# From Boucher Michael 

# Sent Thursday July 

# 10 2008 

# 942

# 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 

# RE Petition to

## Cancel Registration of 

# BusanR 1215 

# EPAReg 

# No 1448-433

Dear Dennis

acknowledge receipt of 

### yourmessage below andof materials attached to it appreciate 

### your cooperation 

### and responsiveness in this 

### matter and will get

### back to

### you with

# my clients thoughts following 

### our review of this 

## new information Thank 

## you Sincerely 

### Michael Boucher Counsel to 

## Buckman Laboratories Inc

Michael Boucher 

## McKenna Long Aldridge

## LLP 1900 Street

# NW Suite 

### 100 Washington 

# DC 20006-1110 

# 202496-7729 -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 

## OnJune

## 25 2008 you sent letter to the 

### Agency concerning petition filed

### on behalf of

# NALCO concerningthe 

### Agencys approval of

### your client 

## Buckman Laboratories Inc.s applications forregistration of 

### two ammonia products aspesticides 

# NALCOin its petition has 

### asked the 

### Agency to reconsider its approval of those registrations

### and has raised questions about the status of 

### ammonia products aspesticides 

## when used in 

### combination withchlorine treated 

### water In

### your letter

### among other 

### thingsyou have asked for 

### copy of the petition as well as 

### anycorrespondence between the 

### Agency and

# NALCOconcerning 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 areproviding 

### you withthe 

### documents which constitute the petition 

### and support 

### documents as well as 

### subsequent correspondence between the 

### Agency and

# NALCOconcerningsome 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 

### andthe attachments to counsel for 

# NALCOwe areincluding 

### your letter to 

### Frank Sanders dated 

### June

## 25 2008 aswell as

### some email 

### exchanges between you andAgency counsel 

### on this 

### matter Please note that

## we are notincluding 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

# 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 

# 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 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