# 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

# EPAReg

# No 1448-433

Dear Dennis 

## Buckman Laboratories 

### Inc 

# Buckman respectfully requests meeting with 

### you during the

### week ofJuly 

## 28August or

### August 

## 11 at

### yourconvenience 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 

### meetingrequest and thank 

### you for

### yourcontinued 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 

# EPAReg 

# No 1448-433



### Dear

# Mr Boucher 

## On June 

## 25 2008 you sent letter to the

### Agency concerning petition filed 

### on behalf of

# NALCOconcerning the

### Agencys approval of

### your client 

## Buckman Laboratories Inc.s applications forregistration 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 

# NALCOconcerning its petition 

## You also asked for 

### copy of an interim response that the

### Agency sentto

# 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 

# NALCOconcerning 

### 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

# NALCOwhich

### 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

# NALCOcounsels firm

### which pertained only to the

### need for review of various 

### documents forconfidential 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

# NALCOto 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 

# AmmoniaCompound 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

# NALCOdated February 

## 2008 concerning its petition It is contained in the file 

### named 

# NALCOresp 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 Emailexchanges 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

# EPArepetition 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