Document NexVOgGm1Ly35K6gEOgQyD8rg

Message From: Sent: To: CC: Subject: Attachments: Kime, Robin [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=7EF7B76087A6475B80FC984AC2DD4497-RKIME] 2/12/2018 5:52:17 PM ADFoley@Venable.com Lovell, Will (William) [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=3bl50bb6ade640f68d744fadcb83a73e-Lovell, Wil] FW: Following up: Request to meet regarding EO 13777 comments - PCB regulatory reform and burden reduction USWAG PCB mtg request_Dravis_12.05.2017.pdf Hi Allison, I hope you are well. Samantha would be glad to meet with you. Would any of the following dates/times work for your schedule? 2/22 at 1:30 or 2:00 or 2:30 or 3:00 2/23 at 2:00 or 2:30 or 3:00 3/2 at 11:00 or 11:30 3/6 at 3:00 If it helps, I can propose additional dates. Thanks and take care. Robin From: Foley, Allison D. [mailto:] Sent: Monday, January 29, 2018 2:34 PM To: Kime, Robin <Kime.Robin@epa.gov> Subject: Following up: Request to meet regarding EO 13777 comments - PCB regulatory reform and burden reduction Dear Ms. Kime: I'm writing on behalf of the Utility Solid Waste Activities Group (USWAG) to follow up on a letter sent to Ms. Samantha Dravis in December regarding USWAG's comments on Executive Order 13777 (copy of December letter attached). In particular, we request a meeting with Ms. Dravis to discuss specific comments regarding regulatory reform and burden reduction in the context of the federal PCB program administered by EPA under TSCA, and the corresponding regulations set forth at 40 C.F.R. Part 761. Of particular urgency are requests for: Clarification of the PCB disposal regulations at 40 C.F.R. 761.50 to expressly allow for the disposal of all PCB remediation wastes with as-found concentrations of <50 ppm PCB in non-TSCA landfills (see Exhibit A at 10-11); and Modification of the PCB analytical rules throughout 40 C.F.R. Part 761 to expressly authorize the use of the most recent EPA-approved extraction method available for the chemical extraction of PCBs from individual and composite samples (currently the automated soxhlet extraction method, Method 3541, though these methods are constantly evolving and the regulatory text should therefore allow for use of whatever the most current method is at any particular time). We are requesting a meeting to discuss these regulatory amendments which would eliminate unnecessary and costly regulatory burdens and logistical challenges that significantly delay PCB cleanup projects, without any risk-based justification. The requested regulatory changes are consistent with EO 13777 and the objectives of EPA's Smart Sector Initiative as they would not only reduce unnecessary regulatory burden but will improve environmental outcomes by streamlining and accelerating PCB cleanup projects and associated compliance efforts by electric and gas utilities. Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00119118-00001 Please advise if Ms. Dravis has availability for a meeting in the second half of February. Please let me know if you have any questions or need more information from me. Thank you for your attention to this. Best, Allison D. Foley, Esq. |Venable LLP i Z Z E I Z D I f 202.344.8300 |m[ Z I 'I i l K Z j 600 Massachusetts Avenue, NW, Washington, DC 20001 ADFoley@Venable.com | www.Venable.com This electronic mail transmission may contain confidential or privileged information. If you believe you have received this message in error, please notify the sender by reply transmission and delete the message without copying or disclosing it. Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00119118-00002