From Boucher Michael

Sent Thursday July 17 2008 946 PM GMT

To Edwards.Denniseparnail.epa.gov

Cc Sanders.Frankeparnail.epa.gov Shackleford.Bettyeparnail epa.gov

Noble.Velrnaepa.gov Ross.Philipeparnail.epa.gov Boucher Michael

rnboucherrnckennalong corn

Subject Petition to Cancel Registration of BusanR 1215 EPA Reg No 1448-433

Dear Dennis

Buckman Laboratories Inc Buckman respectfully requests meeting with you during the week of July 28 August or August 11

at your convenience to explain why Buckmans Busan 1215 is properly registered under FIFRA and to address several inaccuracies in

Nalcos December 2007 petition so that EPA can make fully informed response to the petition We look forward to your response

with respect to our meeting request and thank you for your continued assistance in this matter

Sincerely

Michael Boucher

Counsel to Buckman Laboratories Inc

Michael Boucher

McKenna Long Aldridge LLP

1900 Street NW Suite 100

Washington DC 20006-1110

202 496-7729 -7756 fax

e-mail mbouchermckennalong.com

Original Message

From Edwards.Dennisepamail.epa.gov Edwards.Dennis@epamail epa gov

Sent Thursday July 10 2008 510 PM

To Boucher Michael

Cc Sanders.Frankepamail.epa.gov Shackleford.Bettyepamail.epa gov Noble Velmaepa.gov Ross.Philipepamail.epa.gov

SGoldbergsteptoe com

Subject Petition to Cancel Registration of BusanR 1215 EPA Reg No 1448-433

Dear Mr Boucher

On June 25 2008 you sent letter to the Agency concerning petition filed on behalf of NALCO concerning the Agencys approval

of your client Buckman Laboratories Inc.s applications for registration of two ammonia products as pesticides NALCO in its

petition has asked the Agency to reconsider its approval of those registrations and has raised questions about the status of ammonia

products as pesticides when used in combination with chlorine treated water In your letter among other things you have asked for

copy of the petition as well as any correspondence between the Agency and NALCO concerning its petition

You also asked for copy of an interim response that the Agency sent to NALCO after receiving its petition This email responds to

those requests for documents only and is not addressing at this time any other statements or requests that you have included in your

letter

In filling your request we are providing you with the documents which constitute the petition and support documents as well as

subsequent correspondence between the Agency and NALCO concerning some questions the Agency has had as of this point about

NALCOs petition and support documents We are also providing you with copy of the Agencys interim response to NALCO which
you specifically asked about in your letter Additionally since we are sending copy of this email and the attachments to counsel for

NALCO we are including your letter to Frank Sanders dated June 25 2008 as well as some email exchanges between you

and Agency counsel on this matter Please note that we are not

including email exchanges that Agency staff had with NALCO counsels firm which pertained only to the need for review of various

documents for confidential business information and subsequent redactions The documents you are being provided have been

reviewed and redacted as appropriate to remove any confidential business information The following documents are being provided

to you

December 2007 email from Seth Goldberg to Debbie Edwards It is

contained in the file named 12-4-07 email to EPA.Redacted

See attached file 12-4-2008 email to EPA.Redacted.pdf

December 2007 request from NALCO to reconsider It is contained

in the file named Redacted Request to Reconsider Ammonia Registration

See attached file Redacted Request to Reconsider Ammonia

Registration.pdf

October 31 2007 email from Seth Goldberg to Debbie Edwards It is

contained in the file named 10-31-07 email redacted

See attached file 10-31-07 email redacted.PDF

An attachment to the October 31 2007 email from Seth Goldberg

concerning ammonia It is contained in the file named Ammonia Compound Briefing Paper REDACTED

See attached file Ammonia Compound Briefing Paper REDACTED.PDF

product label for 1448-432 MUP that was attached to the October

31 2007 Goldberg email It is contained in the file named 1448-432 MUP

See attached file 1448-432 MUP.pdf

product label for 1448-43 EP that was attached to the October

31 2007 Goldberg email It is contained in the file named 1448-433 EP

See attached file 1448-43 EP.pdf

The Agencys interim response to NALCO dated February 2008

concerning its petition It is contained in the file named NALCO resp

ltr 2.7.08

See attached file Nalco resp ltr 2.7.08.pdf

Email correspondence from Brown with Steptoe which is NALCOs

counsel dated June 26 2008 It is contained in the file named Brown
Steptoe to Holmes email 6-26-2008

See attached file Brown Steptoe to Holmes email 6-26-2008.pdf

Email exchanges involving Brown Steptoe and Holmes They are

contained in the file named Email to Brown and 7-7-2008 reply

See attached file Email to Brown and 7-7-2008 reply.pdf

10 July 2008 Ammonia Supplemental Information provided to the Agency by Brown Steptoe It is contained in the file named

7-7-2008 Ammonia

supplemental information

See attached file 7-7-2008 Ammonia supplemental information.pdf

11 Email exchanges between Ross Agency counsel in this matter and Boucher counsel for Buckman Laboratories Inc. They are

contained in the file named Ross-Boucher-email-exchanges-ammonia

See attached file Ross-Boucher-email-exchanges-ammonia.pdf

12 Boucher letter to Frank Sanders dated June 25 2008 It is contained in the file named Letter to EPA re petition to cancel Busan

1215

See attached file Letter to EPA repetition to cancel Busan 1215.pdf

Should you have any questions please direct them in writing to me with copy to Philip Ross in our Office of General Counsel

You should also provide copy of any correspondence pertaining to this matter to counsel for NALCO

Sincerely

Dennis Edwards Chief

Regulatory Management Branch

Antimicrobials Division

703 -308-8087