# EPA Reg. No. 71532-7 Volume 1 part 2

## ....

August 8, 2005

Mr. GeorgeLaRocca(PMTeam 13) Office ofPesticidePrograms (7504C) US Environmental Protection Agency Ariel RiosBuilding 1200PennsylvaniaAvenue, NW Washington, DC 20460 SUBJECT: LGLife Sciences, 

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### "LGPermethrin Technical PHInsecticide"; EPAReg. No. 71532-7 and "LGPennethrin 3.2EC Agricultural Insecticide";EPAReg. No. 71532-15 Submittal ofFinal Labeling DearMr. LaRocca: As perthe Notices ofPesticideRegistration, pleasefindenclosedcopies offinal labeling with the changes andcorrections made as statedin each Notice. Shouldyou have any questions orotherwise wish toreach me, pleasefeel free to contactmy office at (203) 740-1200.

115 ObtuseHill. Brookfield, Connecticut 06804· USA Voice: 203.740.1200" Fax: 203.740.1220· Email: lmiller@biologicconsulting.com

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# LG PERMETHRIN TECHNICAL PH INSECTICIDE AN INSECTICIDE FOR FORMULATING USE ONLY 

## NOTREVIEWBD In

## Accordance with

## PR Notice 82-2 Based on

## Draft Labeling Dated

FOR FORMULATION OF MOSQUITO CONTROL PRODUCTS AND ULV MOSQUITO CONTROL AGENTS.

ACTIVE INGREDIENT: ·Permethrin

............................................................................................................... 95.2'% OTHER INGREDIENTS:

............... .. .. ..................................................................... ................. 4.8%

*(3-Phenoxyphenyl)methyl(±) cis,trans-3-(2,2dichloroethenyl)- 2,2-dimethylcyclopropanecarboxylate cis/trans ratio: min. 

### 35% (±) 

### cis and max. 65% (±) 

### trans.



### KEEPOUTOF REACH OFCHILDREN 

# CAUTION See Back Panel For Additional Precautions

Manufactured 

### by: LG 

### Life SCiences, Ltd. 

### 20 Voido-dong Youngdungpo-gu Seoul, Korea
EPA Reg. #71532-7 EPA Est. #71532-KOR-1 

### Net Contents: 110 Ibs. Total 100.0%

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PRECAUTIONARY STATEMENTS Hazards to Humans and Domestic Animals 

# CAUTION Harmful if swallowed or absorbed through skin. Causes moderate eye irritation. Avoid contact with eyes, skin or clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals. Wash thoroughly after handling. 

### Environmental Hazards This product is extremelytoxic to fish. Keep out of lakes, streams, ponds, tidal marshes or estuaries. Do not contaminate water by cleaning of equipment or disposal of wastes. Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA. 

### Physical and Chemical Hazards Do not use or store near heat or open flame. 

### First Aid If Swallowed: Call a poison control center or doctor immediatelyfortreatment advice. Have person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by the poison control center or doctor. Do not give anything by mouth to an unconscious person. 

### If on Skin or Clothing: Take off contaminated clothing. Rinse skin immediately with plenty of waterfor 15-20 minutes. Call a poison control center or doctor for treatment advice. 

### If in Eyes: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a pOison control center or doctorfor treatment advice. 

### User Safety Recommendations Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet. 

### DIRECTIONS FOR USE It is a violation of Federal lawto use this product in a manner inconsistent with its labeling. 

### STORAGE AND DISPOSAL Prohibitions: Do not contaminate water, food or feed by storage or disposal. Open dumping is prohibited. Do not reuse empty container. 

### Storage: Keep container closed when not in use. Do not store near food or feed. Protect from freezing. In case of spill or leak on floor or paved surfaces, soak up with sand, earth or synthetic absorbent. Remove to chemical waste area. 

### Pesticide Disposal: Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste representative of the nearest EPA Regional Office for guidance. 

### Container Disposal: Triple rinse (or equivalent): then offer for recycling or reconditioning or puncture and dispose of in a sanitary landfill, or by other procedures approved by state and local authorities.



### 2

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Formulators using this product are responsible for obtaining EPA registration for their formulated product which may be labe,led for the use patterns as found listed on this label. ONLY FOR FORMULAT!ON INTO AN INSECTICIDE FOR THE FOLLOWING USES: TERRESTRIAL NON-FOOD USE* AND DOMESTIC OUTDOORS. FOR THE CONTROL OF MOSQUITOES, GNATS, BITilNG AND NON-BITING MIDGES, BLACKFLlES, DEERFLIES AND OTHER BITING FLIES. * EXCEPTION: This product may be used to formulate mosquito control products that are labeled for application over growing crops and range grasses that have established tolerances for permethrin. CONDITIONS OF SALE AND LIMITATION OFWARRANTY AND LIABILITY NOTICE: Read the entire Directions for Use and Conditions of Sale and limitation of Warranty and Liability before buying and using this product. If the terms are not acceptable, return the product at once, unopened, andthe purchase price will be refunded. The Directions for Use of this product should befollowed carefully. It is impossibleto eliminate all risks inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended consequences may result because of such factors as manner of use or application, weather or crop conditions, presence of other materials or other influencing factors in the use of the product, which are beyond the control of LG Ufe SCiences, Ltd. or Seller. All such risks shall be assumed by Buyer and User, and Buyer and User agree to hold LG Life Sciences, Ltd. and Seller harmless for any claims relating to such factors. LG Life Sciences. Ltd. warrants that this product conforms to the chemical description on the label and is reasonably fit for the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in accordance with directions under normal use conditions. This warranty does not extend to the use of this product contrary to label instructions, or under abnormal conditions orunder conditions not reasonably foreseeable to or beyond the control of Seller or

### lG Life Sciences, Ltd. and Buyer and User assume the risk of any such use. Tothe extent permitted 

### by law, LG Life Sciences, ltd. MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT AS STATED ABOVE. To the fullest extent permitted by law LG life Sciences, Ltd. or Seller shall not be liablefor any incidental, consequential orspecial damages resulting from the use or handling of this product. TO THE EXTENT PERMITTED BY LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER, AND THE EXCLUSIVE LIABILITY OF LG LIFE SCIENCES, LTD. AND SELLER FOR ANY AND ALL CLAIMS, LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OFWARRANTY, CONTRACT, NEGLIGENCE.TORT, STRICT LIABILITY OR OTHERWISE) RESULTING FROM THE USE OR HANDLING OFTHIS PRODUCT, SHALL BE THE RETURN OFTHE PURCHASE PRICE OFTHE PRODUCT 

### OR, AT THE ELECTION OF 

### lG LIFE SCIENCES, LTD. OR SELLER, THE REPLACEMENT OF THE PRODUCT. LG Life Sciences, Ltd. and Seller offer this product, and Buyer and User accept it, subjecttothe foregoing conditions of sale and limitations of warranty of liability, which may not be modified except by written agreement Signed by a duly authorized representative of LG Life Sciences. Ltd.

3

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Mr. Lawrence A. Miller 

## JUL 2 7 2005 Agent for LG Life Sciences Ltd. 115 Obtuse Hill Brookfield, Connecticut 06804 Dear Mr. Miller: Subject: Amendment- designate use over crops with tolerances LG Permethrin Technical PH Insecticide EPA Registration Number 71532-7 Your submission dated May 5, 2005 The amendment referred to above, submitted in connection with registration under FIFRA section 3 (c) (7) (a), is acceptable provided that you: 1. Submit and/or cite all data or other material required for registration/reregistration of your product under FIFRA section 3(c) (5) or FIFRA section 4 when the Agency requires all registrants of similar products to submit such data. 2. Make the labeling changes listed below before you release the product for shipment bearing the amended labeling: a) Delete**~In** 

### No event shall LG Life Sciences, Ltd. or seller be liable for any incidental, consequential or special damages resulting from use or handling of this product." This statement is overly broad and implies buyer has no legal right to recover damages from manufacturer and is unacceptable under statutory and regulatory standards. we recommend revising it to read "To the fullest extent permitted by law LG Life Sciences, Ltd., Inc or Seller shall not be liable for any ... etc." or " It is LG Life Sciences, Ltd. intent that in no case shall LG Life Sciences, Ltd. or Seller be liable

... etc. n •

## 3. Submit three (3) copies of your final printed labeling before you release the product for shipment. If these conditions are not complied with, the registration will be subject to cancellation in accordance with FIFRA section 6 (e)

. Your release for shipment of the product constitutes acceptance of these conditions. A stamped copy of the label is enclosed for your records.

Enclosure Sincerely,
George T. LaRocca Product Manager 13 Insecticide Branch Registration Division (7505C)

# LG PERMETHRIN TECHNICAL PH INSECTICIDE
AN INSECTICIDE FOR FORMULATING USE ONLY 

### FOR FORMULATION OF MOSQUITO CONTROL PRODUCTS AND ULVMOSQUITO CONTROL AGENTS.

ACTIVE INGREDIENT: 

### AOtEPTED wtth COllWENTS In EPALettet- DIded


# , JUL 2 7 2005

*Permethrin

...................................................."

......................................................... 95.2% OTHER INGREDIENTS:.....................

.................................................................................... 4.8'%

•(3-Phenoxyphenyl)meth

### yl(±) cis,trans-3-(2,2dichloroethenyl)- 2,2-dimethylcyclopropanecarboxylate cis/trans ratio: min. 35% (±) cis and max. 65% (±) trans.



### KEEP OUTOF REACH OF CHILDREN 

# CAUTION See Back Panel For Additional Precautions

Manufactured by: LG Life SCiences, Ltd. 20 Vaido-dong Youngdungpo-gu Seoul, Korea
EPA Reg**#71532~7** EPA Est. #71532-KOR-1 

### Net Contents: 110 Ibs. Total 100.0%

### PRECAUTIONARY STATEMENTS Hazardsto Humans and Domestic Animals 

# CAUTION Harmful 

### if swallowed orabsorbed through skin. Causes moderate eye irritation. Avoid contact with eyes, skin or clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals. Wash thoroughlyafter handling. 

### Environmental Hazards This product is extremelytoxic to fish. Keep out of lakes, streams, ponds, tidal marshes or estuaries. Do notcontaminate water bycleaning of equipment or disposal of wastes. Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior

### to discharge. Do not discharge effluent containing this productto sewer systems without previously notifying the local sewagetreatment plant authority. For guidance contact your StateWater Board or Regional Office of the 

### EPA. Physical and Chemical Hazards Do not use or store near heat or open flame. 

### First Aid If

### Swallowed: Call a poison control center

### or doctor immediatelyfor treatment advice. Have person sip a glass 

### of water if able to swallow. Do not induce vomiting unless told to do so bythe poison control center ordoctor. Do not g1ve anything by mouth 

### to an unconscious person. Ifon Skin 

### or Clothing: Take off contaminated clothing. Rinse skin immediatelywith plenty of water for 

### 15-20 minutes. Call a poison control center ordoctorfor treatment advice. 

### Ifin 

### Eyes: Hold eye open and rinse slowly and gentlywith water for 

### 15·20 minutes. Remove contact lenses, 

### if present, afterthe first 5 minutes, then continue rinsing eye. Call a poison control center or doctorfor treatment advice. 

### User Safety Recommendations Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet. 

### DIRECTIONS FOR USE It is a violation of Federal lawto use this product in a manner inconsistent with its labeling. 

### STORAGE AND DISPOSAL Prohibitions: Do not contaminate water, food orfeed by storage or disposal. Open dumping is prohibited. Do not reuse emptycontainer. Storage: Keep container closed when not in use. Do notstore nearfood

### or feed. Protect from freezing. In case of spill or leak on floor or paved surfaces, soak up with sand, earth 

### orsynthetic absorbent. Remove to chemical waste area. 

### Pesticide Disposal: Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, orthe Hazardous Waste representative of the nearest EPA Regional Office for guidance. 

### Container Disposal: Triple rinse 

### (or equivalent): then offer for recycling or reconditioning or puncture and dispose of in a sanitary landfitl, or by other procedures approved 

### by state and local authorities.



### 2Formulators using this product are responsible for obtaining EPA registration for their formulated product which may be labeled for the use patterns as found listed on this label. ONLY FOR FORMULATION INTO AN INSECTICIDE FOR THE FOLLOWING USES: TERRESTRIAL NON-FOOD USE* AND DOMESTIC OUTDOORS. FOR THE CONTROL OF MOSQUITOES, GNATS, BITING AND NON-BITING MIDGES, BLACKFLlES, DEERFLIES AND OTHER BITING FLIES. 

### * EXCEPTION: This product may be used to formulate mosquito control products that are labeled for application over growing crops and range grasses that have established tolerances for permethrin. Do not use this product to formulate products intended torTerrestrial Food Crops, Aquatic Uses, Greenhouse Uses, Forestry or Indoor Uses. CONDITIONS OF SALE AND LIMITATION OF WARRANTY AND LIABILITY NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and Liability before buying and using this product. If the terms are not acceptable, return the product at once, unopened, and the purchase price will be refunded. The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended consequences may result because of such factors as mannerof use or application, weather or crop conditions, presence of other materials or other influencing factors in the use of the product, which are beyond the control of LG Life Sciences, Ltd. or Seller. All such risks shall be assumed by Buyer and User, and Buyer and User agree to hold LG Life Sciences, Ltd. and Seller harmless for any claims relating to such factors. LG Life Sciences, Ltd. warrants that this product conforms to the chemical description on the label and is reasonably fit for the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in accordance with directions under normal use conditions. This warranty does not extend to the use of this product contrary to label instructions, or under abnormal conditions or under conditions not reasonably foreseeable to or beyond the control of Seller or LG Life Sciences, Ltd. and Buyer and User assume the risk of anysuch use. Tothe extent permitted by law, LG Life Sciences, Ltd. MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT AS STATED ABOVE. In no event shall LG Life Sciences, Ltd. or Seller be liable for any incidental, consequential or special damages resulting from the use or handling of this product. TO THE EXTENT PERMITTED BY LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER, AND THE EXCLUSIVE LIABILITY OF LG Life Sciences, Ltd. AND SELLER FOR ANY AND ALL CLAIMS, LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) RESULTING FROM THE USE OR HANDLING OFTHIS PRODUCT, SHALL BE THE RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF LG Life Sciences, Ltd. OR SELLER, THE REPLACEMENT OFTHE PRODUCT. LG Life Sciences, Ltd. and Seller offerthis product, and Buyer and User accept it, subject to the foregoing conditions of sale and limitations of warranty of liability, which may not be modified except by written agreement signed by a duly authorized representative of LG Life Sciences, Ltd.



### 3PI_6e,e.d, 'Dn ",vente befD", 'fDFm. Form OMB No, 

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.. amir_ 2-2B-95



### , United States 

# §Registration**OPPldantifierNu~r** 

# &EPA Environmental Protection Agency 

### v Amendment Washington. DC 20460 

### Other Appl

.....:...- for II

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# . ..**'""~~'U"** 

## .**~** II 1. Company/Product Number 2. EPA Product Manager 3. Proposed Classification 

### 71532-7 G. LaRocca DNone D Restricted 4. Company/Product (Name) PM'



### LG Permethrin Technical PH 

### 13 5. Name and Address of Applicent /Include ZIP Code) 

### 6. Expedited Reveiw. In accordance with FIFRA Section 3(c)(3) 

### LG Ufe Sciences, Ltd. c/o BIOLOGIC, Inc. (b)(i). my product is similar or identical in composition and labeling 

### 115 Obtuse Hill Road to: 

### EPA Reg. No. 

### 8329-66 Brookfield, CT 06804 

# D Check ifthis is 8 n8Waddress 

### Product 

### Name 

### Clarke Permethrin Technical

# ~ Amendment
- EXplain below.**S~tiOll** 

### U 

# U Final printed labels in repsonse to Agency letter dated 

# 0 Resubmission in response to Agency letter dated 

# D "Me Too· Application. 

# D Notification
- Explain below. 

# D Other
- Explain below. 

### Explanation: Use additional pagels) if necessary. (For section I and Saction II.) This amendment is to add language to allowthe use ofthis product by formulators having end-use products labeled for application overcertain agricultural crops and range grasses (e.g. those cropsthat have established permethrin tolerances). In addition, the label has been revised to make it consistent with similar permethrin technical products intended toformulate mosquito adulticides. The text added has been underlined and the deleted text has been lined through. This action will not fall within scope of PRIA.

co. .:, 

### III ,,",",,""VII 1 Material Thl. Product WiD Be

.. __,._..._ In: Child-Resistant Packaging Unit Packaging Water Soluble Packaging 2. Type of Container BYes BYes 

# B Yes

# [;r~ No No Plastic No Glass 

## * Certification must If ·Yes· No. per If ·Yes· No. par Paper Unit Packaging wgt. container Package wgt container Other (Specify) 

### be submitted I 

### !3. Location of Net "v

........Q Information 4. Size(s) Retail Container**15~**LOCjtiOn of Label Directions



# l J Label 

# l 

# J Container 6. Mannar in Which Label is Affixed to Product 

# l J Uthograph 

# 0 Other Paper.Ptlued Stenclild

### Section 

## IV 1 Contact Point 

### ,,.. ,items directlybelowfor of, .I:. Ito btl ••••••,,/ if. " to process this .J Name Title Telephone No. (Include Area Code) Jane M. Miller Agent for LG Life Sciences, Ltd. (203) 740-1200

·! ••• 

### Certification 6. Oat4t 1jliOlition I certifythat the statements I have made on this form and all attachments thereto are true, accurate and complete.

### Recei~ • 

### • 

### ••• I acknowledge that any knowlinglly false or misleading statement may be punishable by fine or imprisolVTlent or 

### (SU1nDed) both under applicable law. 

## •

.2.

### C::'n. ••• ,-,yo 3. Title 

# ..... :

# . • 

## ••

# '.'(\L~ I\J\).**~** 

# .**~** Agent for LG Life Sciences, Ltd. 

### •

### •••• • 

## •• • • 

## • • 

## •• 4. Typed'NanJ 5. Date 

### •••• ••••• 

## • 

## • Jane M. Miller 

### May 5,2005 •

### •••• 

## •••••

••••

## • EPA Form 8570-1 IRev. 3-941 Previous editions are obsolete. Whit •• EPA File Copy (origin'" 

# yen..**~AppIlCMt** Copy 

## •• 

## •

### May5,2005

Mr. George T. LaRocca ProductManager, PM Team 13 hlsecticideBranch Registration Division (7505C) Office ofPesticide Programs U.S. Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 SUBJECT: LGPermethrinTechnical PHInsecticide; EPAReg. No. 71532-7.

DearMr. LaRocca: This is in further**ref~rence** 

### to ourmost recent telephone conversation regarding the above subject. During that discussion, you advised us that it was not possibleto make the proposed labeling changes by notification. With this letter, LG Life Sciences Ltd. hereby submits a label amendment for its "LGPermethrin Technical PHInsecticide"; EPAReg. No. 71532-7 to allow use ofthe technical grade product by those formulators having end-useproductslabeled for application overcertain agricultural crops andrange grasses 

### (e.g. those crops thathave establishedpennethrintolerances). In addition, we are suggestingremoval ofthe current use restriction to accommodatethis amendment, and to make this label consistentwith otherpermethrintechnical gradeproducts intended to formulate mosquito adulticides 

### (e.g. "ClarkePennethrinTecImical Insecticide"; EPAReg. No. 8329-66). Because anumber offormulators have amendedtheir end-useproductsto allow overspraying certain crops and range grasses, theyhave stopped using LG'sproductbecause ofthe current use restriction. Forthis reason, we are kindlyrequesting an expeditious review and approval ofthis label amendment so that LG can resume its nOlmal business activities. We are enclosing an application for a pesticide amendment, as well as three (3) copies ofthe draft labeling for your review and consideration.

e to call me at (203) 740-1200 

### if!can be ofany assistance.

ence A. 

### Miller ipal nt for LGLife Sciences, Ltd.

115 Obtuse Hill· Brookfield, Connecticut 06804· USA Voice: 203.740.1200· Fax: 203.740.1220· Email: Imiller@biologicconsulting.com 

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## • • •••••UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, 

### D.C. 20460



### BIOLOGIC,INC. 

### LG LIFE SCIENCES,LTD. 

## 115 OBTUSEHILL ROAD BROOKFIELD, CT 06804- May 11,2005

PRODUCTNAME: LGPERMETHRINTECHNICALPH 

### COMPANYNAME: LGLIFE 

### SCIENCES, LTD. EPAFILE SYMBOL: 71532-7 EPARECEIPTDATE: 

### 05/09105 

### SUBJECT: RECEIPTOFAMENDMENT DEARREGISTRANT: OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES



### TheOffice ofPesticideProgramshasreceivedyourapplicationfor anamendmentand

## it 

## has passed

## an administrative screenforcompleteness. Duringthe

### initial screenwedeterminedthattheapplication appearsto qualify forfast track review. Thepackagewill nowbeforwardedtotheProductManagerforreviewto determineits acceptabilityfor fasttrack status. 

## If

youhave any questions, please contactRegistrationDivision, RiskManagementTeam 13,at (703) 305-6100. Sincerely, 

# I.j. 

# lkP1J.uFrontEndProcessingStaff InformationServicesBranch InformationResources and ServicesDivision**-------~-----~--------------**