SILOXANES ECA NEGOTIATIONS MEETING

 U.S. ENVIRONMENTAL PROTECTION AGENCY

 1200 CONSTITUTION AVENUE, N.W.

 WASHINGTON, D.C. 20460

 THURSDAY, MARCH 28, 2013

 1:00 P.M.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 2

1 APPEARANCES

2 WARD PENBERTHY

3 U. S. ENVIRONMENTAL PROTECTION AGENCY

4 PAUL LEWIS

5 U. S. ENVIRONMENTAL PROTECTION AGENCY

6 JENNIFER SEED

7 U. S. ENVIRONMENTAL PROTECTION AGENCY

8 STAN BARONE

9 U. S. ENVIRONMENTAL PROTECTION AGENCY

10 CATHY FEHRENBACHER

11 U. S. ENVIRONMENTAL PROTECTION AGENCY

12 DAVID TOBIAS

13 U. S. ENVIRONMENTAL PROTECTION AGENCY

14 STEVE ANDERSON

15 U. S. ENVIRONMENTAL PROTECTION AGENCY

16 JENNY HOPKINSON

17 U. S. ENVIRONMENTAL PROTECTION AGENCY

18 JOE AVCIN

19 U. S. ENVIRONMENTAL PROTECTION AGENCY

20 NHAN NGUYEN

21 U. S. ENVIRONMENTAL PROTECTION AGENCY

22 TODD STEDEFORD

23 U. S. ENVIRONMENTAL PROTECTION AGENCY

24 KAREN EISENREICH

25 U. S. ENVIRONMENTAL PROTECTION AGENCY
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 3

1 ANNE KIM

2 U. S. ENVIRONMENTAL PROTECTION AGENCY

3 DAVID WIDAWSKY

4 U. S. ENVIRONMENTAL PROTECTION AGENCY/OCSPP

5 MARK SELTZER

6 U. S. ENVIRONMENTAL PROTECTION AGENCY/OCSPP

7 CHARLES STAPLES - SETBC

8 TRENT DOYLE - SEHSC/KELLER & HECKMAN

9 LISA DUMARS - MOMENTIVE

10 GENE BROWNING - SHINETSU SILICONES

11 HUGH FLACK - WACKER CHEMICAL CORPORATION

12 KATHY PLOTZKE - DOW CORNING

13 KARLUSS THOMAS - SEHSC

14 PAUL DELEO - AMERICAN CLEANING INSTITUTE

15 RAY LUDWISZEWSKI - GIBSON DONN

16 KRISTEN SMITH - MOMENTIVE

17 BETSY CARLTON - BLUESTAR SILICONES

18 NORIKO SHIBWYA - SHISEIDO AMERICAS CORPORATION

19 ANDY COULOURIS - DOW CORNING

20 LIZ BOWMAN - SEHSC

21 ELLEN MIHAICH - BLUESTAR SILICONES

22 KAREN VAIL - SEHSC

23 WENDY KOCH - EPONZ

24 TRACY GUERRERO - SEHSC

25 CYNTHIA FINLEY - NACWA
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 4

1 SILOXANES ECA MEETING

2 THURSDAY, MARCH 28, 2013

3 1:00 P.M.

4 PAUL LEWIS: Let's get started. Good

5 afternoon my name is Paul Lewis. I'm with the EPA

6 Office of Toxics and this is our ongoing discussion

7 dealing with siloxanes, of course with a consent of

8 agreement. Just in terms of logistics, we're passing

9 out a sign out sheet, sign in sheet. Please list your

10 name here and affiliation and that way we can record

11 the meeting.

12 We also have a transcriber. We'll be

13 having a transcript available for this meeting like

14 we've had for all other meetings. They'll be

15 available in the public docket. The meeting is

16 scheduled from 1:00 to 4:00. We have several agenda

17 items, SEHSC providing a presentation they revised

18 around a modeling plan. An EPA presentation on our

19 outline for risk assessment plan. We'll also be

20 discussing a peer consultation and then in terms of

21 next steps.

22 Let's first go around the room and then

23 we'll identify people on the phone. Ward?

24 WARD PENBERTHY: Ward Penberthy, EPA.

25 JENNIFER SEED: Jennifer Seed, EPA.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 5

1 STAN BARONE: Stan Barone, EPA.

2 CHARLES STAPLES: Charles Staples for

3 SEHSC.

4 TRENT DOYLE: Trent Doyle with Keller &

5 Heckman for SEHSC.

6 LISA DUMARS: Lisa Dumars, Momentive.

7 GENE BROWNING: Gene Browning, Shinetsu

8 Silicones of America.

9 HUGH FLECK: Hugh Fleck with Wacker.

10 KATHY PLOTZKE: Kathy Plotzke with Dow

11 Corning.

12 KARLUSS THOMAS: Karluss Thomas, SEHSC.

13 KATHY FEHRENBACHER: Kathy Fhrenbacher,

14 EPA.

15 MARK SELTZER: Mark Seltzer, EPA.

16 PAUL LEWIS: Around the back.

17 STEVE ANDERSON: Steve Anderson, EPA's

18 Office of General Counsel.

19 PAUL DELEO: Paul Deleo, American

20 Cleaning Institute.

21 RAY LUDWISZEWSKI: Ray Ludwiszewski for

22 Dow Corning.

23 KRISTEN SMITH: Kristen Smith,

24 Momentive.

25 BETSY CARLTON: Betsy Carlton, Bluestar
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 6

1 Silicones.

2 NORIKO SHIBUYA: Noriko Shibuya,

3 Shiseido Americas Corporation.

4 ANDY COULOURIS: Andy Coulouris with

5 Dow Corning.

6 LIZ BOWMAN: Liz Bowman with SEHSC.

7 KAREN VAIL: Karen Vail with SEHSC.

8 WENDY KOCH: Wendy Koch for Eubonic.

9 TRACY GUERRERO: Tracy Guerrero, SEHSC.

10 ELLEN MIHAICH: Ellen Mihaich for

11 Bluestar.

12 JOE AVCIN: Joe Avcin from EPA.

13 NHAN NGUYEN: Nhan Nguyen with EPA.

14 TODD STEDEFORD: Todd Stedeford, EPA.

15 KAREN EISENREICH: Karen Eisenreich,

16 EPA.

17 ANNE KIM: Anne Kim, EPA.

18 PAUL LEWIS: Now on the phone.

19 RUSSEL MAIT: Russell Mait from Evonik.

20 EVE DEVIS: Eve Devis, PCPC

21 FAMIR DESETAN: Famir Desetan, Shiseido

22 Americas Corporation.

23 PAUL LEWIS: Any one else on the phone?

24 Okay thank you and also joining us today is David

25 Tobias from EPA. Before I turn the meeting over to
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 7

1 Ward and his many additional opening remarks, does

2 anyone have any questions in terms of the format for

3 today's meeting? Any other issues of logistics?

4 Okay seeing none, Ward I'll pass it on

5 to you.

6 WARD PENBERTHY: Okay I hope everyone

7 got a copy of our agenda. We'll have a presentation

8 on the current status of the SEHSC's monitoring

9 proposal and then Kathy Fehrenbacher will go over our

10 risk assessment plan. You should have also received

11 an outline of that.

12 Stan Barone here is also available for

13 an agenda item on what this peer consultation meaning

14 and how it's run and then we'll have some wrap up at

15 the end. Karluss are you ready for your presentation?

16 KARLUSS THOMAS: I am.

17 WARD PENBERTHY: Okay are there any

18 comments on the agenda or anything?

19 MARK SELTZER: Do you like to run the

20 show on this end or do you want me to do that?

21 KARLUSS THOMAS: You can do this.

22 MARK SELTZER: I'm sitting next to it.

23 KARLUSS THOMAS: Yes. All right

24 excellent. Well on behalf of SEHSC I'd like to thank

25 the agency again for this opportunity to continue the
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 8

1 discussions and also share with you some more of the

2 details associated with our revised proposal for

3 environmental monitoring for D4. You can go to the

4 next slide.

5 I'm just going to go right into the

6 details associated with the two primary components of

7 the monitoring programs. So, this is both the POTW

8 portion and also the direct discharge portion. What

9 we're looking at now on the screen is a summary of the

10 municipal waste water treatment POTW portion of the

11 monitoring program, and as we indicated in the letter

12 we submitted to the agency back in early February, we

13 have increased the number of POTWs from five to ten

14 sites.

15 What you see on the screen is in terms

16 of the first five is just the types of treatments that

17 we would focus on for the first five that's identical

18 to what was presented in our earlier proposal. What's

19 been added is this piece on sites six through ten,

20 which we have suggested could be associated with

21 indirect industrial discharge, but certainly that's

22 open for discussion.

23 We'd like to hear the agency's thoughts

24 on how we might identify appropriate sites to

25 constitute those additional five sites with respect to
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 9

1 the monitoring parameters those are unchanged from our

2 earlier proposal where we would focus on influent,

3 effluent surface water, bio-solids, sediment and again

4 there would be two monitoring events.

5 So I'll stop there and see if there are

6 any questions or comments on that piece before we move

7 on to the direct discharge piece.

8 WARD PENBERTHY: So just to fully

9 understand this. All the activated sludge facilities

10 are targeted at the high population with low dilution

11 is that right? Yeah.

12 KARLUSS THOMAS: Yes.

13 WARD PENBERTHY: So that means

14 essentially the effluent stream would be a fairly,

15 would be fairly high compared to the receiving body.

16 I mean there'd be a little, okay. So those would be,

17 I guess from our past discussions on almost our worst

18 case--

19 KARLUSS THOMAS: Yes.

20 WARD PENBERTHY: Scenario? Okay. You

21 have one lagoon there?

22 KARLUSS THOMAS: Yes.

23 WARD PENBERTHY: Okay and then, okay

24 then you have by the four indirect discharge sites--

25 KARLUSS THOMAS: Five.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 10

1 WARD PENBERTHY: Five okay good. And

2 before we talked about influent, effluent, bio-solids,

3 sediment and-- Let's see, the surface water. Okay?

4 KARLUSS THOMAS: All right.

5 WARD PENBERTHY: So that's pretty much

6 what we talked about in terms of the monitoring

7 parameters. Were biota considered here? I mean in

8 previous, maybe you'll have a slide on this, but in a

9 previous proposal you had five POTWS for biota?

10 KATHY PLOTZKE: We modified this based

11 on the feedback we got from the last time where you

12 said you were interested in the biota near the

13 industrial discharge sites and not near the waste

14 water treatment plants because we're doing that in our

15 other proposal.

16 WARD PENBERTHY: All right--

17 KATHY PLOTZKE: But, we did previously

18 have biota there.

19 WARD PENBERTHY: Yeah I think you might

20 have misinterpreted it or maybe we misstated that.

21 Obviously we're interested in the biota at the direct

22 discharge sites, but it was also the indirect

23 industrial sites were important to us too.

24 KARLUSS THOMAS: So you are indeed

25 interested in biota around--
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 11

1 WARD PENBERTHY: Certainly at the sites

2 six through ten.

3 KARLUSS THOMAS: Okay. Okay, and the

4 reason that was taken out as Kathy indicated, it was

5 our impression from the last meeting that the agency

6 wasn't interested in that but we certainly had that in

7 our initial proposal.

8 WARD PENBERTHY: Well, maybe Kathy can

9 clarify if it's your understanding as the same as

10 mine.

11 KATHY FEHRENBACHER: Yes.

12 WARD PENBERTHY: Okay. All right any

13 other questions?

14 KATHY FEHRENBACHER: Well, have you

15 given thought to how you would select the POTWs

16 associated with the indirect discharge?

17 KARLUSS THOMAS: We haven't given, we

18 haven't made firm decisions on that. That's something

19 we would certainly be interested in the agency's

20 thoughts around what would be the best way to identify

21 those sites, but we have not made what I would see as

22 firm decisions on that.

23 WARD PENBERTHY: As I recall during the

24 work you all did on conceptual site modeling, did get

25 individuals, so someone got it, was it you Karluss,
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 12

1 got individual site data that could be informative of

2 the loading of those sites that were part of that?

3 KARLUSS THOMAS: Well, we developed the

4 facility release estimates for all of the reworked

5 facilities--

6 WARD PENBERTHY: Right the scenario--

7 KARLUSS THOMAS: Right and those were

8 used to develop a conceptual site models for

9 manufacturers, for processors, and then for the POTWs.

10 WARD PENBERTHY: Right, but you had

11 information on individual loadings from individual

12 plants right? Or individual discharges to come up

13 with that generic piece?

14 KARLUSS THOMAS: Yes, we do have that

15 information.

16 WARD PENBERTHY: So, maybe there would

17 be some way that, well since they're going to a,

18 incorporated into a population's waste water discharge

19 and dilution would also be a factor. Then when we

20 factor in loading, we figure out some way to use site

21 specific data to pick higher loading POTWs.

22 KARLUSS THOMAS: My understanding is

23 that POTWs have a full understanding of where they

24 receive their influents so certainly if a POTW was

25 receiving influent from one or more industrial
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 13

1 facilities you would be able to use that information

2 to target those facilities that had industrial

3 influent.

4 WARD PENBERTHY: Right, but, I was

5 thinking of targeting industrial POTWs that had D4

6 influent and using data that you had, got in your

7 conceptual site modeling development to select what

8 POTWs of those would be best to monitor at. Do you

9 follow?

10 KARLUSS THOMAS: No, I'm not sure our

11 information would allow you to do that. Those

12 facility release estimates were intended more as mass

13 balance exercises.

14 WARD PENBERTHY: Right.

15 KARLUSS THOMAS: To develop the

16 conceptual site models. I don't know that they would

17 allow you to understand releases to specific D4

18 releases to a POTW.

19 WARD PENBERTHY: But, didn't you use

20 that to calculate a generic model? Right? You

21 basically developed an omissions factor based on

22 individual site data correct? Of releases of D4 to

23 wastewater?

24 KATHY PLOTZKE: It's part of the mass

25 balance you do look at what is going through
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 14

1 treatment.

2 WARD PENBERTHY: Correct. So do you

3 follow?

4 KARLUSS THOMAS: No, I'm not sure

5 exactly what you're getting at here.

6 WARD PENBERTHY: Well, obviously we

7 want to pick indirect discharge sites that have D4

8 going to them and from our perspective if you've got

9 everything else here on developed, sort of around a

10 worst case hypothesis. Wouldn't you want to pick the

11 indirect discharge POTW sites based on sort of maximum

12 D4 going to them in the effluent?

13 KARLUSS THOMAS: Well I guess what I

14 would say is to the extent that we have information

15 that allows the agency to select those sites, those

16 POTWs that the agency is most interested in and if the

17 agency has an explicit interest in sites that are

18 receiving influent from industrial facilities. I mean

19 certainly if we have information that would allow you

20 to do that but would it help you to that. We'd be

21 more than willing to work with you on that. I'm not

22 sure I would have access to the details of the data at

23 that point to figure, at this point to figure out

24 exactly how to do it but I know that we would be

25 willing to work with you on doing it.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 15

1 WARD PENBERTHY: All right, well, let's

2 try it a different way. As I recall there were nine

3 indirect discharge sites from SEHSC facilities? Three

4 or four of them dropped out so the remaining five

5 would be those five, correct? Would that make sense?

6 TRENT DOYLE: So, Ward just to clarify.

7 What you're suggesting is on our POTW monitoring

8 portion of the program these additional new sites, the

9 sites six through ten that we proposed that the POTWs

10 would all be servicing essentially SEHSC member

11 indirect discharge--

12 WARD PENBERTHY: Correct.

13 TRENT DOYLE: Indirect dischargers.

14 Hence you want to make certain that the, that the

15 sites that are being picked are those indirect

16 dischargers that purportedly would have the greatest

17 loading?

18 WARD PENBERTHY: Right.

19 TRENT DOYLE: I mean that's, I think

20 that's what you're saying. So, your basically making

21 the assumption that those six through ten would all be

22 sites that are linked directly to SEHSC member company

23 sites and that those sites would in fact be

24 representative of the world of potential indirect

25 dischargers that would have D4 or D5 loading?
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 16

1 WARD PENBERTHY: Correct.

2 KARLUSS THOMAS: That wasn't the intent

3 in selecting or in proposing five additional sites.

4 Again, I'll say we would absolutely be willing to work

5 with you to identify the five sites that are going to

6 best suit your needs but we didn't say five sites

7 because we had five indirect dischargers. That wasn't

8 the logic we just thought we would propose additional

9 sites to allow the generation of a more robust data

10 set to be responsive to the agency's concerns when we

11 last talked about this but you know I can commit to

12 working with you to figure out how to select those

13 five sites.

14 WARD PENBERTHY: Do you have any better

15 ideas right now?

16 KARLUSS THOMAS: I don't, not right now

17 but after we look at the data and after further

18 discussions we might have a better idea but I don't

19 right now.

20 WARD PENBERTHY: Okay.

21 RUSSEL MAIT: Hey Karluss, Russell.

22 I'd like to add something if I may.

23 KARLUSS THOMAS: Sure.

24 RUSSEL MAIT: This is Russell Mait from

25 Evonik. What I'd like to offer is that we certainly
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 17

1 are understanding of the values gained of how D4 moves

2 through so one of the things that I might suggest we

3 look at is industrial facilities that fit the profile

4 for the value chain for D4. We know what industry

5 they might be and I think that would probably be a

6 good place to start. I just don't think selecting it

7 based on membership is appropriate as a driving

8 criteria.

9 WARD PENBERTHY: Okay.

10 RUSSEL MAIT: So these facilities would

11 either be processes or formulators that would fit into

12 that profile.

13 WARD PENBERTHY: Right, it's a

14 processes or formulators yeah we would definitely

15 understand that. So what do you mean by in the value

16 chain? Is that all you mean processes or formulators

17 or is there other--

18 RUSSEL MAIT: But I think, what I'm

19 saying, Ward, is that there are certainly as I looked

20 at what our industry is doing there's something on the

21 order of eleven different industrial categories that

22 we fell into. You might call it by SAP codes, that

23 would certainly be an opportunity to screen in and

24 screen out facilities to fit what you're trying to

25 drive at.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 18

1 Since we've already established that a

2 processor of D4 and a formulator of D4 regardless of

3 whether they're a member of the club or not would fit

4 in the category of processor or formulator.

5 WARD PENBERTHY: Correct, and I'm

6 trying to recall from a conceptual site models that

7 you had, I think the processors had a bigger release

8 factor then formulators. That's almost what you were

9 doing isn't it?

10 KARLUSS THOMAS: I don't remember.

11 WARD PENBERTHY: Okay.

12 KATHY FEHRENBACHER: And what

13 information will you be providing on the industrial,

14 the indirect facilities themselves so that we can

15 understand releases to the POTW to put the monitoring

16 data there into context?

17 KARLUSS THOMAS: I guess our proposal

18 has not changed from the standpoint of the indirect

19 dischargers. Again, and I know we've talked about

20 this in the past I mean our view is that with respect

21 to the need to do a risk assessment and the idea being

22 that what is discharged to the environment being the

23 most relevant to that. I mean our view is not that

24 indirect dischargers would be necessary to get a

25 estimate of environmental releases and bear those to
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 19

1 levels that would elicit an effect on an organism. So

2 I know we're going to talk about that a little bit

3 later when we get into the risk assessment.

4 WARD PENBERTHY: And I think a past

5 sticking point and I'm glad to see this has changed

6 because what the influent to the indirect dischargers,

7 you had a problem with that at previous meetings so

8 I'm taking that as now, you can do that.

9 KARLUSS THOMAS: This is influent into

10 a POTW.

11 WARD PENBERTHY: Correct.

12 KARLUSS THOMAS: Not an indirect

13 discharger.

14 WARD PENBERTHY: All right, good.

15 KATHY PLOTZKE: It's the influent that

16 would represent the industrial input and the general

17 population input.

18 WARD PENBERTHY: Right. Okay.

19 KATHY PLOTZKE: It's not separated--

20 TRENT DOYLE: It's just not apportioned

21 back.

22 KATHY PLOTZKE: We'd be measuring the

23 influent coming into the POTW.

24 WARD PENBERTHY: Right.

25 KATHY PLOTZKE: Which would have
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 20

1 multiple contradictions.

2 WARD PENBERTHY: Right we'd have to

3 think about that. I know before you said that

4 measuring the influent was there, was a CVI concern

5 associated with that.

6 KARLUSS THOMAS: For the direct

7 dischargers. We're going to talk about that in second

8 but you're right we have not proposed influent

9 measurements for the direct dischargers.

10 WARD PENBERTHY: Okay.

11 KARLUSS THOMAS: Okay.

12 KATHY FEHRENBACHER: So do you, I'm

13 sorry one more question. Do you understand enough

14 about the indirect dischargers to identify facilities

15 and POTWs that would be representative of the indirect

16 dischargers and their associated POTWs?

17 KARLUSS THOMAS: I think there is

18 information available that would allow you to make a,

19 some pretty reasonable determinations of that. I know

20 EPA has a database of POTWs, we've got the folks at

21 NACWA around the table who I think certainly would be

22 willing to work with us on that so I think there is

23 information available that would allow you to get at

24 that type of information.

25 KATHY FEHRENBACHER: Okay.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 21

1 WARD PENBERTHY: Any other questions?

2 KARLUSS THOMAS: All right next slide.

3 So, now this is a, again a proposal for direct

4 discharge monitoring and this has not changed from the

5 previous version of our proposal that we've discussed.

6 So there are four member company facilities that have

7 direct releases to surface waters so our proposal is

8 that there would be monitoring at all of those

9 facilities.

10 The parameters that would be monitored

11 here are effluent, so that's what goes to the

12 environment. Surface water, sediment, fish, benthic

13 species, and two monitoring events. And again this

14 portion of the proposal remains unchanged from the

15 previous version.

16 WARD PENBERTHY: Okay, and you were

17 saying this is where you have CVI concerns about the

18 influent?

19 KARLUSS THOMAS: Yes.

20 WARD PENBERTHY: Well, we can

21 accommodate the CVI in this enterprise so that doesn't

22 have to be a concern.

23 KARLUSS THOMAS: Well, but in addition

24 to that I guess there's also some I guess lack of

25 clarity on our part with respect to how that informs a
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 22

1 risk assessment if what you're concerned about is what

2 gets into the environment. We're going to be

3 measuring the effluent so what goes to surface waters

4 so from the standpoint of the influent how does that

5 help inform the risk assessment?

6 WARD PENBERTHY: Well, I think it does

7 give a sense of, that a treatment efficiency and also

8 magnitude of releases.

9 KARLUSS THOMAS: Right, that's

10 certainly possible but again--

11 WARD PENBERTHY: So, basically you're

12 going to benchmark on what are the current releases

13 and if there were a problem and shown in a risk

14 assessment then you would theoretically have a better

15 concept of what, what would need to be done.

16 KARLUSS THOMAS: And I think from the

17 standpoint of a risk assessment if you, after

18 completion of a risk assessment and you did identify

19 that there's a problem I think that would be

20 consistent with my understanding of the way the agency

21 has typically done risk assessments where you do a

22 screening assessments, a screening assessment if there

23 is a problem then you move on to doing those types of

24 evaluations but if there is no problem identified in

25 the screening assessment then it's not our view that
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 23

1 that type of thing would be pursued.

2 I think certainly from the standpoint

3 of doing the screening assessment you wouldn't

4 ordinarily look for that type of information or at

5 least certainly that's not my understanding.

6 WARD PENBERTHY: Well, if we were doing

7 monitoring we'd be looking for it so yes.

8 KATHY PLOTZKE: One thing to maybe

9 clarify is the effluent is really what is released to

10 the environment so you're going to get that, you're

11 going to understand that potential release for these

12 facilities to the environment.

13 WARD PENBERTHY: Right.

14 KATHY PLOTZKE: So, that would be there

15 in the outline.

16 WARD PENBERTHY: Right.

17 KATHY FEHRENBACHER: But, we wouldn't

18 have that for the indirect is what I'm hearing?

19 KATHY PLOTZKE: Right, that is correct

20 because the indirect does not release to the

21 environment. The indirect only releases through a

22 pipe to either a private or municipal--

23 WARD PENBERTHY: So, I think what we

24 want to know is this stuff just going straight through

25 or is it getting treated?
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 24

1 KATHY PLOTZKE: I think the part of it

2 we tried to address with the previous, with the

3 municipal waste water treatment plants. The variety

4 of treatments that you would see, that would allow you

5 to do that because in that case if you go back a

6 slide, we are doing the influent into the POTW and the

7 effluent which will, and actually even the bio-solids.

8 So that's going to give you that

9 information across those different types and one of

10 the reasons you know, we can structure the six to ten

11 as well with the industrial input but other factors as

12 well if there's additional treatment types or-- That's

13 why we left it kind of six to ten additional with

14 industrial, you could play with those other factors if

15 there's something more that you want to understand

16 around treatment pipes.

17 MARK SELTZER: Should we go forward?

18 KATHY PLOTZKE: Yeah but I think

19 that's, this is the part I think that will give you

20 the information around different treatment types.

21 That's why we tried to structure it across the various

22 treatments that you have within the United States so

23 that we would get that main route.

24 WARD PENBERTHY: And the presumption is

25 that the, this data would be representative of the
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 25

1 industrial treatment?

2 KATHY PLOTZKE: Yeah I mean, yeah

3 you've got the whole variety there of different types

4 of treatments.

5 WARD PENBERTHY: Let's go back to the

6 other slide now.

7 PAUL LEWIS: When you talk about the

8 fish, how many fish specifically are we talking about?

9 KATHY PLOTZKE: That basically would be

10 what we would call like a marker fish or you know, a

11 particular fish that would be representative. One of

12 the things that is critical is to look at the specific

13 environment, identify the appropriate species that

14 would be considered a marker fish of that area.

15 PAUL LEWIS: Okay.

16 KATHY PLOTZKE: Same thing the benthic

17 species could differ from one site to the other and

18 that one particular one because it may be, it's what's

19 natural to that area.

20 WARD PENBERTHY: So, are all these

21 activated sludge? Facilities?

22 KATHY PLOTZKE: We'd have to look that

23 up.

24 WARD PENBERTHY: Well, I mean that's a

25 basic question to know if the other data would be
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 26

1 representative.

2 KATHY PLOTZKE: Yeah I just don't have

3 that. We do have that information but we just don't

4 have it in front of us.

5 KARLUSS THOMAS: Would having that

6 information satisfy the agency that the information on

7 influent would not be necessary to assess what's going

8 to the environment?

9 WARD PENBERTHY: I don't know, I don't

10 think so but-- I mean I think there's a way to hand

11 the agency ideas but I don't understand the concern.

12 So if you're worried about competitive advantage or

13 whatever that doesn't have to be an issue.

14 KARLUSS THOMAS: Well, that's not the

15 only part of it. Again the other is the need for that

16 information for a risk assessment. I think Kathy

17 articulated it much better than I did with respect to

18 getting a variety of information on treatment

19 efficiencies. You'll get that with the indirect, the

20 POTW portion but with respect to the direct

21 dischargers, what's most relevant I think in terms of

22 a risk assessment is what gets into the environment,

23 how we're going to monitor that development.

24 WARD PENBERTHY: We just want to have

25 an understanding of the effectiveness of the waste
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 27

1 water treatment being included.

2 GENE BROWNING: Well, each one of those

3 do have NPDES permit under the Clean Water Act so we

4 do have performance criteria that we have to meet all

5 the time. Now it might not list D4 which in our

6 permits it does not.

7 WARD PENBERTHY: What's it going to be

8 total organic carbon or something like that?

9 GENE BROWNING: Yeah suspended solid,

10 PH, there's a variety you know--

11 WARD PENBERTHY: Yeah but those aren't12 -

13 GENE BROWNING: There's a handful of

14 things that--

15 WARD PENBERTHY: Those aren't

16 representative of the efficiency that we're looking

17 at.

18 GENE BROWNING: But nor does the Clean

19 Water Act ask for my efficiency. It just bases the

20 permit on discharge limit.

21 WARD PENBERTHY: No, I understand that

22 but we're interested in D4 not just the total

23 discharge.

24 KARLUSS THOMAS: Ward, has the agency

25 expressed an interest in treatment efficiencies for
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 28

1 other materials that are being assessed as part of the

2 work plan?

3 WARD PENBERTHY: You know, I don't know

4 if there's a, Kathy probably has a better idea.

5 KATHY FEHRENBACHER: Well, I mean we

6 typically consider it an act when we're conducting a

7 risk assessment. We typically have information or

8 develop information. In this case we would be looking

9 for information from industry on the releases from an

10 industrial, manufacturing, processing, formulating

11 facility.

12 We have information on streams and

13 stream flows. We have to know or have data bases that

14 we can search to identify where a facility discharges

15 and then we generally track those releases down

16 stream. We also have information or can estimate in

17 this case we would like to have measured information

18 that would enable us to understand treatment

19 efficiency but that's a very important part of

20 constructing an exposure assessment that feeds into a

21 risk assessment and all of that information is

22 important to us not only in developing a risk

23 assessment but in considering any follow up risk

24 management actions that might need to be taken.

25 WARD PENBERTHY: I think where you see
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 29

1 this the most is in TRI where they, you have releases

2 to a POTW and then the treatment type, the efficiency

3 and that would in this case if D4 was a TRI chemical

4 you would get all that data for both indirect and

5 direct sites. So, I mean I think our interest here

6 would be consistent with those kind of information

7 needs.

8 KARLUSS THOMAS: And as you know, our

9 proposal was developed with the understanding that the

10 information would be used to inform an exposure

11 evaluation that would be used for a risk assessment.

12 So certainly while those other things might be of

13 interest those weren't considerations when we

14 developed the proposal because what we were being

15 responsive to was the agency's expressed desire to

16 develop a risk assessment.

17 WARD PENBERTHY: Right, okay. Right,

18 well I think we both expressed our interest. Do you

19 have any other questions Kathy?

20 KATHY FEHRENBACHER: Yes, I was also

21 going to ask about the two monitoring events because

22 we've not talked much about that. What is your

23 thinking and what's your plan for the two monitoring

24 events?

25 KATHY PLOTZKE: We haven't had a strict
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 30

1 sort of structure to them. We wanted to have some

2 flexibility. They could be together or apart. They

3 could be at different seasons so it's just dependent

4 upon some of the ultimate goals that you wanted. So

5 we can be flexible and when those are set up.

6 KATHY FEHRENBACHER: And, could you

7 tell us a little bit more about the benthic species

8 that you are considering here?

9 KATHY PLOTZKE: Yeah, we haven't

10 specifically looked at the specific species but that's

11 one of the things even in our voluntary program called

12 the Product Stewardship Initiative, we go into the

13 site, basically do research on the site. The species

14 that are there, the food chain so that we understand

15 the dynamics and then select the appropriate species

16 based on that information. So we would need to that

17 pre-work at each one of those sites to understand that

18 food web that's there so that we would select then the

19 appropriate benthic species and marker fish. That's

20 the way we've managed it in our other current sites

21 like in Lake Pepin and we should now have some program

22 in Lake Champlain in Vermont as well.

23 KATHY FEHRENBACHER: And, how many

24 species are looking at for, I've heard you talk about

25 a marker fish which I am interpreting as one species
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 31

1 and how about for the benthic species?

2 KATHY PLOTZKE: It would be one species

3 for each one of those.

4 KATHY FEHRENBACHER: Okay.

5 JENNIFER SEED: But, not noting if they

6 are the same?

7 KATHY PLOTZKE: Right, site dependent

8 yeah.

9 WARD PENBERTHY: So, when you get down

10 to it then we would have biota at these four sites and

11 did we agree to biota at the other indirect sites?

12 The six through ten sites?

13 KATHY PLOTZKE: And just to be clear so

14 that biota would come from, not from the indirect

15 sites it would come from municipal waste water, after

16 municipal waste water treatment plant sites because

17 there is no biota, it's through a pipe so--

18 WARD PENBERTHY: Around the POTW that

19 would be serving indirect discharge sites.

20 KATHY PLOTZKE: Okay, just wanted to

21 make sure.

22 WARD PENBERTHY: Yeah okay, great.

23 Well that would be nine sites total essentially for

24 biota. If they're there I guess. Okay.

25 KATHY FEHRENBACHER: May I, I'm sorry I
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 32

1 keep coming back to the indirect discharge sites

2 because the influent into the municipal POTW is going

3 to include the industrial indirect discharge as well

4 as all of the consumer so would we be able to

5 apportion the discharge or the influent that pertains

6 to the indirect dischargers as you're proposing to

7 collect that data?

8 KARLUSS THOMAS: Our proposal was not

9 designed to do that. I mean I think that would be

10 what we would consider more associated with risk

11 management than risk assessment. Again our proposal

12 was designed to allow an exposure evaluation for a

13 risk assessment. That's not my understanding that you

14 typically try to apportion environmental loadings to

15 do a risk assessment.

16 Certainly if a risk assessment found a

17 potential problem that's something that you would

18 likely undertake but at this point that's not

19 necessary and I don't think, and certainly our

20 proposal wasn't designed to do that.

21 KATHY PLOTZKE: And if you go back one

22 more slide, let's go back there, I mean one of the

23 things we're trying to do is put some flexibility so

24 we have with a total number of ten sites you could

25 structure it so that some of them don't have the
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 33

1 industrial load coming in. So you could do a

2 comparison at the municipal with ones that have the

3 industrial, ones that don't. That's really actually

4 getting into the environment.

5 So if you're monitoring the POTW and

6 you're monitoring the effluent that's coming out, you

7 know you could look at one that has industrial feed

8 into it and general population versus one that just

9 has general population. So we could try to structure

10 with the ten number, you know across those variables.

11 WARD PENBERTHY: Okay.

12 TRENT DOYLE: Ward just to clarify, I

13 think it's something I heard you say, I want to make

14 sure we're on the same page here but you were talking

15 about the number of sites that we'd be doing benthic

16 species at, biota monitoring at our, and under our

17 current proposal we're just proposing that at the four

18 direct discharge sites.

19 WARD PENBERTHY: Right.

20 TRENT DOYLE: Okay.

21 WARD PENBERTHY: Before your proposal

22 was the four plus five additional and so we want to

23 take you up on your previous offer.

24 TRENT DOYLE: Okay I'm saying you can

25 want that and we can decide if you know, that's going
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 34

1 to be-- But I just want to make sure you're clear on

2 our current proposal.

3 WARD PENBERTHY: Right, but if you

4 offered it before why wouldn't you be willing to do it

5 now?

6 KARLUSS THOMAS: I'm not saying we're

7 not I think I just said--

8 TRENT DOYLE: Yeah, I just said we're

9 just not committing to that right now. I just wanted

10 to make sure we were clear.

11 WARD PENBERTHY: Okay. All right,

12 gotcha. I'm sorry.

13 KARLUSS THOMAS: Any more questions on

14 this before we go to the next slide? Which is my last

15 I think. So I guess just to sum up I just want to

16 again reiterate that the SEHSC members are committed

17 to this revised proposal. We think as expressed in

18 the letter that we sent the agency last month that the

19 proposal demonstrates the willingness to compromise.

20 We've increased the POTW sites that would be monitored

21 from five to ten.

22 From the standpoint of our goal for

23 this meeting we have certainly prepared at this point

24 to conclude the ECA negotiations and initiate

25 monitoring. That would certainly be our preference in
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 35

1 terms of an outcome at this meeting and we also thing

2 concluding the ECA negotiations would allow the D4

3 work plan assessment to proceed according to the EPA

4 schedule.

5 We think to continue a protracted

6 negotiation or to add other elements to the process

7 that weren't initially envisioned in the ECA rules

8 would not only delay the process but delay the

9 agency's ability to do the work plan assessment for

10 D4.

11 WARD PENBERTHY: Yeah. You know

12 obviously we have about a month left in this

13 negotiating period so we're, been instructed to get as

14 far along as we can to try to make that happen. So

15 we're just set on doing that but let me review just

16 what the differences are between our two proposals

17 just so they're totally clear.

18 It would appear that we've agreed that

19 monitoring at the direct discharge sites is not going

20 to be an issue and biota monitoring is not going to be

21 an issue there. Our interests were to have the five

22 indirect discharge sites, the best SEHSC monitored it

23 appears that that could be accommodated in your POTW

24 proposal.

25 We are interested in having biota done
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 36

1 there and it seemed to me that you previously agreed

2 to that. So that would be our interest. The big

3 difference then is, after that is taking care of, we

4 were looking at sixteen POTWs, twelve of which would

5 be aggregated sludge and four lagoons. Those would

6 have been selected based on population and receiving

7 stream flow which are, they're two variables.

8 We also had considerations to include

9 in those selection was geography and the organic

10 content of the receiving stream. I have to believe

11 those two additional components can be accommodated in

12 the POTW selection procedure. I think we were looking

13 at multiple fish species that the, in terms of the

14 biota sampling. So that's a little bit different

15 there.

16 KARLUSS THOMAS: When you say multiple

17 did you have a specific number in mind?

18 WARD PENBERTHY: Two or more was where

19 we were. Is that what we are?

20 KAREN EISENREICH: Two fish species

21 representing a lower and higher probative level.

22 WARD PENBERTHY: So those are the

23 essential differences, I mean from my take on it, it

24 seems like we're about 60 to 70 percent in agreement

25 on how things could work. And based on your, just
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 37

1 recent conversations there seems to be a lack of

2 closure on ability of, to understand the contribution

3 of D4 from indirect sites to the POTWs that serve

4 them.

5 Well there's influent but the component

6 deal and then there, I described our differences in

7 biota monitoring. Those don't seem enormous

8 differences but they are differences and the five

9 indirect sites, that's a key interest of ours.

10 KARLUSS THOMAS: When you say the five

11 indirect sites, you mentioned earlier that you thought

12 the addition of the five POTWs might allow you to get

13 the information that would satisfy your needs with

14 respect to the indirect. So now you're saying you

15 still, I just want to be clear on where the agency is

16 on the indirects.

17 WARD PENBERTHY: Well, we think you

18 know, indirect sites can be handled in the POTW mode

19 and suggest it.

20 KARLUSS THOMAS: Okay.

21 WARD PENBERTHY: I guess you're going

22 to think about the biota component of those five sites

23 or I forgot what they were right? And then so, we

24 also need to know the treatment types of the direct

25 discharge sites to really understand it. The POTWs are
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 38

1 going to be representative of that treatment type.

2 GENE BROWNING: Also, on those directs,

3 you know we're similar to a municipal POTW. We do not

4 just treat D4 we are treating sanitary because of our

5 population some might have cafeterias and in some

6 cases you might be treating storm water.

7 WARD PENBERTHY: Right.

8 GENE BROWNING: So, there's a lot of

9 equalization that goes on prior to so I'll just throw

10 that out.

11 WARD PENBERTHY: Right, but there can

12 be differences to. I mean hopefully if they're both

13 there we'd be more acclimated right for D4? So, there

14 is a number of differences that we need to work

15 through. I just want to highlight them. Are there any

16 others? We need to solve? Okay.

17 DAVID TOBIAS: Have you had a thought

18 about what a lot of that means in the overview sense?

19 Do you have one fish out of the river, do you want to

20 talk about that all what your thinking is on the--

21 KATHY PLOTZKE: Yeah, I think that's

22 the project charters that we've incorporated in the

23 original submission is reflective of what we're

24 currently doing it's way beyond one fish.

25 DAVID TOBIAS: No, I wouldn't suggest--
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 39

1 KATHY PLOTZKE: We do, we do, we

2 actually you know, look at it from a statistical

3 perspective and we can certainly share our current

4 monitoring, our voluntary Product Stewardship is into

5 it's third year. So, we've been doing this for three

6 years and then those programs actually are adjusted on

7 a year to year basis based on the previous year

8 information and I think we have a pretty good handle

9 on numbers, numbers of samples, how we collect the

10 sediment.

11 We've worked that out through the

12 voluntary Product Stewardship Initiative so those are

13 pretty robust plans for a, from a monitoring

14 perspective. So, it would be very similar to that.

15 WARD PENBERTHY: Okay, so while there

16 are differences in our monitoring hopes and

17 commitments we are getting closer. That's good. Any

18 other questions from our EPA folks on the-- Are you

19 okay? All right well maybe we should go on to the,

20 thanks for the clarification that helps I know exactly

21 or almost exactly where you guys stand.

22 I guess the next item on the agenda and

23 this might help us further on down the agenda in the

24 next steps was that Kathy was going to discuss and run

25 through our outline for risk assessment plan. And, as
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 40

1 you all know we are planning to do a risk assessment

2 for D4 and clearly it's bearing forth that any

3 monitoring that we develop in enforceable consent

4 agreement contribute meaningfully to the scope and the

5 objectives of that risk assessment.

6 And, obviously the complexity of the

7 issues associated with developing representative D4

8 environmental data are substantial and so if we want

9 to use that data to put into an exposure assessment

10 and then to our risk assessment, obviously we want to

11 be very careful how that monitoring is developed.

12 That's why we hoped to put together a

13 risk assessment plan for D4 and have it peer reviewed,

14 I'm sorry not peer reviewed, have it go through a peer

15 consultation which is more of a feed back type

16 mechanism and we hope that process informs our ECA

17 process but we view it as a separate activity and

18 distinct from our negotiation here.

19 So Kathy why don't you go ahead and--

20 MARK SELTZER: We have extra copies of

21 the outline if folks have not already not come around.

22 Do you need one?

23 KATHY FEHRENBACHER: Okay, I'm not

24 going to go through all of the details, but we thought

25 it would be helpful for you to have an appreciation
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 41

1 for what would be included within a risk assessment

2 that we would deem for, for D4.

3 So we have prepared an outline and a

4 draft of chapter one so the first statement really

5 describes what Ward has been discussing which is our

6 need to perform a nationally representative

7 assessment. The environmental risks associated with

8 D4 and so the assessment should be sufficiently robust

9 and the uncertainties in the risk estimates of

10 sufficiently characterized to support risk management

11 decisions should we identify potential risks of

12 concern.

13 So the assessment is designed to

14 include a quantitative assessment of the probable

15 release pathways of D4 that could contribute to a

16 better understanding of the distribution of

17 concentrations including the high end concentrations

18 in the environmental media.

19 We have developed a number of release

20 pathways that we intend to include within the risk

21 assessment. As you know we are interested in both the

22 direct as well as the indirect discharge including

23 down the drain releases.

24 We believe that the monitoring data is

25 needed on the releases from the industrial sites and
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 42

1 wastewater treatment plants and measured

2 concentrations in environmental media and biota in

3 order to construct that exposure assessment and risk

4 assessment.

5 So, that is really the purpose of the

6 risk assessment that we intend to develop. So moving

7 on to the outline, the first section will be the

8 background and scope. There will be an introduction

9 which describes the release sources and pathways that

10 feed the hazard then we will discuss the scope of the

11 assessment and we're all quite familiar with what that

12 scope is.

13 We will develop a conceptual model and

14 I'll cover that briefly. The next chapter is chapter

15 two which will cover the physical, chemical, and

16 environmental properties. And then chapter three is

17 the environmental assessment. There is one correction

18 under section A, I on life cycle description, we say

19 include peer reviewed literature and that should be

20 non- confidential industries submissions. That was

21 just a typo.

22 Of course, we have access to

23 confidential business information but of course that's

24 protected and is not released so we would not include

25 any confidential information in the risk assessment.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 43

1 The next section is the environmental

2 release assessment and we've talked a lot about the

3 importance of understanding environmental releases

4 from industrial facilities. We for all of these

5 sections would be identifying data gaps and release

6 estimation approaches.

7 The environmental exposure assessment

8 would review the currently available monitoring data.

9 And because we're intending to utilize peer

10 consultation process here we will in the next section

11 on the monitoring strategies proposed, provide the

12 peer consultation panel members with information on

13 the SEHSC proposal and the EPA proposal for the public

14 meetings and our colleges from the risk assessment

15 division will be talking more about that peer

16 consultation process so I'm not going to get into

17 details but--

18 KARLUSS THOMAS: There's just a

19 question on that though not to get into the details

20 associated with peer consultation but just kind of

21 more, a clarification I guess. Ward you'd mentioned

22 that the agency plans to sort of decouple the peer

23 consultation process from the ECA negotiations and my

24 reading of this suggests that the whole risk

25 assessment plan will be provided to the peer
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 44

1 consultation for review. And if that's going to

2 include SEHSC proposal, the EPA proposal how do you

3 decouple it when you're essentially inviting feedback

4 on the, both proposals and I'm just wondering what you

5 do with the feedback if the agreement has already been

6 reached at that point since this is going to be a six

7 to eight month process?

8 WARD PENBERTHY: Right, and you know,

9 obviously, we have heard some concerns about the

10 extension of the ECA process now it's meant to be

11 driven to conclusion so we want to address that so

12 obviously to do that we would need to close on the

13 agreement and, by the end of April theoretically.

14 That's the current deadline.

15 If, if we did have agreement at that

16 time our hope would be that the monitoring strategy

17 that would be in this document as it's provided to a

18 peer consultation plan would be the content of the

19 ECA.

20 That would be the ideal okay? You

21 know, in the event and since they're starting to be

22 rumblings about multiple extensions to the timeline,

23 there are concerns about that. We don't want to have

24 to get a, it would be preferable not to get into a

25 situation where we have, now here's EPA's proposal,
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 45

1 here's SEHSC what do you think is best? Right.

2 So, we prefer not to do that if at all

3 possible so that's why we think this end of April

4 timeframe is very important to put closure on these

5 items that we were just talking about. So that's how

6 it would fit together.

7 LISA DUMARS: So, you're saying if we

8 have a signed agreement that's what feeds this not to,

9 take it's place.

10 WARD PENBERTHY: Correct, if we don't

11 we still have to do a risk assessment we've told

12 everyone in the world we're going to do a risk

13 assessment so we have to have some way to proceed and

14 we'll have to tell people about, this is what we're

15 going to do.

16 TRENT DOYLE: And so if you just kind

17 of play it off that, if in fact we have an ECA and the

18 ECA monitoring program, is what gets put forth in the

19 risk assessment plan so we're going to go out and now

20 ask for, go through a peer consultation and sort of

21 after the fact ask for input from the peer

22 consultation on whether what the agency and industry

23 has agreed to is sufficient in a risk assessment?

24 WARD PENBERTHY: That's correct.

25 That's what we're trying to address the concerns that
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 46

1 you all had about this ECA negotiation right now. So,

2 that's the only way we could, I got to address that.

3 Now maybe I'm getting ahead of myself

4 but there's always a way and a procedure to modify an

5 ECA so in the event peer consultation pointed out some

6 gross deficiencies and whatever monitoring plan was

7 adopted those could be addressed in the modification

8 procedure and if people wanted to. Again, it's a

9 consensus process.

10 TRENT DOYLE: So, basically the process

11 would work such that effectively we have this

12 agreement which is subject to change as it always is,

13 but we're setting forth a distinct process for the

14 purpose of after the fact to evaluate, getting input

15 on whether it's sufficient.

16 WARD PENBERTHY: That's essentially--

17 TRENT DOYLE: No, I just want to make

18 sure that's--

19 WARD PENBERTHY: That would be

20 essentially what would21 TRENT DOYLE: What we're proposing to

22 do.

23 WARD PENBERTHY: Well, I mean we're

24 committed to doing a risk assessment that would be in

25 effect what would happen. And so obviously then both
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 47

1 would have a lot at stake and getting the ECA right

2 because obviously you don't want to spend a lot of

3 money and work real hard at developing data to have a

4 number of expert reviewers say, well that's not quite

5 enough.

6 And we'd almost put a whole lot of

7 energy in developing a risk assessment based on data

8 that's not sufficient so-- Or it could be that this

9 is great, you're doing a fine job and then we're all

10 happy so--

11 TRENT DOYLE: So, if the peer

12 consultation comes back and says, why do you need all

13 of this data period? Then we're going to have a

14 provisional where we can strike the ECA and cut the

15 monitoring?

16 WARD PENBERTHY: Well, I mean it's a,

17 there is in the ECA regs, there is a new data come

18 available, new information that would make

19 modification of the ECA make sense in that, that's the

20 scenario.

21 TRENT DOYLE: Okay.

22 BETSY CARLTON: Ward I have one other

23 related questions, Betsy Carlton Bluestar Silicone.

24 At what point would the information be submitted to

25 the peer, I mean we assume that we, with the same
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 48

1 scenario you're assuming EPA and industry can come to

2 an agreement on the monitoring program? You said

3 that's what would be submitted to the peer group. If

4 we assume we could conclude that might helpful. At

5 what point does it hold sway?

6 WARD PENBERTHY: The study was going to

7 be done--

8 STAN BARONE: We're going to talk about

9 that process--

10 BESTY CARLTON: I'll wait.

11 STAN BARONE: That's relevant.

12 KATHY FEHRENBACHER: Okay, so, the next

13 section, 3C, is the environmental hazard assessment,

14 and we will summarize the hazard of D4 including

15 available eco-toxicity studies. The next section is

16 the environmental risk characterization. We would

17 describe the approach that we would use to

18 characterize, that we would propose to use to

19 characterize the potential risks to applied organisms.

20 The next section would describe

21 uncertainties, data gaps, and other related issues

22 associated with risk assessment approach. Then we

23 will have of course a section on references that we've

24 used in the document as well as appendices that will

25 have supplemental information.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 49

1 And we included a draft of chapter one

2 just so that you would get a sense of the information

3 that we typically include within the risk assessment.

4 This outline is actually, comes from the HHCV work

5 plan that we posted on the existing chemicals website.

6 If you're interested in taking a look at that.

7 So, the first section again is the

8 introduction that describes D4 including you know,

9 relative information on uses etcetera, production

10 volume, regulatory information, whether it's listed,

11 well listing on the TOSCA inventory. We would really

12 highlight available tox data and monitoring data as

13 well as biota monitoring.

14 The next section covers--

15 KARLUSS THOMAS: Just one comment, can

16 I make one quick comment on the introduction of the

17 summary of the regulatory activity on D4? I mean to

18 the extent that is going to be put in the document I

19 just thought it would be helpful if they were

20 inaccuracies here, it'd be helpful if they were

21 clarified.

22 I think with respect to the D4

23 regulatory activity in Canada and Norway, the second

24 sentence says Canada placed limits on the percentage

25 of D4 that can occur in consumer products and
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 50

1 introduced a mandatory pollution prevention program.

2 There are no concentration based

3 regulatory restrictions for D4 in Canada and indeed

4 there is a requirement that facilities that use D4

5 prepare a pollution prevention plan but at this point

6 there are no regulatory restrictions on the use of D4

7 anywhere in the world.

8 WARD PENBERTHY: Okay, well we'll

9 clarify that. You must have been looking at a

10 different document but anyway that's okay we'll take

11 care of it. So, we're going to scope the assessment

12 then?

13 KATHY FEHRENBACHER: Yes, so the scope

14 of the assessment would describe the breath and depth

15 of the assessment. We have developed a conceptual

16 plan for D4 which you see on page six. We found that

17 in developing the work plan and risk assessments, it's

18 helpful for us to conceptualize not only the flow of

19 in this case D4 but also information on releases for

20 instance going from manufacturing to either on site

21 industrial or to down stream processing through

22 indirect discharge to municipal POTWs or through

23 commercial and residential use to municipal and then

24 releases to surface waters, sediment, biota, and we've

25 shown here both the product flow and the effluent
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 51

1 flow.

2 Again, just highlighting the importance

3 of that information. We've also included some

4 assessment questions on page five to give you a sense

5 of the types of questions that we're looking too

6 address in the risk assessment including the source of

7 pathways through which D4 enters the environment from

8 manufacturing down stream processing and formulation

9 and end use.

10 How do levels of D4 measured in surface

11 water compare to levels that produce adverse effects

12 in aquatic organisms. How do the levels of D4 measure

13 in sediments in the U.S. compared to levels that

14 produced adverse effects in sediment dwelling

15 invertebrates and how do the biota concentrations near

16 the release sources such as the formulator sites

17 compare to the previously collected biota

18 concentration data.

19 And again this section helps us to

20 characterize the overall assessment and really focus

21 our work on the exposure pathways of interest, the

22 sources feeding into the risk assessment so that's a

23 very important section for us.

24 And then we, for your information

25 included some of the references that we've used in
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 52

1 preparing this draft, chapter one of the document.

2 But, again the outline is a draft outline at this

3 point, we have drafted chapter one again to give you a

4 flavor of what we would develop which would then be

5 submitted to the peer consultation panel for review.

6 Yes, so with that all started I'd ask

7 if there are questions?

8 KARLUSS THOMAS: A comment I think the

9 scope of the assessment and brief I think we would

10 agree is extremely important. I think to the extent

11 that the key questions that are going to be addressed

12 are not articulated here and we'd certainly like to

13 see the rest of those because they include but are not

14 limited to.

15 I think number two and number three

16 form the crux of what we would see as the critical

17 items for a risk assessment and again our proposal was

18 generated to allow the development of information that

19 allows you to make that determination.

20 We did have our facility folks take a

21 real close look at the diagram and have made some

22 really important changes that I think will help

23 crystallize those two things that are going to be most

24 critical from the standpoint of a risk assessment.

25 We don't have to go through that now,
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 53

1 we're happy to go through that now if you'd guys would

2 like to do that. We can provide that for you later in

3 written comments on this but I just wanted you to be

4 aware that we do think this is important and we've

5 made some changes to this that we think better reflect

6 production reality.

7 We think that's going to feed into what

8 you've laid out under the scope in terms of the

9 critical questions. So I just wanted to note that and

10 back to the earlier comment on D4, not to belabor that

11 but you are right Canada did at one time consider a

12 range of concentration based on the limitations for D4

13 and a variety of products.

14 They did have a stakeholder process

15 back in the fall of 2010 where they brought in

16 stakeholders to provide comments on that and the

17 ultimate outcome of that was that they decided to go

18 with a pollution prevention plan as the only risk

19 management instrument for dealing with D4.

20 So, while those concentration

21 limitations were considered, they ultimately

22 determined they weren't necessary.

23 WARD PENBERTHY: Okay that's great. We

24 would appreciate your written comments that would be

25 particularly on the conceptual plan, that would be a
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 54

1 great help because if we got it wrong that's not good

2 so yeah.

3 PAUL DELEO: Question Kathy, I have a

4 question.

5 KATHY FEHRENBACHER: Yes.

6 PAUL DELEO: With your, it's Paul

7 Deleo, American Cleaning Institute. With your risk

8 assessment conceptual plan do you think we'd try to

9 instruct a material balance around, you have the

10 diagram of another plan?

11 KATHY FEHRENBACHER: No this is, this

12 particular diagram is really focused on the assessment

13 because the plan that we would use for building out

14 the assessment. We would however when, when

15 evaluating the releases certainly a material balance

16 is the general approach that we use there.

17 So that would be an important component

18 for that section of the document but this diagram is

19 really intended to present a graphic of a conceptual

20 graphic of the assessment and the sources and pathways

21 that we intend to address within the disclosure and

22 risk assessment.

23 WARD PENBERTHY: Yeah I don't think

24 we're trying to track every pound of D4 through the

25 American economy that's not our--
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 55

1 PAUL DELEO: Well, you know the reason

2 I made that, asked that question is um, my

3 understanding is there is a pretty significant loss

4 during the consumer release phase so what goes down

5 the drain might be a small portion of what's actually

6 a consumer products and it's not reflected in the plan

7 right now, I'm not sure if you're--

8 WARD PENBERTHY: Can you say that

9 again?

10 PAUL DELEO: That a significant portion

11 of the material in consumer products doesn't go down

12 the drain so if you're using deodorant that's what

13 qualifies as a decoded ingredient. It doesn't go down

14 the drain when you take a shower I'd say.

15 WARD PENBERTHY: Okay.

16 PAUL DELEO: And so, if you try to do

17 material balance by virtue of this you might over,

18 over state what's going down the drain, if you're

19 going to run I'd say EFAST or something like that to

20 look at that.

21 WARD PENBERTHY: Okay.

22 PAUL DELEO: This would get us enough

23 material balance to make a decision.

24 KATHY FEHRENBACHER: Yeah thank you.

25 WARD PENBERTHY: Any other questions?
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 56

1 All right Stan do you want to talk a little bit about

2 plans for a peer consultation?

3 STAN BARONE: Sure as many of you know

4 there's a distinction between a peer consultation and

5 a peer review and we're taking the approach of a peer

6 consultation for a number of significant reasons. One

7 this is a draft assessment plan. We're getting input

8 from a broad range of folks with different expertise.

9 This is not going to be a consensus

10 report. I think there are some questions about that

11 so, let's be clear about that. There's not, consensus

12 is not the objective of this particular approach. EPA

13 will arrange for this independent contractor to man an

14 independent contractor to manage this peer

15 consultation.

16 The contractor will select the peer

17 consultants based upon technical expertise and perform

18 a conflict of interest and bias evaluation of those

19 potential peer consultants. The EPA will develop the

20 risk assessment plan given some of the information

21 we've discussed today and additional information that

22 we receive.

23 The list of expertise needed to

24 evaluate the risk assessment plan and the science

25 questions and charge questions will be developed by
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 57

1 EPA. We'll make all of this information available

2 through a federal register notice so it will be

3 publicly released to everyone including stakeholders,

4 so that's the public.

5 GENE BROWNING: And will there be an

6 opportunity to comment?

7 STAN BARONE: That's my next point

8 actually. So there will be a public comment period,

9 very definitely, prior to the meeting to the peer

10 consultation meeting. We're shooting right now just

11 to give you a ball park that would be early August for

12 that federal register notice, that release.

13 And a meeting would probably be

14 September, potentially. There are some uncertainties

15 that are in play right now so we're working with that,

16 those assumptions.

17 ELLEN MIHAICH: That's this year right?

18 STAN BARONE: That is this year. Yes I

19 am talking this year, this calendar year.

20 ELLEN MIHAICH: Okay.

21 STAN BARONE: So, following, let's

22 follow my notes here. Following the peer consultation

23 meeting there would be a recording by the contractor

24 of the comments, the collection of the comments as per

25 the science questions. There would be a report we
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 58

1 hope from the science consultation within 30 to 45

2 days that would be made publically available. EPA

3 would use that report in evaluating it's assessment

4 plan, revising it's assessment plan and moving

5 forward.

6 At the peer consultation there would

7 also be the opportunity for public comment as well as

8 the previous public comments that were provided during

9 the comment period. And the public comments that are

10 received would be of course communicated to the peer

11 consultations through the contractor prior to the

12 science consultation meeting.

13 Are there questions?

14 HUGH FLACK: Yeah, what are the source

15 of the data that these consultants will be looking at?

16 Where are they going to get their information from?

17 STAN BARONE: So, primarily the

18 information that's available will be the report that

19 the science plan, the risk assessment plan that's

20 provided to them. That's going to be the core source

21 material that they'll be evaluating. Any other public

22 comments or data that's received during the public

23 comment period would also be made available to them

24 and they'll have all of that in the public record as

25 well.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 59

1 KARLUSS THOMAS: Will assessments done

2 under other jurisdictions be provided to the

3 consultation for review? So for example the

4 assessments that's already been done by Canada, will

5 that be made available?

6 STAN BARONE: We're not asking them to

7 comment on other organization's assessments. Those

8 kinds of materials would be made available to them if

9 they were made available during the public comment

10 period. They will be cited more than likely in our

11 plan as they are outlined as they are now.

12 But that's not the subject of their,

13 that's not the subject of the consultation. The

14 subject of the consultation is on the proposal that

15 EPA is presenting.

16 KARLUSS THOMAS: Right, I know the idea

17 was that since they are going to be reviewing a plan

18 that the agency intends to pursue with respect to the

19 risk assessment. It might be helpful for them to see

20 assessments that have already been done by other

21 public officials.

22 JENNIFER SEED: If they request that

23 and it's representative, I guess they can have access

24 to it.

25 KARLUSS THOMAS: Okay.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 60

1 STAN BARONE: But again focuses on the

2 risk assessment plan that EPA is putting forward.

3 KARLUSS THOMAS: Sure.

4 STAN BARONE: Okay.

5 TRENT DOYLE: Stan taking a step back

6 in terms of the outside contracts they use as a, to

7 manage the process in terms of you know, scheduling

8 the meeting, compiling the reports, etcetera. You

9 also said they would be selecting the participants.

10 Will there be an opportunity for interested parties to

11 provide comments to the agency on a recommendations

12 for the peer consultees? I mean if they are the

13 people that they are going to be picking?

14 STAN BARONE: So, that is a

15 possibility. We haven't ruled that out. We will be

16 giving in our performance work statement, the

17 expertise. We're, EPA is not picking the peer

18 consultants. We provide the expertise that we think

19 is required for this endeavor and the contractor

20 actually picks based upon the criteria and the

21 expertise that we've listed.

22 TRENT DOYLE: Yeah I'm just aware, I

23 know that sometimes in the past there's been an

24 opportunity for--

25 STAN BARONE: For nomination.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 61

1 TRENT DOYLE: Folks for EPA as well as

2 any other interested party to submit nominees that

3 would be you know, then up to the, this outside

4 contractor to sift through those and pick those at

5 least there's an opportunity to give nominations.

6 STAN BARONE: We are talking about

7 actually when we release the federal register notice

8 for the meeting also listing the draft list of the

9 consultants so that'll be available to everybody with

10 the information on when the meeting is going to be and

11 who's going to be the consultants.

12 KATHY PLOTZKE: Is there a possibility

13 for collaborating on as you put together the list of

14 expertise in the charge questions for us to provide

15 feedback?

16 STAN BARONE: The public comment period

17 is really the opportunity for you to comment on the

18 charge questions and the expertise that we have

19 listed. If you think there's some expertise that's

20 missing we would very much appreciate your comments.

21 We have to also, this is the agency's

22 process and you also have to bear in mind that other

23 outside parties might also be submitting comments into

24 the same subject matter.

25 TRENT DOYLE: With respect to the work
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 62

1 product from the peer consultation meeting as I

2 understand it. What would come out of that is

3 essentially a report that summarizes the various, I

4 guess viewpoints if you will of the peer consultation

5 group and that's really what the outside contractor

6 would put together. The agency would then take that

7 under advisement and then use that to presumably

8 inform its final risk management plan?

9 STAN BARONE: Risk assessment plan.

10 TRENT DOYLE: Risk assessment, I'm

11 sorry risk assessment plan.

12 STAN BARONE: Let's be clear.

13 TRENT DOYLE: I don't want to race

14 ahead of myself. So the risk assessment plan and then

15 that would be, that would be what, would there be an

16 opportunity then for commenting on that sort of final,

17 or you know, revised plan etcetera? Or is that

18 essentially going to just go final once you receive

19 the comments back from the--

20 STAN BARONE: Well, what we have done

21 with the other work plan chemicals and I think the

22 intention is this to follow after that report. Follow

23 the process that we've done with the other work plan

24 chemicals is we go on and develop a draft risk

25 assessment.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 63

1 We would release that draft risk

2 assessment for public comment and peer review when it

3 has gone through the entire agency process and then

4 you would have an opportunity to again comment on that

5 draft risk assessment and provide any additional data

6 that might have come in or any additional information

7 to inform that assessment product during the peer

8 review, not consultation. Peer review.

9 TRENT DOYLE: So, as far as, just

10 taking a step back, is this whole risk assessment plan

11 is new to the work plans in terms if you haven't

12 really done this process in terms of the front end

13 process. I know how you do on the back end but as far

14 as once the EPA has finalized its risk assessment

15 plan, after taking it under advisement, the report

16 that comes from the peer consultation. Will that plan

17 be then published to the federal register? That risk

18 assessment plan, or is that going to be just, I mean

19 what I'm trying to get at is how do we know what the

20 agency decided to do until we see the actual draft

21 risk assessment? Will there be an opportunity

22 beforehand?

23 STAN BARONE: You're talking about

24 would you see the finalized risk assessment plan?

25 TRENT DOYLE: Yes.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 64

1 STAN BARONE: I think what we're

2 talking about is we take the comments from the peer

3 consultation report. We would take our draft risk

4 assessment plan. We move forward to our risk

5 assessment process. We'd move forward to a risk

6 assessment. We're not going to publish another

7 interim product, I mean again we want to move forward.

8 TRENT DOYLE: No, I understand, I just

9 want to make sure that comes out so we're all very

10 clear on that. So essentially what the proof will be

11 in whatever the plan, whatever the risk assessment,

12 the draft risk assessment was the next time we'll be

13 able to see, oh this what, this is how the agency

14 incorporated the feedback from the peer consultation.

15 STAN BARONE: Yeah, there's no

16 intention to have a response to comments or in, for

17 the peer consultation. This is unlike a peer review

18 where for an influential product or highly influential

19 product that in the peer review that we would have a

20 response to comments document and a revised assessment

21 so, note we're putting some, that's a different

22 process, different steps.

23 TRENT DOYLE: Sure.

24 STAN BARONE: Other questions?

25 PAUL DELEO: Comments, not the specific
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 65

1 peer consultation but the process in general. I think

2 the document that the outline was prepared is really

3 valuable. It's sort of a roadmap of where you're

4 going on D4 and this kind of approach I think would

5 have been valuable for the five risk assessments that

6 came out recently and yesterday a number of chemicals

7 were announced for risk assessment.

8 I think it would be valuable to have

9 something like this. I don't think they all need a

10 peer consultation process but some kind of roadmap

11 just talking about you know what the general plan is

12 for the individual chemicals that are going to be

13 assessed. I think that would be valuable for

14 especially industries that are effected potentially or

15 who might have information with respect to those

16 chemicals and be unaware of exactly where the agency's

17 planning to go.

18 KATHY PLOTZKE: I guess that kind of

19 leads to, so was this the first time you've done it

20 this way or is this something you're seeing to maybe

21 incorporate into the work plan process or?

22 JENNIFER SEED: If you recall years

23 back we had a voluntary children's campaign evaluation

24 process. The whole thing was peer consultation. So

25 it's sort of modeled after that appeal. So I don't
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 66

1 think there's, this is just a unique situation because

2 of the issues over the monitoring so that's why we're

3 seeking comment.

4 If others have other unique questions

5 we would pursue the same thing. We've gone through

6 this with other kinds of assessments that have gone to

7 our Science Advisory Board and so in that case we'll

8 have an advisory group and we might go to them way too

9 many times, several times for consolation on specific

10 science issues and then once we have the document

11 we'll go for a formal approval. So it's a fairly

12 common practice in the agency.

13 STAN BARONE: Across programs including

14 ORD. So other examples include the Thalight

15 Cumulative Assessment scoping for that. The dioxin

16 reassessment also went through a peer consultation

17 process.

18 BETSY CARLTON: But never associated

19 with an ECA before? This is the first ECA that does

20 that?

21 WARD PENBERTHY: Yeah people shouldn't

22 expect that this would every happen again in the ECA

23 process. You know I think there are unique attributes

24 of this effort to monitoring which is particularly

25 complex to deal with and I think the ECA process is
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 67

1 really designed around, testing around the health

2 effect around the known guideline.

3 You know and this sort of a custom

4 build situation so yeah don't anticipate that this

5 will be a standard feature of future ECA activity.

6 Any other questions?

7 BETSY CARLTON: Yeah this is Betsy

8 Carlton from Bluestar Silicones again. So now that we

9 have the approximate estimated time frame, so assume

10 that we can agree on monitoring proposal by the end of

11 April. It doesn't go to peer until August.

12 STAN BARONE: It doesn't go out for

13 public comment.

14 BETSY CARLTON: It doesn't go out for

15 public comment. Okay I'm trying to figure out how the

16 comments from the peer consultation if they were to

17 come back and say we need a revision to an ECA that's

18 already been agreed to.

19 WARD PENBERTHY: How does that work?

20 BETSY CARLTON: Yeah.

21 WARD PENBERTHY: There are modification

22 procedures in our regulations governing ECAs and

23 they're very specific. They're essentially, basically

24 opening up another round of these type of meetings.

25 And so I think what you would get is, you'd have the
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 68

1 peer consultation report, people would have a sense is

2 a modification necessary? And then we would start

3 these discussions with interested parties, consensus,

4 modifying the ECA.

5 TRENT DOYLE: What's novel about it

6 appears is the fact that I'm not sure if a situation

7 where we've gone through an ECA negotiation and the

8 next step after that is to evoke a peer consultation

9 process, or a process where it essentially get's

10 opened up and subject to review all that before

11 anything's really transpired. I mean it's clearly,

12 pretty unprecedented and sort of a--

13 WARD PENBERTHY: It's different.

14 TRENT DOYLE: Interesting approach

15 given that everybody was invited at the beginning of

16 this to you know, it's just they said stakeholders

17 were invited to participate, have comments etcetera.

18 WARD PENBERTHY: Yeah I mean I think

19 part of problems associated with the whole ECA

20 discussion were the novel science issues that we're

21 having to deal with. This is one way to help us deal

22 with those.

23 So are we at the next agenda item?

24 Okay so in terms of next steps, you know through our

25 discussions we identified a number of issues that we
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 69

1 need to work on towards the end of April. There's

2 some issues around biota monitoring, how many sites.

3 The contribution of D4 from indirect sites to POTW

4 influent versus from consumer sources.

5 Contribution, or the amount of D4 in

6 influented waste water treatment at direct discharge

7 sites is another issue we talked about. And then the

8 general issue around you know is ten POTWs enough

9 versus our sixteen and that kind of thing.

10 One concept that we've been talking to

11 around our senior management is that we do our best to

12 come to an agreement on these remaining issues

13 understanding that your current proposal would be

14 basically the foundation of an ECA agreement.

15 Hopefully we'll be able to resolve

16 these outstanding issues in the interim period till

17 the end of April and then we get to an ECA agreement

18 that, an ECA agreement would be part of the risk

19 assessment plan and then there would be a commitment

20 included in the ECA agreement that all the interested

21 parties would consider the results of the peer

22 consultation and assess whether modification is

23 necessary.

24 And I think the thinking about this is

25 that when you stand back and look at, you know we're
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 70

1 about 70% in agreement. It's hard to resolve those

2 differences. It doesn't appear that we're going to

3 resolve those issues quickly anyway. So that would be

4 an approach that we can sort of get things moving,

5 come to some conclusion to this effort and these

6 negotiations that have been going on since, well about

7 this time last year.

8 So I think it's time to bring it back

9 in and this would be one approach to do that. I think

10 for instance if we were able to come to an agreement

11 on the components of an ECA obviously one would have

12 to be a drafted, that draft gets sent to all

13 interested parties for a 30 day review so you know, we

14 might have to do another extension past April to

15 ensure that that capability could be done.

16 You know I think all during that

17 drafting period we'll have a clear sense of what a

18 monitoring program could look like to be able to

19 include in the developing risk assessment plan, concur

20 so that would be the proposal that I would make to you

21 and obviously we've heard some new stuff on your plans

22 so I need to go back and talk with our science people

23 and figure out, you know what are must haves and what

24 we could live without and then we've got to the test

25 the, by sort of an agreement and concept that is a
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 71

1 good approach at the senior management level.

2 You know they didn't know the details

3 of your commitment in terms of the monitoring plan

4 either so we would have to go through that with them.

5 I think that would take us about a couple weeks and so

6 I think probably what we might be able to do is have a

7 conference call of this group in about two weeks.

8 I understand if you're willing to

9 proceed on that level then we ought to. So that's

10 what I would offer at this point. Are there any

11 comments that you have on that concept?

12 KARLUSS THOMAS: Well I guess, yeah I

13 guess my one comment is with respect to the proposal.

14 I think certainly the proposal that was articulated in

15 the letter that we submitted in February represents,

16 represent an agreement from all of the member

17 company's senior management and I'll note that that's

18 on a number of continents so that was a really heavy

19 lift. It might not be evident in, you might not think

20 it's evident in this proposal but I think it was quite

21 substantial that we were able to pull together this

22 type of an agreement.

23 I think from the standpoint of that

24 proposal that's what I can absolutely stand behind at

25 this point and say that the members are behind. If
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 72

1 there are going to be substantive changes to that that

2 would require a fair number of discussions which would

3 obviously extend well beyond April.

4 So my hope is that we can get at least

5 a formal response from the agency on the proposal that

6 was submitted in February. Certainly we are going to

7 take all of the comments we've received today under

8 advisement but it would be helpful to get sort of a

9 formal response on that proposal because I think again

10 that's where we are.

11 If there are some changes around the

12 margins that we might come to agreement on, I think

13 we'll try to do that. But I think in terms of the

14 substantive elements of the proposal, those were

15 articulated in the letter, I've tried to highlight

16 them again here today and it's certainly our hope that

17 that could be used as the basis for moving forward

18 with the monitoring.

19 The other thing I'll mention is that we

20 in the past, the versions of the proposal that we

21 talked about we had sought input from the other

22 stakeholders around the table. We haven't done that

23 with this particular proposal so if you think it's

24 helpful we would certainly be interested in thoughts

25 from other stakeholders with respect the revised
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 73

1 proposal that we've talked about today and that we

2 obviously described in more detail in the letter back

3 in February.

4 WARD PENBERTHY: Yeah, that's a good

5 point because it is important because in the end it is

6 a consensus determination. So do any of the other

7 interested parties have concerns about the approach

8 and, or concerns about the proposal?

9 We have one? I'm sorry.

10 CYNTHIA FINLEY: That's all right.

11 This is Cynthia Finley with NACWA. We're really

12 pleased to see the increase in the number of POTWs

13 that were purposed for monitoring. We feel like ten

14 is enough, I know you're still concerned about the

15 discrepancy between the sixteen recommended by EPA

16 versus the ten that's proposed but we feel that with

17 ten you could get a real cross section of treatment

18 types and POTW configurations. So you would get a very

19 good set of data from ten.

20 Also I've heard you mention again today

21 using population served as one of the criteria to look

22 at in POTW selection. We still feel like that really

23 doesn't matter. That that's not one of the best

24 criteria to use in the selection because if you're

25 increasing your population I'm sure you're probably
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 74

1 increasing your use of products that contain siloxanes

2 but then you're also increasing your flow to the

3 treatment plant.

4 We have no evidence to show that a

5 greater population uses more of these products and it

6 just doesn't seem like the best way to choose a POTW.

7 WARD PENBERTHY: So, what's the better

8 way?

9 CYNTHIA FINLEY: I think your other

10 criteria are fine looking at treatment type. I like

11 the comparison of POTWs that have direct dischargers

12 versus those that don't. To go to your question about

13 if you can sort of I think, look at the proportion of

14 discharge from an industrial facility.

15 I think that would be highly dependent

16 on the POTW. If it's in a very large area that's

17 taking you know, from a huge population and lots of

18 different industries, you know the industrial

19 facilities are not discharging at a constant rate most

20 likely and I don't think you'd ever be able to come to

21 any conclusion there.

22 If was a very small POTW and that was

23 the only industry in town, you might be able to figure

24 that out but I think in most situations you wouldn't

25 be able to.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 75

1 Karluss mentioned that NACWA could help

2 out in POTW selection and we do have members and even

3 non-members that are keeping track of this issue and

4 some of them are very eager to be part of ECA

5 actually. So if you're looking for volunteers we'd

6 probably be able to find some and again they'd

7 probably represent a good cross section POTW site

8 you're looking for.

9 WARD PENBERTHY: Well hopefully we'll

10 take you up on that offer.

11 CYNTHIA FINLEY: Yeah. The one other

12 thing, you know our concern is really with siloxanes

13 and bio-gas and the impact that has on the energy,

14 renewable energy production at POTWs. So I know that's

15 not your concern, you know that's not part of this

16 risk assessment but we still feel like if you were to

17 sample the bio-gas you would have a more complete set

18 of data and you could look at a mass balance, a

19 complete mass balance of how these things are working

20 their way through the treatment plant and being

21 discharged into the environment. So I'd just like

22 that to be considered as part of this process--

23 WARD PENBERTHY: Does influent

24 concentrations help you with that?

25 CYNTHIA FINLEY: It does yeah.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 76

1 Influent, I think that's good again I'm not quite sure

2 how that goes to the risk assessment as far as you

3 know, what's happening in the environment with the

4 discharge but I do think to get a complete picture of

5 what's happening you should sample the influent at the

6 POTW and the effluent, the bio-solids, bio-gas.

7 WARD PENBERTHY: Okay. All right thank

8 you. All right so I guess we have to go back and talk

9 to our appropriate groups and try to figure out how

10 close we are to an agreement here. I guess we'll plan

11 on a conference call in a couple weeks to give each

12 other some feedback on where we are and we'll give you

13 a direct response on exactly what we feel we need to

14 inform, you know in two weeks.

15 KARLUSS THOMAS: Okay, if we could have

16 that before the call that would be very helpful.

17 WARD PENBERTHY: Okay. Is there

18 anything else we need?

19 PAUL LEWIS: No, that's it again, a

20 transcript of this meeting will be made available in

21 the docket. We'll work with interested parties in

22 terms of scheduling the next teleconference in the

23 next two weeks. Obviously we have something in

24 advance in terms of laying our role and obviously the

25 circle back about issue and we can do the same.
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 77

1 WARD PENBERTHY: You know, in the event

2 that we can get on a glide path that gets us towards

3 going through an ECA. Usually, or typically I don't

4 know if you guys are new to it, what would happen is

5 the EPA and the primary interested parties would, have

6 found maybe one or two people to start drafting the

7 ECA working together and interested parties could also

8 provide a person if they wanted to.

9 They would work closely together to try

10 to put together an agreeable draft to share with

11 broader group so that, that usually is the next step

12 after you know, we start working on the specifics.

13 TRENT DOYLE: Today, and Ward to we did

14 include a draft ECA in our original proposal back last

15 April.

16 WARD PENBERTHY: Yeah April or March.

17 I know that.

18 TRENT DOYLE: So, it just says--

19 WARD PENBERTHY: We could, you know,

20 start working off that draft and I will tell you that

21 the timeline on some of that stuff, like I think for

22 instance it had a 270 day for, what do they call it?

23 Not a sampling plan, a test plan. Usually in ECAs

24 they're 60 days so we have some, we're going to have

25 some work around the schedule I know. So the 270 days
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 78

1 isn't going to be, isn't going to work. So, we're

2 going to have some issues like that to deal with.

3 Okay any thing else? All right, we'll

4 talk again in two weeks.

5 KARLUSS THOMAS: All right, thank you

6 very much.

7 (WHEREUPON, the meeting concluded at 2:40 P.M.)

8

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Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 79

1 STIPULATION

2

3 The foregoing matter was taken on the date, and

4 at the time and place set out on the title page

5 hereof.

6

7 It was requested that the matter be taken by the

8 reporter and that the same be reduced to typewritten

9 form.

10

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Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 80

1 CERTIFICATE OF REPORTER AND SECURE ENCRYPTED

2 SIGNATURE AND DELIVERY OF CERTIFIED TRANSCRIPT

3 I, JASON ALAN LEES, Notary Public, do hereby

4 certify that the forgoing matter was reported by

5 stenographic and/or mechanical means, that same was

6 reduced to written form, that the transcript prepared

7 by me or under my direction, is a true and accurate

8 record of same to the best of my knowledge and

9 ability; that there is no relation nor employment by

10 any attorney or counsel employed by the parties

11 hereto, nor financial or otherwise interest in the

12 action filed or its outcome.

13 This transcript and certificate have been

14 digitally signed and securely delivered through our

15 encryption server.

16 IN WITNESS HEREOF, I have here unto set my hand

17 this 3rd day of April, 2013.

18

19

20

21

22

23 /s/JASON ALAN LEES

24 COURT REPORTER / NOTARY

25 My Commission Expires: October 2, 2016
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 81

1

1:00 4:3 4:16

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Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 82

16:9

20:18 20:23

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64:6
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 83

64:11 64:12

64:20

65:7

66:15 69:19

70:19 75:16

76:2

assessments

22:21 22:22

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61:22

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63:22

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68:15

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71:24 71:25

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5:25

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16:14 16:18

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38:24 72:3

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9:3 10:2

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biota 10:7

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31:10 31:11

31:14 31:17

31:24 33:16
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 84

35:20 35:25

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ion 48:16

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Cleaning 5:20

54:7

clear 31:13

34:1

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37:15 56:11

62:12 64:10
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 85

70:17

clearly

40:2 68:11

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52:21 76:10

closely 77:9

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closure

37:2 45:4

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61:13

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32:7 39:9

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71:17

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26:12

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60:8

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75:17 75:19

76:4

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22:18

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complexity

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37:5

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53:20

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34:24 48:4

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78:7

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35:2

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44:11

70:5 74:21

concur 70:19

conducting

28:6

conference

71:7 76:11

confidential

42:20 42:23
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42:25

configuration

s 73:18

conflict

56:18

consensus

46:9 56:9

56:11

68:3 73:6

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22:20 29:6

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66:9

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74:19

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8:25

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42:3

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28:20

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56:17 56:19

58:15 60:18

61:9 61:11

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4:20 7:13

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43:12 43:16

43:20 43:23

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45:22

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58:11

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60:12

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55:11 69:4

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44:18

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71:18

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56:13 56:14

56:16 57:23

58:11 60:19

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60:6

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s 20:1

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40:4 41:15

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37:2 69:3

69:5

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37:1

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Corning

5:11 5:22

6:5

Corporation

6:3 6:22

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14:2 15:5

15:12

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42:17

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6:4

Counsel 5:18

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76:11

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42:22 42:23

48:23 58:10

cover 42:14

42:15

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27:4

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73:24 74:10

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25:12 52:16

52:24 53:9

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75:7

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52:23

Cumulative

66:15

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22:12 30:20

33:17

34:2 39:3

44:14 69:13

currently

38:24 43:8

custom 67:3

cut 47:14

CVI 20:4
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cycle 42:18

Cynthia 73:10

73:11

74:9

75:11 75:25

D

D4 8:3 13:5

13:17 13:22

14:7

14:12 15:25

17:1 17:4

18:2 18:2

27:5

27:22

29:3 35:2

35:10

37:3 38:4

38:13

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41:2 41:8

41:15 48:14

49:8

49:17 49:22

49:25

50:3 50:4

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50:16 50:19

51:7

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53:10 53:12

53:19 54:24

65:4 69:3

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data 12:1

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13:22 14:22

16:9

16:17 18:16

24:25 25:25

28:13

29:4 32:7

40:8 40:9

41:24

43:5 43:8

47:3 47:7

47:13 47:17

48:21 49:12

49:12 51:18

58:15 58:22

63:5

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database

20:20

David 6:24

38:17 38:25

day 70:13

77:22

days 58:2

77:24 77:25

deadline

44:14

deal 37:6

66:25 68:21

68:21 78:2

dealing 4:7

53:19

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decided 53:17

63:20

decision

55:23

decisions

11:18 11:22

41:11

decoded 55:13

decouple

43:22 44:3

deem 41:2

deficiencies

46:6

definitely

17:14 57:9

delay 35:8

35:8

Deleo 5:19

5:19 54:3

54:6 54:7

55:1

55:10 55:16

55:22 64:25

demonstrates

34:19

deodorant

55:12

dependent

30:3 31:7

74:15

depth 50:14

describe

48:17 48:20

50:14

described

37:6 73:2

describes

41:5 42:9

49:8

description

42:18

Desetan

6:21 6:21

designed 32:9

32:12 32:20

41:13 67:1

desire 29:15

detail 73:2

details 8:2

8:6 14:22

40:24 43:17

43:19 71:2

determination

52:19 73:6

determination

s 20:19

determined

53:22

develop

12:8

13:15

28:8

29:16

40:3 42:6

42:13

52:4

56:19 62:24

developed

12:3

13:21

14:9 29:9

29:14 40:11

41:19 50:15

56:25

developing

28:22

40:7 47:3

47:7

50:17 70:19

development

13:7

26:23 52:18
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 88

Devis 6:20

6:20

diagram 52:21

54:10 54:12

54:18

differ 25:17

difference

36:3

differences

35:16 36:23

37:6 37:8

37:8

38:12 38:14

39:16 70:2

different

15:2

17:21

24:9

24:20

25:3 30:3

36:14 50:10

56:8

64:21 64:22

68:13 74:18

dilution 9:10

12:19

dioxin 66:15

direct 8:8

9:7 10:21

20:6 20:9

21:3 21:7

26:20

29:5

33:18 35:19

37:24 41:22

69:6

74:11 76:13

directly

15:22

directs 38:2

discharge 8:8

8:21 9:7

9:24

10:13 10:22

11:16 12:18

14:7

14:11

15:3

15:11

21:4

27:20 27:23

31:19

32:1 32:3

32:5

33:18 35:19

35:22 37:25

41:22 50:22

69:6

74:14 76:4

discharged

18:22 75:21

discharger

19:13

dischargers

15:13 15:16

15:25

16:7

18:19 18:24

19:6 20:7

20:9

20:14 20:16

26:21

32:6 74:11

discharges

12:12 28:14

discharging

74:19

disclosure

54:21

discrepancy

73:15

discuss 39:24

42:10

discussed

21:5 56:21

discussing

4:20 41:5

discussion

4:6 8:22

68:20

discussions

8:1 9:17

16:18

68:3

68:25 72:2

distinct

40:18 46:13

distinction

56:4

distribution

41:16

division

43:15

docket 4:15

76:21

document

44:17 48:24

49:18 50:10

52:1

54:18 64:20

65:2 66:10

done 22:15

22:21 35:25

48:7 59:1

59:4

59:20 62:20

62:23 63:12

65:19 70:15

72:22

Dow 5:10 5:22

6:5

Doyle 5:4 5:4

15:6

15:13 15:19

19:20 33:12

33:20 33:24

34:8

45:16 46:10

46:17 46:21

47:11 47:21

60:5

60:22

61:1

61:25 62:10

62:13

63:9

63:25

64:8

64:23

68:5

68:14 77:13

77:18

draft 41:4

49:1 52:1

52:2 56:7

61:8

62:24

63:1 63:5

63:20

64:3

64:12 70:12

77:10 77:14

77:20

drafted

52:3 70:12

drafting
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 89

70:17 77:6

drain 41:23

55:5

55:12 55:14

55:18

drive 17:25

driven 44:11

driving 17:7

dropped 15:4

Dumars 5:6

5:6 45:7

during

11:23

55:4 58:8

58:22

59:9 63:7

70:16

dwelling

51:14

dynamics

30:15

E

eager 75:4

earlier

8:18 9:2

37:11 53:10

early 8:12

57:11

ECA 4:1 34:24

35:2 35:7

40:16 43:23

44:10 44:19

45:17 45:18

46:1 46:5

47:1

47:14 47:17

47:19 66:19

66:19 66:22

66:25

67:5

67:17

68:4 68:7

68:19 69:14

69:17 69:18

69:20 70:11

75:4 77:3

77:7 77:14

ECAs 67:22

77:23

economy 54:25

ecotoxicity

48:15

EFAST 55:19

effect 19:1

46:25 67:2

effected

65:14

effectively

46:11

effectiveness

26:25

effects 51:11

51:14

efficiencies

26:19 27:25

efficiency

22:7

27:16 27:19

28:19 29:2

effluent

9:3 9:14

10:2

14:12 21:11

22:3 23:9

24:7 33:6

50:25 76:6

effort

66:24 70:5

eight 44:7

Eisenreich

6:15 6:15

36:20

either

17:11 23:22

50:20 71:4

elements 35:6

72:14

eleven 17:21

elicit 19:1

Ellen 6:10

6:10

57:17 57:20

else 6:23

14:9

76:18 78:3

enable 28:18

endeavor

60:19

energy 47:7

75:13 75:14

enforceable

40:3

enormous 37:7

ensure 70:15

enterprise

21:21

enters 51:7

entire 63:3

environment

18:22 21:12

22:2

23:10 23:12

23:21 25:13

26:8

26:22

33:4 51:7

75:21 76:3

environmental

8:3 18:25

32:14

40:8 41:7

41:18

42:2

42:16 42:17

43:1 43:3

43:7

48:13 48:16

envisioned

35:7

EPA 4:5

4:18 4:24

4:25 5:1

5:14 5:15

6:12 6:13

6:14 6:16

6:17 6:25

20:20

35:3

39:18 43:13

44:2 48:1

56:12 56:19

57:1 58:2

59:15

60:2

60:17

61:1

63:14 73:15

77:5

EPA's 5:17

44:25
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 90

equalization

38:9

especially

65:14

essential

36:23

essentially

9:14

15:10 31:23

44:3

46:16 46:20

62:3

62:18 64:10

67:23 68:9

established

18:1

estimate

18:25 28:16

estimated

67:9

estimates

12:4

13:12 41:9

estimation

43:6

etcetera 49:9

60:8

62:17 68:17

Eubonic 6:8

evaluate

46:14 56:24

evaluating

54:15

58:3 58:21

evaluation

29:11 32:12

56:18 65:23

evaluations

22:24

Eve 6:20 6:20

event 44:21

46:5 77:1

events 9:4

21:13 29:21

29:24

everybody

61:9 68:15

everyone

7:6 45:12

57:3

everything

14:9

evidence 74:4

evident 71:19

71:20

evoke 68:8

Evonik 6:19

16:25

exactly

14:5

14:24 39:20

39:21 65:16

76:13

example 59:3

examples

66:14

excellent

7:24

exercises

13:13

existing 49:5

expect 66:22

expert 47:4

expertise

56:8

56:17 56:23

60:17 60:18

60:21 61:14

61:18 61:19

explicit

14:17

exposure

28:20 29:10

32:12

40:9 42:3

43:7 51:21

expressed

27:25 29:15

29:18 34:17

extend 72:3

extension

44:10 70:14

extensions

44:22

extent

14:14 49:18

52:10

extra 40:20

extremely

52:10

F

facilities

9:9 12:5

13:1 13:2

14:18

15:3 17:3

17:10 17:24

18:14 20:14

21:6 21:9

23:12 25:21

43:4 50:4

74:19

facility 12:4

13:12 28:11

28:14 52:20

74:14

fact 15:23

45:17 45:21

46:14 68:6

factor

12:19 12:20

13:21 18:8

factors 24:11

24:14

fair 72:2

fairly 9:14

9:15 66:11

fall 53:15

familiar

42:11

Famir 6:21

6:21

feature 67:5

February 8:12

71:15

72:6 73:3

federal

57:2

57:12

61:7 63:17

feed 33:7

40:15 42:10

53:7

feedback

10:11

44:3 44:5

61:15 64:14

76:12
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 91

feeding 51:22

feeds 28:20

45:8

feel 73:13

73:16 73:22

75:16 76:13

Fehrenbacher

5:13 7:9

11:11 11:14

18:12 20:12

20:25 23:17

28:5

29:20

30:6

30:23

31:4

31:25 40:23

48:12 50:13

54:5

54:11 55:24

fell 17:22

Fhrenbacher

5:13

figure

12:20 14:23

14:23 16:12

67:15 70:23

74:23 76:9

final 62:8

62:16 62:18

finalized

63:14 63:24

fine 47:9

74:10

Finley

73:10 73:11

74:9

75:11 75:25

firm 11:18

11:22

first 4:22

8:16 8:17

41:4 42:7

49:7

65:19 66:19

fish 21:12

25:8 25:8

25:10 25:11

25:14 30:19

30:25 36:13

36:20 38:19

38:24

fit 17:3

17:11 17:24

18:3 45:6

five 8:13

8:16 8:17

8:25 9:25

10:1 10:9

15:4 15:5

16:3 16:5

16:6 16:7

16:13 33:22

34:21 35:21

37:8

37:10 37:12

37:22

51:4 65:5

FLACK 58:14

flavor 52:4

Fleck 5:9 5:9

flexibility

30:2 32:23

flexible 30:5

flow 36:7

50:18 50:25

51:1 74:2

flows 28:13

focus 8:17

9:2 51:20

focused 54:12

focuses 60:1

folks 20:20

39:18 40:21

52:20

56:8 61:1

food 30:14

30:18

forgot 37:23

form 52:16

formal

66:11

72:5 72:9

format 7:2

formulating

28:10

formulation

51:8

formulator

18:2 18:4

51:16

formulators

17:11 17:14

17:16 18:8

forth 40:2

45:18 46:13

forward 24:17

58:5 60:2

64:4 64:5

64:7 72:17

foundation

69:14

frame 67:9

front 26:4

63:12

full 12:23

fully 9:8

future 67:5

G

gained 17:1

gaps 43:5

48:21

Gene 5:7

5:7 27:2

27:9

27:13 27:18

38:2 38:8

57:5

general

5:18

19:16

33:8 33:9

54:16

65:1

65:11 69:8

generally

28:15

generated

52:18

generation

16:9

generic 12:13

13:20

geography

36:9

gets 22:2

26:22 45:18

70:12 77:2
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 92

get's 68:9

getting

14:5

23:25 26:18

33:4

39:17

46:3

46:14

47:1 56:7

given 11:15

11:17 56:20

68:15

giving 60:16

glad 19:5

glide 77:2

goal 34:22

goals 30:4

gone 63:3

66:5 66:6

68:7

gotcha 34:12

governing

67:22

graphic 54:19

54:20

great 31:22

47:9

53:23 54:1

greater 74:5

greatest

15:16

gross 46:6

group 48:3

62:5 66:8

71:7 77:11

groups 76:9

Guerrero

6:9 6:9

guess 9:17

14:13 18:17

21:24 21:24

31:24 34:15

37:21 39:22

43:21 59:23

62:4

65:18 71:12

71:13

76:8 76:10

guideline

67:2

guys 39:21

53:1 77:4

H

hand 26:10

handful 27:13

handle 39:8

handled 37:18

happen

35:14 46:25

66:22 77:4

happy 47:10

53:1

hard 47:3

70:1

haven't 11:17

11:18 29:25

30:9

60:15 63:11

72:22

haves 70:23

having 4:13

26:5

35:25 68:21

hazard

42:10 48:13

48:14

health 67:1

hear 8:23

heard 30:24

33:13

44:9

70:21 73:20

hearing 23:18

heavy 71:18

Heckman 5:5

help 14:20

22:5

39:23 52:22

54:1

68:21

75:1 75:24

helpful 40:25

48:4

49:19 49:20

50:18 59:19

72:8

72:24 76:16

helps 39:20

51:19

Hence 15:14

here's

44:25 45:1

Hey 16:21

HHCV 49:4

high 9:10

9:15 41:17

higher

12:21 36:21

highlight

38:15 49:12

72:15

highlighting

51:2

highly

64:18 74:15

hold 48:5

hope 7:6

40:16 44:16

58:1 72:4

72:16

hoped 40:12

hopefully

38:12 69:15

75:9

hopes 39:16

huge 74:17

Hugh 5:9

5:9 58:14

hypothesis

14:10

I

I'd 7:24

16:22 16:25

52:6

55:14 55:19

75:21

idea 16:18

18:21

28:4 59:16

ideal 44:20

ideas 16:15

26:11

identical

8:17
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 93

identified

22:24 68:25

identify 4:23

8:24

11:20

16:5

20:14 22:18

25:13 28:14

41:11

identifying

43:5

I'll 7:4

9:5 16:4

38:9

42:14 48:10

71:17 72:19

I'm 4:5

7:22 8:5

13:10

14:4

14:21 17:18

18:5 19:5

19:8

20:12 23:18

31:25 33:24

34:6

34:12 40:14

40:23 43:16

44:4 46:3

55:7

60:22 62:10

63:19 67:15

68:6 73:9

73:25 76:1

impact 75:13

importance

43:3 51:2

important

10:23 28:19

28:22

45:4

51:23 52:10

52:22

53:4

54:17 73:5

impression

11:5

inaccuracies

49:20

include

32:3 36:8

41:14 41:20

42:19 42:24

44:2 49:3

52:13 66:14

70:19 77:14

included 27:1

41:1 49:1

51:3

51:25 69:20

including

41:17 41:22

48:14

49:8 51:6

57:3 66:13

incorporate

65:21

incorporated

12:18 38:22

64:14

increase

73:12

increased

8:13 34:20

increasing

73:25

74:1 74:2

indeed

10:24 50:3

independent

56:13 56:14

indicated

8:11 11:4

indirect 8:21

9:24

10:22 11:16

14:7

14:11

15:3

15:11 15:13

15:15 15:24

16:7

18:14 18:18

18:24

19:6

19:12 20:14

20:15 23:18

23:20 23:21

26:19

29:4

31:11 31:14

31:19

32:1 32:3

32:6

35:22

37:3 37:9

37:11 37:14

37:18 41:22

50:22 69:3

indirects

37:16

individual

12:1

12:11 12:11

12:12 13:22

65:12

individuals

11:25

industrial

8:21

10:13 10:23

12:25

13:2 13:5

14:18

17:3

17:21 18:13

19:16 24:11

24:14

25:1

28:10

32:3 33:1

33:3 33:7

41:25

43:4

50:21 74:14

74:18

industries

42:20 65:14

74:18

industry 17:4

17:20

28:9

45:22

48:1 74:23

influent

9:2 10:2

12:25

13:3 13:6

14:18

19:6 19:9

19:15 19:23

20:4 20:8

21:18

22:4 24:6

26:7 32:2

32:5 37:5

69:4

75:23

76:1 76:5
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 94

influented

69:6

influential

64:18 64:18

influents

12:24

inform 22:5

29:10

62:8 63:7

76:14

information

12:11 12:15

13:1

13:11 14:14

14:19 18:13

20:18 20:23

20:24

23:4 24:9

24:20

26:3 26:6

26:6

26:16 26:18

28:7 28:8

28:9

28:12 28:16

28:17 28:21

29:6

29:10 30:16

37:13

39:8

42:23 42:25

43:12 47:18

47:24 48:25

49:2 49:9

49:10 50:19

51:3

51:24 52:18

56:20 56:21

57:1

58:16 58:18

61:10

63:6 65:15

informative

12:1

informs 21:25

40:16

ingredient

55:13

initial 11:7

initially

35:7

initiate

34:24

Initiative

30:12 39:12

input 19:16

19:17 24:11

45:21 46:14

56:7 72:21

instance

50:20 70:10

77:22

Institute

5:20 54:7

instruct 54:9

instructed

35:13

instrument

53:19

intend

41:20

42:6 54:21

intended

13:12 54:19

intending

43:9

intends 59:18

intent 16:2

intention

62:22 64:16

interest

14:17 27:25

29:5

29:13 29:18

36:2 37:9

51:21 56:18

interested

10:12 10:21

10:25

11:6

11:19 14:16

27:22 35:25

41:21

49:6

60:10

61:2 68:3

69:20 70:13

72:24

73:7

76:21

77:5 77:7

Interesting

68:14

interests

35:21

interim

64:7 69:16

interpreting

30:25

introduced

50:1

introduction

42:8 49:8

49:16

inventory

49:11

invertebrates

51:15

invited 68:15

68:17

inviting 44:3

isn't 18:9

78:1 78:1

issue 26:13

35:20 35:21

69:7 69:8

75:3 76:25

issues 7:3

40:7

48:21

66:2

66:10 68:20

68:25

69:2

69:12 69:16

70:3 78:2

it'd 49:20

item 7:13

39:22 68:23

items 4:17

45:5 52:17

I've 30:24

72:15 73:20

J

Jennifer 4:25

4:25 31:5

59:22 65:22

job 47:9

Joe 6:12 6:12

joining 6:24

jurisdictions
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 95

59:2

K

Karen 6:7 6:7

6:15 6:15

36:20

Karluss

5:12 5:12

7:15 7:16

7:21 7:23

9:12 9:19

9:22 9:25

10:4

10:24

11:3

11:17 11:25

12:3 12:7

12:14 12:22

13:10 13:15

14:4

14:13

16:2

16:16 16:21

16:23 18:10

18:17

19:9

19:12

20:6

20:11 20:17

21:2

21:19 21:23

22:9

22:16

26:5

26:14 27:24

29:8 32:8

34:6

34:13 36:16

37:10 37:20

43:18 49:15

52:8 59:1

59:16 59:25

60:3

71:12

75:1

76:15 78:5

Kathy 5:10

5:10 5:13

5:13 7:9

10:10 10:17

11:4 11:8

11:11 11:14

13:24 18:12

19:15 19:19

19:22 19:25

20:12 20:25

23:8

23:14 23:17

23:19

24:1

24:18

25:2 25:9

25:16 25:22

26:2

26:16

28:4 28:5

29:19 29:20

29:25

30:6 30:9

30:23

31:2 31:4

31:7

31:13 31:20

31:25 32:21

38:21

39:1

39:24 40:19

40:23 48:12

50:13

54:3 54:5

54:11 55:24

61:12 65:18

Keller 5:4

key 37:9

52:11

Kim 6:17 6:17

kinds 59:8

66:6

known 67:2

Koch 6:8 6:8

Kristen

5:23 5:23

L

lack 21:24

37:1

lagoon 9:21

lagoons 36:5

laid 53:8

Lake 30:21

30:22

large 74:16

last 10:11

11:5

16:11 34:14

34:18

70:7 77:14

later 19:3

53:2

laying 76:24

leads 65:19

least 23:5

61:5 72:4

let's 4:4

4:22 10:3

15:1 25:5

32:22 56:11

57:21 62:12

letter 8:11

34:18 71:15

72:15 73:2

level 36:21

71:1 71:9

levels 19:1

51:10 51:11

51:12 51:13

Lewis 4:4 4:5

5:16 6:18

6:23 25:7

25:15 76:19

life 42:18

lift 71:19

likely

32:18 59:10

74:20

limit 27:20

limitations

53:12 53:21

limited 52:14

limits 49:24

linked 15:22

Lisa 5:6

5:6 45:7

list 4:9 27:5

56:23

61:8 61:13

listed

49:10 60:21

61:19

listing 49:11

61:8

literature

42:19

little 9:16

19:2 30:7
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36:14 56:1

live 70:24

Liz 6:6 6:6

load 33:1

loading

12:2

12:20 12:21

15:17 15:25

loadings

12:11 32:14

logic 16:8

logistics 4:8

7:3

loss 55:3

lot 38:8

38:18

43:2 47:1

47:2 47:6

lots 74:17

low 9:10

lower 36:21

Ludwiszewski

5:21 5:21

M

magnitude

22:8

main 24:23

Mait 6:19

6:19

16:21 16:24

16:24 17:10

17:18

man 56:13

manage

56:14 60:7

managed 30:20

management

28:24 32:11

41:10 53:19

62:8

69:11

71:1 71:17

mandatory

50:1

manufacturers

12:9

manufacturing

28:10 50:20

51:8

March 4:2

77:16

margins 72:12

Mark 5:15

5:15 7:19

7:22

24:17 40:20

marker

25:10 25:14

30:19 30:25

mass 13:12

13:24 75:18

75:19

material 54:9

54:15 55:11

55:17 55:23

58:21

materials

28:1 59:8

matter

61:24 73:23

maximum 14:11

may 16:22

25:18 31:25

maybe 10:8

10:20

11:8

12:16

23:8

39:19

46:3

65:20 77:6

mean 9:16

10:7

14:18 15:19

17:15 17:16

18:20 18:23

25:2

25:24 26:10

28:5 29:5

32:9

32:22 36:23

38:12 46:23

47:16 47:25

49:17 60:12

63:18

64:7

68:11 68:18

meaning 7:13

meaningfully

40:4

means 9:13

38:18

meant 44:10

measure 51:12

measured

28:17

42:1 51:10

measurements

20:9

measuring

19:22

20:4 22:3

mechanism

40:16

media 41:18

42:2

meet 27:4

meeting 4:1

4:11 4:13

4:15 6:25

7:3 11:5

34:23

35:1 57:9

57:10 57:13

57:23 58:12

60:8 61:8

61:10

62:1

76:20 78:7

meetings 4:14

19:7

43:14 67:24

member

15:10 15:22

18:3 21:6

71:16

members 34:16

43:12 71:25

75:2

membership

17:7

mention 72:19

73:20

mentioned

37:11 43:21

75:1

Mihaich

6:10 6:10

57:17 57:20
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 97

mind 36:17

61:22

mine 11:10

misinterprete

d 10:20

missing 61:20

misstated

10:20

mode 37:18

model 13:20

42:13

modeled 65:25

modeling 4:18

11:24 13:7

models 12:8

13:16 18:6

modification

46:7

47:19 67:21

68:2 69:22

modified

10:10

modify 46:4

modifying

68:4

Momentive 5:6

5:24

money 47:3

monitor

13:8 26:23

monitored

21:10 34:20

35:22

monitoring

7:8 8:3 8:7

8:11 9:1

9:4 10:6

15:7

18:15

21:4 21:8

21:13

23:7

29:21 29:23

33:5 33:6

33:16 34:25

35:19 35:20

37:7 39:4

39:13 39:16

40:3

40:11 41:24

43:8

43:11 44:16

45:18

46:6

47:15

48:2

49:12 49:13

66:2

66:24 67:10

69:2

70:18

71:3

72:18 73:13

month 34:18

35:12 44:7

move 9:6

22:23

64:4 64:5

64:7

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moving 42:6

58:4 70:4

72:17

multiple 20:1

36:13 36:16

44:22

municipal

8:10

23:22

24:3

31:15 31:16

32:2 33:2

38:3

50:22 50:23

myself 46:3

62:14

N

NACWA 20:21

73:11 75:1

nationally

41:6

natural 25:19

necessary

18:24

26:7

32:19 53:22

68:2 69:23

negotiating

35:13

negotiation

35:6

40:18

46:1 68:7

negotiations

34:24

35:2

43:23 70:6

Nguyen 6:13

6:13

Nhan 6:13

6:13

nine 15:2

31:23

nomination

60:25

nominations

61:5

nominees 61:2

non 42:20

none 7:4

non-members

75:3

nor 27:18

Noriko 6:2

6:2

Norway 49:23

note 53:9

64:21 71:17

notes 57:22

notice 57:2

57:12 61:7

noting 31:5

novel 68:5

68:20

NPDES 27:3

O

objective

56:12

objectives

40:5

obviously

10:21

14:6

35:12

40:6

40:10

44:9

44:12 46:25
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 98

47:2

70:11 70:21

72:3 73:2

76:23 76:24

occur 49:25

offer 16:25

33:23 71:10

75:10

offered 34:4

Office 4:6

5:18

officials

59:21

oh 64:13

okay 6:24 7:4

7:6 7:17

9:16 9:20

9:23 9:23

10:1 10:3

11:3 11:3

11:12 16:20

17:9

18:11 19:18

20:10 20:11

20:25 21:16

25:15 29:17

31:4

31:20 31:22

31:24 33:11

33:20 33:24

34:11 37:20

38:16 39:15

39:19 40:23

44:20 47:21

48:12

50:8

50:10 53:23

55:15 55:21

57:20 59:25

60:4

67:15 68:24

76:7

76:15 76:17

78:3

omissions

13:21

ones 33:2

33:3

ongoing 4:6

open 8:22

opened 68:10

opening 7:1

67:24

opportunity

7:25

17:23

57:6 58:7

60:10 60:24

61:5

61:17 62:16

63:4 63:21

ORD 66:14

order 17:21

42:3

ordinarily

23:4

organic

27:8 36:9

organism 19:1

organisms

48:19 51:12

organization'

s 59:7

original

38:23 77:14

others

38:16 66:4

ought 71:9

ours 37:9

outcome

35:1 53:17

outline

4:19 7:11

23:15 39:25

40:21

41:3 42:7

49:4 52:2

52:2 65:2

outlined

59:11

outside

60:6 61:3

61:23 62:5

outstanding

69:16

overall 51:20

overview

38:18

P

P.M 4:3 78:7

page 33:14

50:16 51:4

panel 43:12

52:5

parameters

9:1 10:7

21:10

park 57:11

participants

60:9

participate

68:17

particular

25:11 25:18

54:12 56:12

72:23

particularly

53:25 66:24

parties 60:10

61:23

68:3

69:21 70:13

73:7

76:21

77:5 77:7

party 61:2

pass 7:4

passing 4:8

past 9:17

18:20

19:4

60:23 70:14

72:20

path 77:2

pathways

41:15 41:20

42:9 51:7

51:21 54:20

Paul 4:4

4:5 5:16

5:19 5:19

6:18 6:23

25:7

25:15

54:3 54:6

54:6 55:1

55:10 55:16

55:22 64:25

76:19
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 99

PCPC 6:20

peer 4:20

7:13

40:13 40:14

40:14 42:19

43:9

43:12 43:15

43:20 43:22

43:25 44:18

45:20 45:21

46:5

47:11 47:25

48:3 52:5

56:2 56:4

56:5 56:5

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56:19

57:9

57:22

58:6

58:10 60:12

60:17

62:1 62:4

63:2 63:7

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63:16

64:2

64:14 64:17

64:17 64:19

65:1

65:10 65:24

66:16 67:11

67:16

68:1 68:8

69:21

Penberthy

4:24 4:24

7:6 7:17

9:8 9:13

9:20 9:23

10:1 10:5

10:16 10:19

11:1 11:8

11:12 11:23

12:6

12:10 12:16

13:4

13:14 13:19

14:2 14:6

15:1

15:12 15:18

16:1

16:14 16:20

17:9

17:13

18:5

18:11

19:4

19:11 19:14

19:18 19:24

20:2

20:10

21:1

21:16 21:20

22:6

22:11

23:6

23:13 23:16

23:23 24:24

25:5

25:20 25:24

26:9

26:24

27:7

27:11 27:15

27:21

28:3

28:25 29:17

31:9

31:18 31:22

33:11 33:19

33:21 34:3

34:11 35:11

36:18 36:22

37:17 37:21

38:7

38:11 39:15

44:8

45:10 45:24

46:16 46:19

46:23 47:16

48:6 50:8

53:23 54:23

55:8

55:15 55:21

55:25 66:21

67:19 67:21

68:13 68:18

73:4 74:7

75:9

75:23

76:7

76:17

77:1

77:16 77:19

people 4:23

45:14

46:8

60:13 66:21

68:1

70:22 77:6

Pepin 30:21

per 57:24

percent 36:24

percentage

49:24

perform

41:6 56:17

performance

27:4 60:16

period

35:13 47:13

57:8 58:9

58:23 59:10

61:16 69:16

70:17

permit 27:3

27:20

permits 27:6

person 77:8

perspective

14:8 39:3

39:14

pertains 32:5

PH 27:10

phase 55:4

phone 4:23

6:18 6:23

physical

42:15

pick 12:21

14:7

14:10 61:4

picked 15:15

picking 60:13

60:17

picks 60:20

picture 76:4

piece 8:19

9:6 9:7

12:13

pipe 23:22

31:17

pipes 24:16

placed 49:24

plan 4:18

4:19 7:10
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 100

28:2

29:23

35:3 35:9

39:25 40:13

43:25 44:18

45:19

46:6 49:5

50:5

50:16 50:17

53:18 53:25

54:8

54:10 54:13

55:6 56:7

56:20 56:24

58:4 58:4

58:19 58:19

59:11 59:17

60:2 62:8

62:9

62:11 62:14

62:17 62:21

62:23 63:10

63:15 63:16

63:18 63:24

64:4

64:11 65:11

65:21 69:19

70:19

71:3

76:10 77:23

77:23

planning 40:1

65:17

plans 39:13

43:22

56:2

63:11 70:21

plant 31:16

74:3 75:20

plants

10:14 12:12

24:3 42:1

play 24:14

45:17 57:15

Please 4:9

pleased 73:12

Plotzke

5:10 5:10

10:10 10:17

13:24 19:15

19:19 19:22

19:25

23:8

23:14 23:19

24:1

24:18

25:2 25:9

25:16 25:22

26:2

29:25

30:9 31:2

31:7

31:13 31:20

32:21 38:21

39:1

61:12 65:18

plus 33:22

point 14:23

14:23

19:5

32:18 34:23

44:6

47:24

48:5 50:5

52:3 57:7

71:10 71:25

73:5

pointed 46:5

pollution

50:1 50:5

53:18

population

9:10

19:17

33:8 33:9

36:6 38:5

73:21 73:25

74:5 74:17

population's

12:18

portion 8:8

8:8 8:10

15:8

21:14 26:20

55:5 55:10

possibility

60:15 61:12

possible

22:10 45:3

posted 49:5

potential

15:24 23:11

32:17 41:11

48:19 56:19

potentially

57:14 65:14

POTW 8:7 8:10

12:24 13:18

14:11

15:7

18:15 19:10

19:23

24:6

26:20

29:2

31:18

32:2 33:5

34:20 35:23

36:12 37:18

38:3 69:3

73:18 73:22

74:6

74:16 74:22

75:2 75:7

76:6

POTWs 8:13

10:9

11:15

12:9

12:21 12:23

13:5 13:8

14:16

15:9

20:15 20:16

20:20

36:4 37:3

37:12 37:25

50:22

69:8

73:12 74:11

75:14

pound 54:24

practice

66:12

prefer 45:2

preferable

44:24

preference

34:25

prepare 50:5

prepared

34:23

41:3 65:2

preparing

52:1

present 54:19

presentation
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 101

4:17 4:18

7:7 7:15

presented

8:18

presenting

59:15

presumably

62:7

presumption

24:24

pretty 10:5

20:19

39:8

39:13

55:3 68:12

prevention

50:1 50:5

53:18

previous 10:8

10:9 19:7

21:5

21:15

24:2

33:23

39:7 58:8

previously

10:17

36:1 51:17

pre-work

30:17

primarily

58:17

primary 8:6

77:5

prior 38:9

57:9 58:11

private 23:22

probable

41:14

probably 17:5

28:4

57:13

71:6

73:25

75:6 75:7

probative

36:21

problem

19:7

22:13 22:19

22:23 22:24

32:17

problems

68:19

procedure

36:12

46:4 46:8

procedures

67:22

proceed

35:3

45:13 71:9

process

35:6 35:8

40:16 40:17

43:10 43:16

43:23

44:7

44:10

46:9

46:10 46:13

48:9

53:14

60:7

61:22 62:23

63:3

63:12 63:13

64:5

64:22

65:1

65:10 65:21

65:24 66:17

66:23 66:25

68:9 68:9

75:22

processes

17:11 17:14

17:16

processing

28:10 50:21

51:8

processor

18:2 18:4

processors

12:9 18:7

produce 51:11

produced

51:14

product 30:12

39:4

39:12 50:25

62:1 63:7

64:7

64:18 64:19

production

49:9 53:6

75:14

products

49:25 53:13

55:6

55:11

74:1 74:5

profile

17:3 17:12

program

8:11 15:8

30:11 30:21

45:18

48:2 50:1

70:18

programs

8:7 39:6

66:13

project 38:22

proof 64:10

properties

42:16

proportion

74:13

proposal

7:9 8:2

8:18 9:2

10:9

10:15

11:7

18:17

21:3 21:5

21:7

21:14

29:9

29:14

32:8

32:11 32:20

33:17 33:21

34:2

34:17 34:19

35:24 43:13

43:13

44:2 44:2

44:25 52:17

59:14 67:10

69:13 70:20

71:13 71:14

71:20 71:24
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 102

72:5 72:9

72:14 72:20

72:23

73:1 73:8

77:14

proposals

35:16 44:4

propose

16:8 48:18

proposed 15:9

20:8

43:11 73:16

proposing

16:3 32:6

33:17 46:21

protected

42:24

protracted

35:5

provide 43:11

53:2

53:16 60:11

60:18 61:14

63:5 77:8

provided

43:25 44:17

58:8

58:20 59:2

providing

4:17 18:13

provisional

47:14

public 4:15

43:13

57:4 57:8

58:7 58:8

58:9

58:21 58:22

58:24

59:9

59:21 61:16

63:2

67:13 67:15

publically

58:2

publicly 57:3

publish 64:6

published

63:17

pull 71:21

purportedly

15:16

purpose

42:5 46:14

purposed

73:13

pursue

59:18 66:5

pursued 23:1

putting

60:2 64:21

Q

qualifies

55:13

quantitative

41:14

question

20:13 25:25

43:19

54:3 54:4

55:2 74:12

questions 7:2

9:6 11:13

21:1

29:19 34:13

39:18 47:23

51:4 51:5

52:7

52:11

53:9

55:25 56:10

56:25 56:25

57:25 58:13

61:14 61:18

64:24

66:4 67:6

quick 49:16

quickly 70:3

quite 42:11

47:4

71:20 76:1

R

race 62:13

range 53:12

56:8

rate 74:19

Ray 5:21 5:21

reached 44:6

reading 43:24

ready 7:15

real 47:3

52:21 73:17

reality 53:6

really 23:9

33:3

37:25

41:4 42:5

49:11 51:20

52:22 54:12

54:19 61:17

62:5

63:12

65:2 67:1

68:11 71:18

73:11 73:22

75:12

reason 11:4

55:1

reasonable

20:19

reasons 24:10

56:6

reassessment

66:16

recall

11:23

15:2 18:6

65:22

receive 12:24

56:22 62:18

received 7:10

58:10 58:22

72:7

receiving

9:15

12:25 14:18

36:6 36:10

recent 37:1

recently 65:6

recommendatio

ns 60:11

recommended

73:15

record 4:10

58:24

recording

57:23

references
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48:23 51:25

reflect 53:5

reflected

55:6

reflective

38:23

regardless

18:2

register 57:2

57:12

61:7 63:17

regs 47:17

regulations

67:22

regulatory

49:10 49:17

49:23

50:3 50:6

reiterate

34:16

related 47:23

48:21

relative 49:9

release

12:4

13:12

18:7

23:11 23:20

41:15 41:19

42:9 43:2

43:5

51:16

55:4

57:12

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released 23:9

42:24 57:3

releases

13:17 13:18

13:22 18:15

18:25

21:7 22:8

22:12 23:21

28:9

28:15

29:1

41:23 41:25

43:3

50:19 50:24

54:15

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18:23 26:21

48:11

remaining

15:4 69:12

remains 21:14

remarks 7:1

remember

18:10

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75:14

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56:10 57:25

58:3

58:18

62:3

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19:16 71:16

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e 15:24

20:15 24:25

25:11

26:1

27:16

38:1 40:7

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representing

36:21

represents

71:15

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require 72:2

required

60:19

requirement

50:4

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30:13

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50:23

resolve 69:15

70:1 70:3

respect

8:25

18:20 21:25

26:17 26:20

37:14 49:22

59:18 61:25

65:15 71:13

72:25

response

64:16 64:20

72:5 72:9

76:13

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16:10 29:15

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restrictions

50:3 50:6

results 69:21

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35:15

43:8 44:1

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59:3 63:2

63:8 63:8

64:17 64:19

68:10 70:13

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40:13 40:14

42:19

reviewers

47:4

reviewing

59:17

revised

4:17 8:2

34:17 62:17

64:20 72:25

revising 58:4

revision

67:17

reworked 12:4

risk 4:19

7:10

18:21

19:3 22:1

22:5

22:13 22:17

22:18 22:21

26:16 26:22

28:7

28:21 28:22

28:23 29:11

29:16 32:10

32:11 32:13

32:15 32:16

39:25
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40:1 40:5

40:10 40:13

41:1 41:9

41:10 41:20

42:3 42:6

42:25 43:14

43:24 45:11

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45:23 46:24

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49:3

50:17

51:6

51:22 52:17

52:24 53:18

54:7

54:22 56:20

56:24 58:19

59:19

60:2 62:8

62:9

62:10 62:11

62:14 62:24

63:1 63:5

63:10 63:14

63:17 63:21

63:24

64:3 64:4

64:5

64:11 64:12

65:5 65:7

69:18 70:19

75:16 76:2

risks 41:7

41:11 48:19

river 38:19

roadmap

65:3 65:10

robust 16:9

39:13 41:8

role 76:24

room 4:22

round 67:24

route 24:23

ruled 60:15

rules 35:7

rumblings

44:22

run 7:14 7:19

39:24 55:19

RUSSEL 6:19

16:21 16:24

17:10 17:18

Russell

6:19

16:21 16:24

S

sample

75:17 76:5

samples 39:9

sampling

36:14 77:23

sanitary 38:4

SAP 17:22

satisfy

26:6 37:13

scenario 9:20

12:6

47:20 48:1

schedule 35:4

77:25

scheduled

4:16

scheduling

60:7 76:22

science 56:24

57:25

58:1

58:12 58:19

66:7

66:10 68:20

70:22

scope 40:4

42:8

42:10 42:12

50:11 50:13

52:9 53:8

scoping 66:15

screen 8:9

8:15

17:23 17:24

screening

22:22 22:22

22:25 23:3

search 28:14

seasons 30:3

second 20:7

49:23

section

42:7

42:18

43:1

43:10 48:13

48:15 48:20

48:23

49:7

49:14 51:19

51:23 54:18

73:17 75:7

sections 43:5

sediment

9:3 10:3

21:12 39:10

50:24 51:14

sediments

51:13

Seed 4:25

4:25 31:5

59:22 65:22

seeing 7:4

65:20

seeking 66:3

seem 37:7

74:6

seemed 36:1

seems 36:24

37:1

SEHSC 4:17

5:3 5:5

5:12 6:6

6:7 6:9

7:24 15:3

15:10 15:22

34:16 35:22

43:13

44:2 45:1

SEHSC's 7:8

select

11:15

13:7

14:15 16:12

30:15 30:18

56:16

selected 36:6

selecting

16:3 17:6

60:9

selection

36:9

36:12 73:22
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 105

73:24 75:2

Seltzer

5:15 5:15

7:19 7:22

24:17 40:20

senior

69:11

71:1 71:17

sense 15:5

22:7

38:18 47:19

49:2 51:4

68:1 70:17

sent 34:18

70:12

sentence

49:24

separate

40:17

separated

19:19

September

57:14

serve 37:3

served 73:21

servicing

15:10

serving 31:19

setting 46:13

several

4:16 66:9

share 8:1

39:3 77:10

sheet 4:9 4:9

Shibuya 6:2

6:2

Shinetsu 5:7

Shiseido

6:3 6:21

shooting

57:10

shower 55:14

shown 22:13

50:25

sift 61:4

sign 4:9 4:9

signed 45:8

significant

55:3

55:10 56:6

Silicone

47:23

Silicones 5:8

6:1 67:8

siloxanes 4:1

4:7 74:1

75:12

similar

38:3 39:14

site 11:24

12:1 12:8

12:20

13:7

13:16 13:22

18:6

25:17 30:13

30:13

31:7

50:20 75:7

sites 8:14

8:19 8:24

8:25 9:24

10:13 10:22

10:23

11:1

11:21

12:2 14:7

14:11 14:15

14:17

15:3 15:8

15:9

15:15 15:22

15:23 15:23

16:3 16:5

16:6 16:9

16:13

29:5

30:17 30:20

31:10 31:11

31:12 31:15

31:16 31:19

31:23

32:1

32:24 33:15

33:18 34:20

35:19 35:22

37:3 37:9

37:11 37:18

37:22 37:25

41:25 51:16

69:2 69:3

69:7

sitting 7:22

situation

44:25

66:1 67:4

68:6

situations

74:24

six 8:19 11:2

15:9

15:21 24:10

24:13 31:12

44:6 50:16

sixteen

36:4 69:9

73:15

slide 8:4

10:8 21:2

24:6 25:6

32:22 34:14

sludge 9:9

25:21 36:5

small 55:5

74:22

Smith 5:23

5:23

solid 27:9

solve 38:16

someone 11:25

sorry 20:13

31:25 34:12

40:14 62:11

73:9

sort 14:9

14:11

30:1

43:22 45:20

62:16

65:3

65:25

67:3

68:12

70:4

70:25

72:8 74:13

sought 72:21

source 51:6

58:14 58:20

sources

42:9

51:16 51:22
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 106

54:20 69:4

species 21:13

25:13 25:17

30:7

30:10 30:13

30:15 30:19

30:24 30:25

31:1 31:2

33:16 36:13

36:20

specific

12:21 13:17

25:12 30:10

36:17 64:25

66:9 67:23

specifically

25:8 30:10

specifics

77:12

spend 47:2

stake 47:1

stakeholder

53:14

stakeholders

53:16

57:3

68:16 72:22

72:25

Stan 5:1

5:1 7:12

48:8

48:11

56:1 56:3

57:7

57:18 57:21

58:17

59:6 60:1

60:4 60:5

60:14 60:25

61:6

61:16

62:9

62:12 62:20

63:23

64:1

64:15 64:24

66:13 67:12

stand 39:21

69:25 71:24

standard 67:5

standpoint

18:18

22:4

22:17

23:2

34:22 52:24

71:23

Staples 5:2

5:2

start 17:6

68:2 77:6

77:12 77:20

started 4:4

52:6

starting

44:21

state 55:18

statement

41:4 60:16

States 24:22

statistical

39:2

status 7:8

Stedeford

6:14 6:14

step 60:5

63:10

68:8 77:11

steps 4:21

39:24 64:22

68:24

Steve 5:17

5:17

Stewardship

30:12

39:4 39:12

sticking 19:5

stop 9:5

storm 38:6

straight

23:24

strategies

43:11

strategy

44:16

stream 9:14

28:13 28:16

36:7

36:10 50:21

51:8

streams 28:12

strict 29:25

strike 47:14

structure

24:10 24:21

30:1

32:25 33:9

studies 48:15

stuff 23:24

70:21 77:21

subject 46:12

59:12 59:13

59:14 61:24

68:10

submission

38:23

submissions

42:20

submit 61:2

submitted

8:12

47:24

48:3 52:5

71:15 72:6

submitting

61:23

substantial

40:8 71:21

substantive

72:1 72:14

sufficient

45:23 46:15

47:8

sufficiently

41:8 41:10

suggest

17:2

37:19 38:25

suggested

8:20

suggesting

15:7

suggests

43:24

suit 16:6

sum 34:15

summarize

48:14
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 107

summarizes

62:3

summary 8:9

49:17

supplemental

48:25

support 41:10

sure 13:10

14:4

14:22 16:23

31:21 33:14

34:1

34:10 46:18

55:7 56:3

60:3 64:9

64:23

68:6

73:25 76:1

surface 9:3

10:3 21:7

21:12

22:3

50:24 51:10

suspended

27:9

sway 48:5

T

table 20:21

72:22

taking 19:8

36:3 49:6

56:5 60:5

63:10 63:15

74:17

talk 19:2

20:7 25:7

30:24 38:20

48:8 56:1

70:22

76:8 78:4

talked 10:2

10:6

16:11 18:19

29:22

43:2 69:7

72:21 73:1

talking

25:8

33:14 43:15

45:5

57:19

61:6

63:23

64:2

65:11 69:10

target 13:2

targeted 9:10

targeting

13:5

technical

56:17

teleconferenc

e 76:22

ten 8:13 8:19

11:2 15:9

15:21 24:10

24:13 31:12

32:24 33:10

34:21

69:8

73:13 73:16

73:17 73:19

terms 4:8

4:20 7:2

8:15 10:6

26:21 35:1

36:13

53:8 60:6

60:7

63:11 63:12

68:24

71:3

72:13 76:22

76:24

test 70:24

77:23

testing 67:1

Thalight

66:14

thank 6:24

7:24

55:24

76:7 78:5

thanks 39:20

that'll 61:9

themselves

18:14

theoretically

22:14 44:13

there'd 9:16

there's 17:20

21:24 22:19

24:12 24:15

26:10 27:10

27:13

28:4 37:5

38:8

43:18

46:4 56:4

56:11 60:23

61:5

61:19 64:15

66:1 69:1

they'd 75:6

they'll

4:14

58:21 58:24

they're 12:17

18:3

31:24 35:17

36:7

38:12 44:21

67:23 67:23

77:24

third 39:5

Thomas 5:12

5:12 7:16

7:21 7:23

9:12 9:19

9:22 9:25

10:4

10:24

11:3

11:17

12:3 12:7

12:14 12:22

13:10 13:15

14:4

14:13

16:2

16:16 16:23

18:10 18:17

19:9

19:12

20:6

20:11 20:17

21:2

21:19 21:23

22:9

22:16

26:5

26:14 27:24

29:8 32:8

34:6

34:13 36:16
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 108

37:10 37:20

43:18 49:15

52:8 59:1

59:16 59:25

60:3

71:12 76:15

78:5

thoughts 8:23

11:20 72:24

throw 38:9

THURSDAY 4:2

till 69:16

timeframe

45:4

timeline

44:22 77:21

Tobias 6:25

38:17 38:25

today 6:24

56:21

72:7

72:16

73:1

73:20 77:13

today's 7:3

Todd 6:14

6:14

TOSCA 49:11

total 27:8

27:22 31:23

32:24

totally 35:17

towards

69:1 77:2

town 74:23

tox 49:12

Toxics 4:6

track 28:15

54:24 75:3

Tracy 6:9 6:9

transcriber

4:12

transcript

4:13 76:20

transpired

68:11

treat 38:4

treated 23:25

treating 38:4

38:6

treatment

8:10

10:14

14:1 22:7

24:3

24:12 24:16

24:20

25:1

26:18

27:1

27:25 28:18

29:2

31:16 37:24

38:1 42:1

69:6

73:17

74:3

74:10 75:20

treatments

8:16 24:4

24:22 25:4

Trent 5:4 5:4

15:6

15:13 15:19

19:20 33:12

33:20 33:24

34:8

45:16 46:10

46:17 46:21

47:11 47:21

60:5

60:22

61:1

61:25 62:10

62:13

63:9

63:25

64:8

64:23

68:5

68:14 77:13

77:18

TRI 29:1 29:3

tried 24:2

24:21 72:15

try 15:2

32:14

33:9

35:14

54:8

55:16 72:13

76:9 77:9

trying

17:24

18:6

32:23 45:25

54:24 63:19

67:15

turn 6:25

twelve 36:4

type 20:24

23:1 23:4

29:2 38:1

40:15 67:24

71:22 74:10

types 8:16

22:23

24:9

24:12 24:20

25:3

37:24

51:5 73:18

typically

22:21

28:6 28:7

32:14

49:3 77:3

typo 42:21

U

U.S 51:13

ultimate 30:4

53:17

ultimately

53:21

um 55:2

unaware 65:16

uncertainties

41:9

48:21 57:14

unchanged 9:1

21:14

understand

9:9 13:17

17:15 18:15

20:13 23:11

24:15 26:11

27:21 28:18

30:14 30:17

37:2

37:25

62:2 64:8

71:8
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 109

understanding

11:9

12:22 12:23

17:1

22:20

23:5

26:25

29:9

32:13 41:16

43:3 55:3

69:13

undertake

32:18

unique 66:1

66:4 66:23

United 24:22

unlike 64:17

unprecedented

68:12

upon 30:4

56:17 60:20

usually

77:3

77:11 77:23

utilize 43:9

V

Vail 6:7 6:7

valuable 65:3

65:5 65:8

65:13

value 17:4

17:15

values 17:1

variables

33:10 36:7

variety

24:3 25:3

26:18 27:10

53:13

various 24:21

62:3

Vermont 30:22

version

21:5 21:15

versions

72:20

versus 33:8

69:4 69:9

73:16 74:12

view 18:20

18:23 22:25

40:17

viewpoints

62:4

virtue 55:17

volume 49:10

voluntary

30:11

39:4

39:12 65:23

volunteers

75:5

W

Wacker 5:9

wait 48:10

Ward 4:23

4:24 4:24

7:1 7:4 7:6

7:17 9:8

9:13 9:20

9:23 10:1

10:5

10:16 10:19

11:1 11:8

11:12 11:23

12:6

12:10 12:16

13:4

13:14 13:19

14:2 14:6

15:1 15:6

15:12 15:18

16:1

16:14 16:20

17:9

17:13 17:19

18:5

18:11

19:4

19:11 19:14

19:18 19:24

20:2

20:10

21:1

21:16 21:20

22:6

22:11

23:6

23:13 23:16

23:23 24:24

25:5

25:20 25:24

26:9

26:24

27:7

27:11 27:15

27:21 27:24

28:3

28:25 29:17

31:9

31:18 31:22

33:11 33:12

33:19 33:21

34:3

34:11 35:11

36:18 36:22

37:17 37:21

38:7

38:11 39:15

41:5

43:21

44:8

45:10 45:24

46:16 46:19

46:23 47:16

47:22

48:6 50:8

53:23 54:23

55:8

55:15 55:21

55:25 66:21

67:19 67:21

68:13 68:18

73:4 74:7

75:9

75:23

76:7

76:17

77:1

77:13 77:16

77:19

wasn't 11:6

16:2 16:7

32:20

waste 8:10

10:13 12:18

24:3

26:25 31:15

31:16 69:6

wastewater

13:23 42:1

water 8:10

9:3 10:3

10:14 12:18

21:12
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 110

24:3 27:1

27:3

27:19 31:15

31:16

38:6

51:11 69:6

waters 21:7

22:3 50:24

web 30:18

website 49:5

we'd 8:23

14:20 19:22

20:2 23:7

25:22 33:15

38:13

47:6

52:12

54:8 64:5

75:5

weeks 71:5

71:7

76:11 76:14

76:23 78:4

we'll 4:12

4:19 4:23

7:7 7:14

45:14

50:8

50:10

57:1

64:12

66:7

66:11 69:15

70:17 72:13

75:9

76:10 76:12

76:21 78:3

Wendy 6:8 6:8

we're 4:8 8:9

10:14 10:21

19:2 20:7

22:2

26:23 27:16

27:22

28:6

32:23 33:14

33:17

34:6 34:8

35:13 35:15

36:24

38:3

38:23 42:11

43:9

45:12 45:14

45:19 45:25

46:13 46:21

46:23

47:9

47:13

48:8

50:11

51:5 53:1

54:24

56:5 56:7

57:10 57:15

59:6

60:17

64:1 64:6

64:9

64:21

66:2

68:20 69:25

70:2

73:11 77:24

78:1

we've 4:14

18:1

18:19 20:20

21:5

29:22 30:20

34:20 35:18

38:22

39:5

39:11

43:2

45:11 48:23

50:24

51:3

51:25

53:4

56:21 60:21

62:23

66:5 68:7

69:10 70:21

70:24

72:7 73:1

whatever

26:13

46:6

64:11 64:11

WHEREUPON

78:7

whether

18:3

45:22 46:15

49:10 69:22

whole 25:3

43:24

47:6

63:10 65:24

68:19

who's 61:11

willing 14:21

14:25

16:4

20:22

34:4 71:8

willingness

34:19

wondering

44:4

work 11:24

14:21 14:25

16:4

20:22

28:2 35:3

35:9

36:25 38:14

46:11

47:3 49:4

50:17 51:21

60:16 61:25

62:21 62:23

63:11 65:21

67:19

69:1

76:21

77:9

77:25 78:1

worked 39:11

working 16:12

57:15 75:19

77:7

77:12 77:20

world 15:24

45:12 50:7

worried 26:12

worst 9:17

14:10

wrap 7:14

written

53:3 53:24

wrong 54:1

Y

yesterday

65:6

you'll 10:8

26:19
Siloxanes ECA Negotiations Meeting March 28, 2013 VR # 115-1 Page 111

you've 14:8

25:3 53:8

65:19