FABRICS GROUP INC
PRECISION PLATING CO
PRECISION PRODUCTS INC
PREMARK INTERNATIONAL INC
PRINTED CIRCUIT CORP
PROCTER & GAMBLE CO
PROGRESS CASTING GROUP INC
PROSPECT INDUSTRIES
 (PROSPECT PURCHASING)
PROSPECT PURCHASING CO
 PROSPECT INDUSTRIES
PROVIDENCE METALLIZING CO
PRUETT-SCHAFFER CHEMICAL CO
QUAKER STATE CORP
QUALITY COATINGS INC
QUALITY METAL PRODUCTS INC
QUALITY ROLLING & DEBURRING CO
QUANTUM CHEMICAL CORP
R G F ENTERPRISES INC
STATE       COMPANY                              STATE

  NY        R H SHEPPARD COMPANY INC                  PA
            R L C INDUSTRIES CO                        OR
             ROSEBURG LUMBER
  TX        R P ADAMS CO                             NY
   Ml        RAMPART INDUSTRIES INC                     Ml
  OH        RANBAR TECHNOLOGY INC                    PA
   FL        RAYOVAC CORP                            Wl
  MO        RAYTHEON CO                             MA
  NJ        RED SPOT PAINT & VARNISH CO                 IN
  NY        REFRACTORY SALES & SERVICE CO             AL
  NY        REINHOLD (BAIRNCO CORP)
            REINZ WISCONSIN GASKET CO                 Wl
  OK        RELIANCE FINISHING CO                      Ml
  Wl        REPUBLIC ENGINEERED STEELS                OH
  AZ        REPUBLIC STORAGE SYSTEMS CO               OH
  NY        RESIUTE SPORTS PRODUCTS INC               PA
   IL        REVCOR INC                                IL
  CT        REVLIS CORP                              OH
  PA        REYNOLDS METALS CO                       VA
  MA        RHONE-POULENC INC                        NJ
  PA        RICO COATINGS INC                         GA
  MA        RIDG-U-RACK (DITRI ASSOCIATES)
  NY        RIVER CAPITAL PARTNERS  I                   GA
  AR         DECOR GRAVURE
  CA        RIVERSIDE HOLDINGS INC                     AR
  TX        RIVERSIDE INTERNATIONAL INC                 Ml
  PA        RJR NABISCO HOLDINGS                      NY
  PA         ARCHER CO
  OR        ROBERT WEED PLYWOOD CORP                 IN
  NC        ROBINSON RUBBER  PRODUCTS                MN
   IL        ROCKWELL INTERNATIONAL CORP               CA
   IL        ROHM AND HAAS CO                        PA
   IL        ROLSCREEN CO                             IA
  MA        ROMAC ELECTRONICS INC                     NY
  OH        ROME CABLE (ROME GROUP INC)
  MN        ROME GROUP INC                          NY
             ROME CABLE
            ROMO INC                                Wl
   NJ        RONKEN INDUSTRIES INC                      IL
            ROSEBURG LUMBER (R L C INDUSTRIES)
   Rl        RSR HOLDING CORP                        TX
   PA        RTZ AMERICA INC                           UT
   PA         KENNECOTT
   IN        RUBICON INC                               LA
  CO        RUDDICK CORP                            NC
   CT        AMERICAN & EFIRD
  NY       RUSSELL CORP                             AL
  CA        S C JOHNSON & SON INC                      Wl
                                               -37-

-------
 APPENDIX A—Companies Making Commitments to the 33/50 Program (February, 1992)
 COMPANY                              STATE

 SADOLIN PAINT PRODUCTS INC                 NC
 SANDEN OF AMERICA INC                      CA
 SANDOZ CORP                              NY
 SANDSTROM PRODUCTS CO                     IL
 SARA LEE CORP                              IL
 SARGENT-FLETCHER (A J INDUSTRIES)
 SARTORIUS NORTH AMERICA INC                NY
 SAUNDERS SUPPLY CO                       VA
 SCHERING-PLOUGH CORP                     NJ
 SCHNELLER INC                             OH
 SCOTT PAPER CO                            PA
 SEABOARD METAL FINISHING CO                CT
 SEAWARD INTERNATIONAL                     VA
 SEM PAINT CO                               CA
 SENECA FOODS CORP                        NY
 SHAEFFER (GEFINOR)
 SHELL PETROLEUM INC                       DE
 SHELLER-GLOBE (UNITED TECHNOLOGIES)
 SHEPHERD CHEMICAL                         OH
 SHERWIN-WILLIAMS CO                       OH
 SHOP VAC CORP                             PA
  MCCULLOUGH
 SHUFORD INDUSTRIES INC                     NC
 SIBV/MS HOLDINGS INC                       MO
  JEFFERSON SMURFIT
 SIEBE INC                                  MA
  FOXBORO
 SILVER FURNITURE CO                        TN
 SIMPSON INVESTMENT CO                    WA
 SIMPSON PAPER
 SIMPSON PAPER (SIMPSON INVESTMENT)
 SKF USA INC                                PA
 SLATER STEELS                              IN
 SMITH EVERETT INV LTD                       Wl
 EAGLE OTTAWA LEATHER
 SMITH SYSTEM MANUFACTURING CO             MN
 SMITHKUNE BEECHAM AMERICAS                PA
 SNYDER GENERAL CORP                      TX
 SOMMER METALCRAFT                        IN
 SONOCO PRODUCTS CO                      SC
 SOUTHWIRE (SPECTRUM LTD)
 SPD TECHNOLOGIES INC                       PA
 SPECIALTY MATERIALS  CORP                    PA
 J&L SPECIALTY PRODUCTS
SPECTRULITE CONSORTIUM INC                 IL
SPECTRUM LTD                             GA
 SOUTHWIRE
SPIROL INTERNATIONAL HOLDING CO             CT
 COMPANY

 SPRAY PRODUCTS CORP
 SPRAYING SYSTEMS CO
 STANDARD CHLORINE CHEMICAL CO
 STANDARD INDUSTRIES INC
 STANDARD MOTOR PRODUCTS INC
 STAR ENTERPRISE
 STEEL OF WEST VIRGINIA INC
 STEELCASE INC
 STEPHENSON * LAWYER INC
 STERLING CHEMICALS INC
 STEWART HALL CHEMICAL CORP
 STILLWATER INVESTMENT
 UNITED ELECTRIC
 STOLPER INDUSTRIES INC
 FABRALLOY
 STORA HOLDING INC
 TARKETT
 STOREYS TRANSPRINT INC
 STREATER (JOYCE INTERNATIONAL)
 SUBA MANUFACTURING INC
 SUMITOMO METAL USA CORP
 WESTERN TUBE & CONDUIT
 SUMMITVILLE TILES INC
 SUN COMPANY INC
 SUN METAL PRODUCTS  INC
 SUNNEN PRODUCTS
 SUNSET FIREPLACE FIXTURES
 SWANK INC
 SYBRON ACQUISITION CO
 NALGE CO
 SYBRON CHEMICALS (CITICORP)
 SYNTEX AGRIBUSINESS (SYNTEX USA)
 SYNTEX USA INC
 SYNTEX AGRIBUSINESS
 TALON INC
TARKETT (STORA HOLDING)
TAWAS PLATING CO
TECH INDUSTRIES INC
TECHALLOY (IMPHY ALLOYS)
TECHMETALS INC
TECUMSEH PRODUCTS CO
TEKNI-PLEX INC
TELLABSINC
TEMPLE-INLAND INC
TEMPRESS INC
STATE

  PA
   IL
  NJ
  TX
  NY
  TX
  WV
  Ml
  Ml
  TX
  NY
  CT

  Wl

  NJ

  VA

  CA
  NY

  OH
  PA
  IN
  MO
  CA
  MA
  Wl
  CA

  PA

  Ml
  Rl

  OH
  Ml
  NY
   IL
  TX
  WA
                                            -38-

-------
APPENDIX A—Companies Making Commitments to the 33/50 Program (February, 1992)
COMPANY                               STATE

TENNECOINC                              TX
 JI CASE
 MONROE EQUIPMENT
 PACKAGING CORP
TEXACO INC                               NY
TEXAS INDUSTRIES INC                       TX
 CHAPARRALSTEEL
TEXAS INSTRUMENTS INC                     TX
THIOKOL CORP                             UT
THOMAS INDUSTRIES INC                     KY
THOMAS STEEL STRIP CORP                   OH
THOMSON CONSUMER ELECTRONICS            IN
TIMKEN CO                                 OH
TISHCON CORP                             NY
TOLEDO COKE CORP                         OH
TORWICO ELECTRONICS INC                   NJ
TOWER OIL  & TECHNOLOGY CO                  IL
TRANSCO PRODUCTS CORP                   NJ
TRI-STATE POLE & PILING INC                   MS
TRINOVA CORP                             OH
TRIPLEX PLATING INC                        IN
TUSONIX INC                               AZ
U S ENTERPRISE                             IL
 WASHINGTON STEEL
US STEEL (USX CORP)
USX CORP                                PA
 U S STEEL
U TI CORP                                 PA
 UNIFORM TUBES
UCC INVESTORS HOLDING                     CT
 UNIROYAL  CHEMICAL CO
ULTRA FORGE INC                           OH
UNIFORM TUBES (U TI CORP)
UNION CAMP CORP                          NJ
UNION CARBIDE CORP                        CT
UNION ZINC INC                             TN
UNIROYAL CHEMICAL
 {UCC INVESTORS HOLDING)
UNITED AGRI PRODUCTS (CONAGRA)
UNITED ELECTRIC (ST1LLWATER INVESTMENT)
UNITED SILK MILLS INC                       NY
 BURRELL-LEDER BELTECH INC
UNITED TECHNOLOGIES                       CT
 UNITED TECHNOLOGIES
 SHELLER-GLOBE
UNIVERSAL  COOPERATIVES INC                 MN
UNIVERSAL  PACKAGING CORP                  NH
UNOCAL CORP                              CA
COMPANY                              STATE

UOP                                       IL
UPJOHN CO                                Ml
USS-POSCO INDUSTRIES                      CA
VAIL RUBBER WORKS                         Ml
VALLEY CRAFT                              MN
VALSPAR CORP                             MN
VAN DER HORST USA CORP                    TX
VANGUARD PAINTS & FINISHES                  OH
VARIAN ASSOCIATES INC                      CA
VELJE CIRCUITS INC                          CA
VELSICOL CHEMICAL CORP                     IL
VICOM INC                                 TX
VISKASE (EMERALD ACQUISITION)
VISTA CHEMICAL CO                          TX
VISTA RESOURCES INC                       NY
 IRVING TANNING
VIZ MANUFACTURING CO                      PA
VULCAN MATERIALS CO                       AL
VYTECH (ICI AMERICAN HOLDINGS)
W J RUSCOE CO                            OH
W M BARR & CO                             TN
W R GRACE & CO                            NY
W W CUSTOM CLAD INC                       NY
WABASH NATIONAL CORP                      IN
WALLE CORP                               LA
WALTCO ENGINEERING CO                    CA
WARUCK PAINT CO                          NC
WARN INDUSTRIES (WARNCOM)
WARNCOM INC                              OR
 WARN INDUSTRIES
WARNER-LAMBERT CO                       NJ
WASHINGTON STEEL (U S ENTERPRISE)
WEIRTON STEEL CORP                       WV
WEISS-AUG CO                              NJ
WELDON TOOL CO                           OH
WELLCO ENTERPRISES INC                    NC
WELLONS                                 OR
WESTERN RESERVE MANUFACTURING CO         OH
WESTERN TUBE & CONDUIT
 (SUMITOMO METAL)
WESTINGHOUSE ELECTRIC CORP               PA
WESTVACO CORP                            NY
WEYERHAEUSER CO                         WA
WHIRLPOOL CORP                            Ml
WHITE CONSOLIDATED INDUSTRIES              OH
WHITEHALL CORP                            TX
WHITTAR STEEL STRIP (DOFASCO)
WILKO PAINT                               KS
                                                -39-

-------
 APPENDIX A—Companies Making Commitments to the 33/50 Program (February, 1992)
COMPANY                                STATE

WILLAMETTE INDUSTRIES INC                   OR
WINCO INC                                 MN
WINONA CORP                              IN
WISCONSIN TOOL & STAMPING CO               IL
WISE CO                                   AR
WITCO CORP                                NY
WOLVERINE HOLDING CO                      AL
 WOLVERINE TUBE
WOLVERINE TUBE (WOLVERINE HOLDING)
WOOD PRESERVERS INC                      VA
WOODBRIDGE HOLDINGS INC                   PA
WOODSTUFF (FULCRUM III LTD PARTNERSHIP)
WORLD GENERATOR CO                       IL
WORTH INC                                 TN
XEROX CORP                                CT
YALE SECURITY INC                           NC
YOUNGWOOD ELECTRONIC METALS              PA
ZIMMERMAN HOLDINGS INC                     CA
 F W WINTER
 FLEXONICS
ZIRCOA INC                                OH
                                            -40-

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FOR MORE INFORMATION...

Anyone interested in obtaining additional information about the 33/50 Program can do so
by contacting EPA's TSCA Hotline at (202) 554-1404, Monday through Friday between 8:30
a.m. and 5:00 p.m. EST. In addition, all information received by EPA through the 33/50
Program is available to the public.  Written communications from companies are
maintained in the 33/50 Program Administrative Record, which is available for inspection
on a walk-in basis at EPA's Emergency Planning and Community Right-to-Know Act
(EPCRA) Reporting Center. To make requests from the 33/50 Program Administrative
Record, please contact the Reporting Center at (202) 488-1501, or mail your request to:
EPCRA Reporting Center, P. O. Box 23779, Washington, D. C.. 20026-3779. Attention: 33/50
Program.

^formation about the 33/50 Program can also be obtained by contacting EPA's Regional Offices:
Region I
33/50 Program Coordinator
US Environmental Protection Agency
Pesticides & Toxics Substances
1 Congress Street. Room 2203
Boston. MA 02203
Connecticut, Massachusetts. Maine. New Hampshire. Rhode
Island, Vermont

Region II
33/50 Program Coordinator
US Environmental Protection Agency
Environmental Services Division
2890 Woodbridge Avenue, Building 10
Edison NJ 08837-3679
New Jersey. New York. Puerto Rico. Virgin Islands

Region III
33/50 Program Coordinator
US Environmental Protection Agency
841 Chestnut Street
Philadelphia. PA 19107
Delaware, District of Columbia. Maryland, Pennsylvania,
Virginia, West Virginia

Region IV
33/50 Program Coordinator
US Environmental Protection Agency
Title III & Toxics Section
345 Courtland Street, NE
Atlanta. GA 30365
Alabama, Florida, Georgia. Kentucky. Mississippi, North
Carolina, South Carolina. Tennessee

Region V
33/50 Program Coordinator
US Environmental Protection Agency
Pesticides & Toxic Substances Branch
77 West Jackson
Chicago. IL 60604
Illinois. Indiana. Michigan. Minnesota. Ohio, Wisconsin
Region VI
33/50 Program Coordinator
US Environmental Protection Agency
1445 Ross Avenue
Dallas. TX 75202-2733
Arkansas. Louisiana. New Mexico, Oklahoma. Texas

Region VII
33/50 Program Coordinator
US Environmental Protection Agency
Air & Toxics Division
726 Minnesota Avenue
Kansas City. KS 66101
Iowa. Kansas. Missouri. Nebraska

Region VIII
33/50 Program Coordinator
US Environmental Protection Agency
999 18th Street
Denver. CO 80202-2405
Colorado. Montana. North Dakota. South Dakota. Utah.
Wyoming

Region DC
33/50 Program Coordinator
US Environmental Protection Agency
75 Hawthorne Street
San Francisco. CA 94105
Arizona. California, Hawaii, Nevada, American Samoa.
Guam. Commonwealth of the Northern Mariana Islands

Region X
33/50 Program Coordinator
US Environmental Protection Agency
Toxics Substances  Section
1200 6th Avenue
Seattle. WA 98101
Alaska, Idaho. Oregon, Washington

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