Document JrMbb4zN8O3w6EMD9XqYqB9Ze

Message From: Sent: To: CC: Subject: lcurcio@solutous.com [lcurcio@solutous.com] 10/6/2017 9:22:30 PM Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy]; Ewing, Kevin [kevin.ewing@bracewell.com] lcurcio@solutous.com Re: Follow-Up Thank you Nancy we appreciate your help on this one.. Safe travels. Best regards, Larry Lawrence N. Curcio, LJh.D President The Solutous Group, LLC (T) 919-942-0408 Icurcio&jsolutous. com ------Original message------From: Beck, Nancy Date: Fri, Oct 6, 2017 4:31 PM To: Ewing, Kevin; Cc: lcurcio@solutous.com; Subject:RE: Follow-Up Kevin, Just wanted to let you know we are working through this one. I will be out of the office on travel through next Thursday, and I've asked Jeff Morris, our OPPT Office Director, to follow up with you if we can get it sorted out quickly. Regards, Nancy Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273 ; Ex. 6 ! i___________________________________________ : beck.nancy@epa.gov From: Ewing, Kevin [mailto:kevin.ewing@bracewell.com1 Sent: Wednes day, October 4, 2017 8:59 PM To: Beck, Nancy <BECK.NANCY@EPA.GOV< a=""</BECK.NANCY@EPA.GOV<> Cc: lcurcio@solutous.com Subject: Follow-Up Nancy, Following up on the matter we discussed, a few points of orientation: SNUN filed January' 2017 for use solely in closed systems. Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00040763-00001  Since January, we have responded to several rounds of questions from Staff, mainly premised on exposure concerns that appear inconsistent with closed system use. Staff recently provided two options: o Option 1: Consent order followed by SNUR; the CO would require minimal PPE and conditions, given low exposure concern; however, the CO also would require release testing for yet further modeling by EPA of potential exposure o Option 2: SNUR only; same conditions as CO, except no testing required We are advised that the Option 1 CO could be available quickly, but Option 2 could take many months. We would like to understand: o The likely timetable for Option 2 SNUR. o The basis for requiring testing in Option 1when there is minimal exposure concern and the agency is prepared to make a finding under Option 2, without further testing or analysis, of not likely to present unreasonable risk. Thank you. Regards, Kevin KEVIN EWING Partner kevin.ewing@bracewell.com - I BRACEWELL LLP 2001 M Street NW, Suite 900 |Washington,D.C. 120036-3310 bracewell.com 1profile [download v-card CONFIDENTIALITY STATEMENT This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00040763-00002