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Schmit, Ryan [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=7077ECBAC4914A00AD465398F92BBE78-SCHMIT, RYAN] 7/13/2017 4:12:13 PM Culleen, Lawrence E. [Lawrence.Culleen@apks.com]; greg.louer@apks.com Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy] RE: thank you and additional material attached
Larry and Greg, Wanted to check to see if your client planning to submit the additional the material to the docket? The dockets are currently active, and would be good to have this information in there. Could you let me know when you get a chance? Thanks, Ryan (202)564-0610
From: Culleen, Lawrence E. fmailto:Lawrence.Culleen@apks.com] Sent: Wednesday, July 12, 2017 7:08 PM To: Beck, Nancy <Beck.Nancy@epa.gov> Cc: Ringel, Aaron <ringel.aaron@epa.gov>; Louer, Greg <Greg.Louer@apks.com> Subject: thank you and additional material attached
Nancy and Aaron -
Thank you again for meeting with us today. We found the session to be extremely helpful. We will be following up in August with Joel for a more "in depth" session with CCD and the pertinent technical staff with whom we will focus more specifically on some of the "science aspects" of the comments, EPA's risk and economic assessments, and the data WM Barr provided to the Agency with its comments.
In the meantime, because a great deal of the discussion today focused on the lack of technically and economically feasible alternatives to MeCl2 paint strippers, we are sharing with you the attached copy of the Report prepared by Barr Brands personnel in 2017. The Report compares the performance of consumer-use paint stripper products available on the retail market today. The efficacy tests were performed in a manner consistent with the industry standard published by ASTM. Barr's Report also includes an evaluation of alternative formulations that are likely to emerge in the retail (consumer and small business contractor) market if MeCl2 strippers are no longer available at retail. Some information on the prices of retail-sale paint strippers is reflected in the Report, as is very basic information on the flammability of the various products noted in the Report. Of course, Barr's public comments and the technical reports we submitted during the comment period explore these and other facets of the rule in greater depth.
Again, thank you for meeting with the delegation from Barr Brands; we appreciate your time and attention to this important matter.
Larry
Lawrence E. Culleen Partner
Arnold & Porter Kaye Scholer LLP 601 Massachusetts Ave., NW | Washington | DC 20001-3743
Sierra Club v. EPA 18cv3472 NDCA
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ED 002061 00043640-00001
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Sierra Club v. EPA 18cv3472 NDCA
Tier 12
ED 002061 00043640-00002