# From Ross.Philipepamail.epa.gov 

# Sent Tuesday September 

# 23 2008 

# 458

# PM

# GMT To Boucher Michael 

# mbouchermckennalong

# com Cc Shackleford.Bettyepamail epa.gov Edwards.Dennisepamail.epa.gov 

# Boucher Michael 

# mbouchermckennalong

# .com Noble.Velmaepa.gov Subject 

# ReBuckman Laboratories 

## Inc--Meeting request

Michael Did you send Seth 

### Goldberg counsel for

# NALCO copy of

### yourSeptember petition 

### and this follow-up 

### email believe in an earlier 

### communication this 

### summer Dennis Edwards requested that 

### you do so

## when sending us anything related to this matter
Please advise 

### Thank 

## you
Phil 

### Ross Philip 

### Ross United States Environmental Protection 

### Agency Office of General Counsel Pesticides and Toxic Substances 

## Law Office 

### 202-564-5637



## Boucher Michael 

## mboucher@mckenn To along.com Dennis 

## Edwards/DC/USEPA/US@EPA cc 09/23/2008 

### 1217 Betty 

# PM Shackleford/DC/USEPA/US@EPA Velma 

## Noble/DC/USEPA/US@EPA Philip 

## Ross/DC/USEPA/US@EPA Boucher Michael 

## mbouchermckennalong 

# com Subject 

## Buckman Laboratories 

### Inc--Meeting request

### Dear Dennis Following our electronic submission of the attached petition to

# EPAon September 

## 2008 would like to respectfully 

### renew request 

### on behalf of our client 

## Buckman Laboratories 

### Inc 

# Buckman for face-to-face 

### meeting at

## OPP in Arlington with 

## you Phil

## Ross and 

### your colleagues in the Antimicrobial Division to discuss the substance of 

## Buckmans petition In 

### August following 

## my initial meeting request understood that 

### youwere looking forpossible meeting dates and 

### would be responding to 

## me with suggestions but never heard anything further 

### fromyou with respect to 

### meeting 

# Now that there is something concrete and detailed to discuss 

### namely the attached petition 

## am hoping that 

### you will be able to suggest date or dates to 

### meet with 

## me and representatives of

## Buckman to discuss the serious 

### problems associated with the

### ongoing distribution and sale of unregistered 

### ammonia forwater treatment thank 

### you for

### yourkind consideration of this 

### meeting request and look forward to reply at

### yourconvenience Thank 

## you Dennis Sincerely 

### Michael Boucher Counsel to

## Buckman Laboratories 

### Inc 

# McKENNA LONG ALDRIDGE LLP Attorneys at

## Law Michael Boucher 

## Tel

# 202 496-7729 

## Fax

# 202 496-7756 Cell

# 202 306-1645 

## mbouchermckennalong com
1900 Street 

# NW Suite 100 

### Washington 

## D.C 20006-1102 United States of

### America 

## Tel

# 202 496-7500 http//www.mckennalong.com 

# ALBANY ATLANTA BRUSSELS 

# DENVER LOSANGELES 

# NEW YORK PHILADELPHIA 

# SAN DIEGO SAN FRANCISCO 

# WASHINGTON D.C

Original 

### Message 

## From Boucher Michael Sent Tuesday September 

## 02 2008 

## 431 

# PM To Edwards.Dennisepamail.epa.gov 

# Cc Sanders.Frankepamail.epa.gov Shackleford.Bettyepamail epa

# gov NobleVelmaepa.gov Ross.Philipepamail.epa.gov Boucher Michael Subject 

# RE Petition

### on behalf of

## Buckman Laboratories 

### Inc

Dear DennisAttached is slightly 

### amended version of

## Buckmans petition 

### added missing citation 

### on page and fixed

### one typographical error 

### on page 13

look forward to discussing with 

### you what

# EPA can 

### do to resolve the outstanding registration issues surrounding 

### ammonia forwater treatment 

### Thank 

## you 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 Boucher Michael Sent Tuesday September 

## 02 2008 

## 221 

# PM To Edwards.Dennisepamail.epa.gov 

# Cc Sanders.Frankepamail.epa.gov Shackleford.Bettyepamail.epa 

## gov Noble 

## Velmaepa.gov Ross.Philipepamail.epa.gov Boucher Michael Subject Petition

### on behalf of

## Buckman Laboratories 

### Inc

Dear Dennis
Attached is petition that 

## we are filing 

### on behalf of our client 

## Buckman Laboratories 

### Inc under section

# 553e of the Administrative Procedures 

## Act U.S.C 

# 553e The petition requests that 

# EPA immediately prohibit any further distribution or sale of unregistered 

### ammonia forwater treatment 

### Thank you for

### yourconsideration of

## Buckmans petition 

# We will telephone 

### you to learn

## how

# EPAwill handle 

### and process the petition 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 

## gov

### Sent Thursday July 

### 10 2008 

## 510

# PM To Boucher Michael 

# Cc Sanders.Frankeparnail.epa.gov Shackleford.Bettyepamail.epa 

## gov Noble 

## Velmaepa.gov Ross.Philipeparnail.epa.gov 

### SGoldbergsteptoe corn Subject Petition to Cancel Registration of

### BusanR 1215 

# EPAReg 

# No 1448-43



### 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 for registration of

### two arnrnonia 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 arnrnonia products as pesticides 

## when used in cornbination with chlorine treated

### water In 

### your letter arnong 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 interirn response that the

### Agency sentto 

# NALCO after receiving its petition This ernail responds to those requests fordocurnents only and is not addressing at this tirne any other staternents or requests that 

### you have included in

### your letter

In filling 

### your request 

## we are providing 

### you with the docurnents 

### which constitute the petition and support docurnents as well as subsequent correspondence 

### between the

### Agency and 

# NALCOconcerning sorne questions the

### Agency has 

### had as of this point about 

# NALCOs petition and support docurnents 

# We are also providing 

### you with 

### copy of the

### Agencys interirn response to

# NALCOwhich you specifically asked about in

### your letter Additionally since

## we are sending 

### copy of this ernail 

### and the attachrnents to counsel for

# NALCO we are including 

### your letter to 

### Frank Sanders dated June 

## 25 2008 as well as sorne ernail exchanges 

### between you and 

### Agency counsel 

### on this rnatter Please note that

## we are not including ernail 

### exchanges that 

### Agency staff 

### had with

# NALCOcounsels firrn 

### which pertained only to the

### need forreview of various docurnents for confidential business inforrnation and subsequent redactions 

### The docurnents 

### you are being provided 

### have been reviewed and redacted as appropriate to rernove any confidential business inforrnation 

### The following docurnents are being provided to

## you Decernber 

### 2007 ernail frorn Seth 

### Goldberg to 

### Debbie Edwards It is contained in the file narned 

### 12-4-07 ernail to

## EPA.Redacted See attached file 12-4-2008 ernail to 

### EPA.Redacted.pdf
Decernber 

### 2007 request frorn 

# NALCOto reconsider It is contained in the file narned 

### Redacted Request to Reconsider Arnrnonia Registration 

## See attached file 

### Redacted Request to Reconsider Arnrnonia Registration.pdfOctober 

## 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 

## AmmoniaCompound 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 

## BrownSteptoe 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 

## CONFIDENTIALITY 

# NOTICE This e-mail and any attachments contain information 

### from the

### lawfirm of

## McKenna Long Aldridge 

# LLP and are intended solely forthe use of the

### named recipient or recipients This e-mail 

## may contain privileged attorney/client 

### communications or

### work product 

## Any dissemination of this e-mail 

### by anyone other than an intended recipient is strictly prohibited If

### you are not 

### named recipient 

### you are prohibited 

### from any further viewing of the e-mail or any attachments or

### from making any use of the e-mail or attachments If

### you believe 

### you have received this e-mail in error notify the sender immediately 

### and permanently delete the e-mail any attachments 

### and all copies thereof 

### from any drives or storage 

### media and destroy any printoutsof the e-mail or attachments 

## Amended petition.pdf deleted 

### by Philip 

## Ross/DC/USEPA/US