DEQ-CFW_00021512

From: Culpepper, Linda [/O=EXCHANGELABS/OU=EXCHANG[ADMINISTRATIVE GROUP
(FYD|BOHF2]SPDLT)/CN=REOP|ENTS/CN=73D475CBAE324A29B87E171IDC9A79C5-UNCULPEPPER]
Sent: 6/22/I0I77:I6:I1PW1
To: Culpepper, Linda [/b=ExchanXeLabs/ou=[xchangeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=73d475cbae3Z4aI9687e171Idc9a79c5'|mcu|pepper]
Subject: Notes CBI
Location: Conf.cuU
Sta rt: 6/22/20176:00:00PK8
End: 6/22/20176:30:00PK8
Show Time As: Busy
Don Sadowsky lead most of the EPA discussion. Dr. Amy Risen lead for DHHS and I lead for DEQ with Bill Lan
Jessica Barkas will be our point person at EPA. Need to keep Carol Kemker informed. I
EPA has new legislation from last fall to implement in TSCA regarding Confidential Business Information (CBI).
They are working onguidance and this isearly inthe game. Before, they had toask the company for consent
toallow others tosee information. Now they are developing procedures toshare information for purposes of
1) Responding to a release and 2) permitting. ( Ref. 14.d.5 )
Questions onwho will see kand why ?
DHHS — to see health study information to make informed decisions with EPA on appropriate health advisory
levels
DEQ— the same, and to evaluate NPIDES permit compliance and renewal provisions, and to ensure we are
sampling
at the appropriate areas.
EPA considers those different needs. The actions torespond tothe release may beable tobecleared more quickly.
Will need to provide who will seethe information, why they need to see it and what control measures we will have in
place
to protect the information. Will be lengthy process. May need each person tosign a CB| agreement.
EPA indicated the health studies should not be confidential.
Task - Jessica is checking to see what can be released that Dr. Riseb does not already have from Sean Gannon at
Cnemoum.
Information regarding production process and volumes may be considered under the permitting aspect, and not allowed
tobeseen
under the need due tothe release. The production information isimportant for permit decisions.
Given [hemouohas been cooperative insharing information todate, N[isgoing toseek aletter from [hemours
allowing NCaccess to
CBI inEPA'spossession.
Tasks — Dr. Risen is going to see if Sean Gannon can get a letter allowing us access, and Shefla/Linda will discuss
this during our
re -scheduled phone call with Michael Johnson this afternoon. Both will get back with each other and
inform EPA of progress.
If the above is not achievable, we will move forward with Statement of Need and individuals.
OEQ-CFVV_00021512