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Thatcher Company f. For each category of information claimed as CBI, explain with specificity why release of the information is likely to cause substantial harm to your competitive position. Explain the.specific nature of those harmful effects, why they should be viewed as substantial, and the causal relationship between disclosure and such harmful effects. How would your competitors make use of this information to your detriment? g. Do you assert that the information is submitted on a voluntary or a mandatory basis? Please explain the reason for your assertion. If the Company asserts that the information is voluntarily submitted, please explain whether and why disclosure of the information would tend to lessen the availability to EPA of similar information in the future. h. If you believe any information to be a trade secret or trade secrets, please so state and explain the reason for your belief. Please attach copies of those pages with brackets around the text that you claim to be a trade secret or trade secrets. i. State any other information that you deem relevant, including, if pertinent, reasons why you believe that the information you claim to be CBI is not emissions data or effluent data. Please note that you bear the burden of substantiating your CBI claim(s). Conclusory allegations and statements will be given little or no weight in the determination. Information designated as CBI will be disclosed by EPA only to the extent allowed by, and by means of the procedures set forth in, 40 C.F.R. Part 2, Subpart B. If you fail to substantiate your claim that the information you provided to EPA is confidential, it may be made available to the public without further notice to you. Notice is hereby given that, pursuant to 40 CFR § 2.301(h), EPA may disclose CBI that you provide to EPA's authorized representatives, including its contractors,Weston Solutions, for the following reasons: to assist with document handling, inventory and indexing; to assist with document review and analysis for verification of completeness; and to provide expert technical review of the contents of the response. Pursuant to 40 CFR § 2.301(h), you may submit any comments or concerns regarding EPA's disclosure of CBI to the representative identified below. The Company's comments regarding CBI must be postmarked or hand delivered to this office at the address listed below, or emailed to Greg Bazley at bazley.greg@epa.gov,by the 15th working day after your receipt of this letter. You may seek an extension of time to submit your comments to this office,but the request must be made before the end of the 15-day period. Except in extraordinary circumstances, no extension will be approved. Failure to submit your comments within that time will be regarded as a waiver of your confidentiality claim or claims, and EPA may release the information. Enclosed Information Request Please review the enclosed Inspection Report, which includes Section III, Areas of Concern ("AOC"), for your information and response. These AOCs describe conditions observed at the 3