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**EPA’s Monitoring**  **Proposal for Manufacturing, Processing, and Formulating Sites**  **8/02/2012**
**Charge :**  To develop an understanding of the sources of and pathways to environmental c oncentrations of D4/D5 in environmental media and biota associated with industrial releases from siloxane manufacturing (M), processing (P), and formulating (F) s ites

. **Monitoring Objective :**  A s ampling strategy should collect monitoring data from the appropriate media at appropriate locations in order to characterize the range of environmental concentrations of D4/D5 around the M, P, F sites. This sampling should also provide information on the effects of several variables on these concentrations. These variables include production and/or throughput volumes of D4/D5, separation technologies, configuration of on

site WWTP and their various treatment efficiencies, plant activity (M, P, F) and geographical location

. With these data, an understanding can be developed of the environmental concentrations of D4/D5 around M , P , F sites to support a national risk assessment for D4 and D5

. **EPA’s Proposal:** Four of the thirteen M, P, F sites associated with the SEHSC directly discharge their wastewater from the site into rivers (see Table 1 below). Seven of the thirteen sites indirectly

discharge (via a POTW) their wastewater into various water bodies (see Table 2 below). EPA agrees with the SEHSC that the four direct discharge sites should be monitored. Additionally, EPA proposes that all the indirect discharge sites be monitored in order to accomplish the stated charge unless there is a scientific basis for excluding monitoring at a facility

. Tables 1 and 2 below identify the direct and indirect discharge sites EPA proposes to monitor.
**Table 1**  **. Direct**  **Discharge Sites Activity**  **Company Facility**  **City, State D4**  **D5 Discharge**  **Receiving Water Body**  Dow Corning Carrollton Plant Carrollton, KY M,F M,F Direct Ohio River Momentive Waterford Plant Waterford, NY M,F,P M,F,P Direct Hudson River

Sistersville Plant Friendly, WV P P Direct Ohio River Wacker Chemical Wacker

Chemical Adrian, MI P P Direct River Raisin2 **Table 2. Indirect Discharge Sites**  **Activity**

**Company Facility**  **City, State D4**  **D5 Discharge**  **On**
**- site**  **WWTP C**  **onfiguration POTW** 

**L ocation**  **& C**  **onfiguration Receiving** 

**Water Body**  Bluestar Silicones Ventura Plant Ventura, CA P F,P Indirect TBD TBD TBD

Dow Corning Greensboro

Plant Greensboro,

NC F,P F Indirect TBD TBD TBD Auburn Plant Auburn, MI F F Indirect TBD TBD TBD Healthcare Industries Mtrls Hemlock, MI F F Indirect TBD TBD TBD Midland Plant Midland, MI P P Indirect TBD TBD TBD Elizabethtown Plant Elizabethtown,

KY P P Indirect TBD TBD TBD Evonik Goldschmidt Hopewell

Plant Hopewell, VA P P Indirect TBD TBD TBD Shin

-Etsu Silicones Shin

-Etsu

Silicones Akron, OH

-- F None TBD TBD TBD Shincor Silicones Akron, OH P

-- None TBD TBD TBD

**Rationale for EPA’s Proposal**  **to Include the Thirteen**  **Direct and Indirect Dis**  **charge Sites:** The environmental releases of D4/D5 from both these direct and indirect discharge M , P , F sites depend upon a number of factors as stated in the monitoring objective

. In order to accomplish the charge stated above, the effect o f these factors on the sites ’ releases of D4/D5 to a POTW and/or to a water body need to be understood, and this is only feasible if all the thirteen direct and indirect discharge sites are monitored.