SILOXANES ECA MEETING

 UNITED STATES ENVIRONMENTAL PROTECTION

 U.S. EPA

 ROOM 1117A, EPA EAST

 1201 CONSTITUTION AVENUE NORTHWEST

 WASHINGTON, DC 20460

 SEPTEMBER 20, 2012

 1:00 P.M.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 2

1 APPEARANCES:

2 BETSY CARLTON, BLUESTAR SILICONES

3 LISA DUMARS, MOMENTIVE

4 ELLEN MIHAICH, BLUESTAR SILICONES

5 HUGH FLACK, WACKER CHEMICAL CORP.

6 GENE BROWNING, SHINETSU SILICONES OF AMERICA

7 SCOTT DYER, PERSONAL CARE PRODUCTS COUNSIL

8 JOHN F. KROWKA, PERSONAL CARE PRODUCTS COUNSIL

9 RUSSELL MAIT, EVONIK GOLDSCHMIDT CORP.

10 KATHY PLOTZKE, DOW CORNING

11 KARLUS THOMAS, SEHSC

12 CHARLES STAPLES, SEHSC

13 TRENT M. DOYLE, KELLER AND HECKMAN, LLP

14 CATHY FEHRENBACKER, EPA

15 WARD PENBERTHY, EPA

16 PAUL LEWIS, EPA

17 MARCUS AGUILAR, EPA

18 KAREN EISENREICH, EPA

19 PAUL DeLEO, AMERICAN CLEANING INSTITUTE

20 RAY HILEY, MOMENTIVE

21 KEVIN WEST, MOMENTIVE

22 CYNTHIA FINLEY, NACWA

23 PATRCIK GRIFFITH, LA COUNTY SANITATION DISTRICT

24

25
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 3

1 U.S. EPA

2 SILOXANE ECA MEETING

3 AUGUST 7, 2012

4 MR LEWIS: Okay. Several people just dialed

5 in and I just wanted to begin by welcoming everyone to

6 today's meeting discussing our siloxanes ECA.

7 Again, this is Paul Lewis. I'm with EPA

8 Environmental Control Division and you should all have

9 the agenda for today's meeting and the focus is to

10 discuss EPA's revised siloxanes monitoring proposal and

11 this gives interested parties the opportunity to

12 provide feedback and really our goal for today is to

13 determine if a consensus can be reached by the

14 interested parties of each of the major parts of the

15 proposal, direct discharge sites, indirect discharge

16 sites, and POTWs.

17 Following introduction, there is going to be

18 a very minor, slight change in terms of the agenda for

19 today's meeting.

20 I want to first focus on the POTW discussion,

21 then go into the direct discharge sites, followed by

22 indirect discharge sites, and then from there the

23 sampling details from all the sites. We have an

24 opportunity for input from the stakeholder community,

25 next steps, and then adjourn.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 4

1 We plan to have this meeting run from one to

2 about four o'clock today and again, our goal is to help

3 get consensus in terms of this ECA agreement.

4 To begin, I'd like to first go around the

5 table. If everyone could introduce themselves and

6 their affiliation. And again, speak into the

7 microphone because this meeting is being recorded.

8 MR. PENBERTHY: Ward Penberthy with the EPA.

9 MS. FEHRENBACHER: Cathy Fehrenbacher, EPA.

10 MR. DOYLE: Trent Doyle, Keller and Heckman

11 and outside counsel to SEHSC.

12 MR. STAPLES: Charles Staples for the SEHSC.

13 MR. THOMAS: Karluss Thomas with SEHSC.

14 MS. PLOTZKE: Kathy Plotzke with Dow Corning

15 on behalf of SEHSC.

16 MR. MAY: Russell May, Evonik.

17 MR. KROWKA: Joe Krowka, Personal Care

18 Products Council.

19 MR. DYER: Scott Dyer, Proctor and Gamble

20 representing PCPC.

21 MR. BROWNING: Gene Browning representing

22 Shin-Etsu Silicone Group of America.

23 MR FLACK: Hugh Flack with Wacker Chemical

24 Corporation.

25 MS. MIHAICH: Ellen Mihaich with Bluestar
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 5

1 Silicones.

2 MS. DUMARS: Lisa DuMars with Momentive.

3 MS. CARLSON: Betsy Carlson, Bluestar

4 Silicones.

5 MR. AGUILAR: Marcus Aguilar, EPA.

6 MR. LEWIS: If we could also go around the

7 perimeter of the room here and identify yourself and

8 speak into the mic?

9 MR. STEVENS: Rick Stevens, EPA's Office of

10 Water.

11 MS. DANESI: Robyn Danesi, EPA's Office of

12 Water.

13 MR. AVCIN: Joe Asta, Branch.

14 MR. NGUYEN: Nahn Nguyen, EPA.

15 MS. DONOVAN: Yvette Donovan of EPA.

16 MS. KEATING: Elaine Keating, EPA.

17 MS. MEASURY: Keira Measury, EPA.

18 MR. TOBIAS: David Tobias, EPA.

19 MS. GUERRERO: Tracy Guerrero, SEHSC.

20 MS. KOCH: Wendy Koch, Consultant to Evonik.

21 MS. WILKINSON: Jenny Wilkinson, reporter for

22 the EPA.

23 MS. BARKAS: Jessica Barkas, EPA.

24 MS. BELL: Jessica Bell, EPA General Counsel.

25 MR. ANDERSON: Steve Anderson, EPA House
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 6

1 Counsel.

2 MR. LUCHESKI: Ray Luckeski.

3 MR. LISCOE: George Liscoe, Keller and

4 Heckman.

5 MR. LEWIS: Thank you. That identifies all

6 individuals that are present in this meeting room.

7 We also have several that have called-in.

8 Can you please identify yourself?

9 MR. DELEO: This is Paul DeLeo with the

10 American Cleaning Institute.

11 MR. HILEY: This is Ray Hiley, Momentive.

12 MR. LEWIS: Can you repeat yourself, please?

13 I didn't catch the last two.

14 TELEPHONE SPEAKER: This is (Inaudible).

15 MR. WICKER: This is Kent Woodburn from Dow

16 Corning.

17 MR. KOZERSKI: This is Gary Kozerski from Dow

18 Corning.

19 MR. KIM: Jaeshin Kim, Dow Corning.

20 MR. POWELL: David Powell, Dow Corning.

21 MR. GRIFFITH: Patrick Griffith, LA County

22 Sanitation District.

23 MS. PERRICANE: Lisa Perricane, Wacker

24 Corporation.

25 MS. GRAM DeMURPHY: Andrea Gram DeMurphy
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 7

1 MR. LEWIS: Is there anyone else on the phone

2 or in the room that hasn't identified themselves?

3 Okay. Thank you.

4 Before I turn the meeting over to Ward

5 Penberthy, I just want to remind everyone that all the

6 materials for this meeting is available in the public

7 docket. In addition, we will be preparing a transcript

8 of this meeting. That will also be available in the

9 public docket.

10 Are there any questions in terms of the

11 operations of the meeting this afternoon?

12 MR. AGUILAR: One more thing, there is

13 a...this is Marcus Aguilar. There is a sign-up sheet

14 going around, so if you would please record your

15 information, that would help us make sure that the

16 transcript is accurate and also, if you could, state

17 your name before each comment, that way, the transcript

18 will be more accurate. That would really help us out.

19 MR. LEWIS: Thank you.

20 MR. PENBERTHY: Well, thanks everyone for

21 coming and participating. I'm looking forward to your

22 input.

23 In addition, for today's meeting, obviously

24 we have revised our monitoring proposal and sent that

25 out and that's what we really want to discuss today.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 8

1 There were also comments and I hope that you also

2 received by email by the American Cleaning Institute

3 and NACWA. Those will also be in the docket and if

4 there, at some point during the meeting,

5 representatives of each of those organizations want to

6 express their comments related to the...from those

7 letters related to the issue that we discussed, that

8 would be very comfortable.

9 Let me just give you a brief overview of the

10 EPA revised proposal. That was developed based a lot

11 on the work of the groups seated at previous meetings

12 which has been very helpful, so we appreciate that.

13 It's also been a lot of contact with other parts of the

14 agency and a lot of colleagues, our regional offices,

15 and other parts of the EPA that have provided some

16 counsel on how to develop this monitoring plan.

17 Basically, you all know that monitoring

18 proposal history components, the industrial sites with

19 direct discharges to industrial sites with indirect

20 discharges and the publicly-owned treatment works.

21 I think the first two that I mentioned, the

22 industrial sites, are pretty self-explanatory. I think

23 over the past, in the past meetings which has been the

24 issue of greatest concern and greatest amount of

25 discussion is exactly how we should approach monitoring
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 9

1 the POTWs that receive siloxane releases, so obviously

2 we've spent a lot of time on that.

3 In our initial proposal from prior meetings

4 we had several key factors we wanted to look at. Based

5 on the discussions with this group and the

6 consultations with others, we've narrowed those key

7 factors significantly to the population served by the

8 POTW treatment method and the flow rate of the

9 receiving body, but also wanting to keep track in the

10 monitoring effort the organic content of receiving

11 water body and geography.

12 So basically what we've proposed as far as

13 POTWs is basically 16 POTWs, 12 of which would be

14 activated sludge. They would be in a variety ofthey

15 would serve a variety of populations and flow rates. I

16 think the matrix is pretty well laid-out and how we got

17 to it and some of the factors and considerations we

18 used to develop it.

19 Then finally in the proposal there's some

20 sampling details for all the monitoring sites and so

21 we'll get to that later on the agenda today.

22 So with that, maybe we should start off on

23 the first item on the POTWs, unless there's any other

24 interjections that anyone would like to note.

25 Okay.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 10

1 MR. THOMAS: Okay. I can start and before I

2 start, I'd just like to thank EPA again for the

3 opportunity to continue these discussions and I guess

4 my first question is one more of clarification with

5 respect to the agency's suggestion for the POTW

6 monitoring. In particular, there was a note that the

7 agency thought that the range of POTWs that should be

8 monitored should account for the uncertainty and

9 variability associated with different factors and I

10 know that there are other that are going to be able to

11 speak much more than I can about the specific factors,

12 but I was just hopeful that you guys could give a

13 little bit more feedback on how the 16 addresses the

14 uncertainty and variability. It wasn't clear to me in

15 the proposal how specific do the 16 sites allow some

16 understanding of the variability and uncertainty.

17 MS. FEHRENBACHER: This is Cathy Fehrenbacher

18 from the EPA and I think as Ward described in coming up

19 with the 16 we really considered the prior discussions

20 and the interests and I think among all of the

21 interested parties in having a practical, yet efficient

22 way of understanding the amount of concentrations

23 associated with the POTWs.

24 So we also, I think, made it very clear in

25 the past meeting that we thought five was far too few
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 11

1 because there are, depending on how you count them,

2 there are about 4,500 or so activated sludge treatment

3 plants in the U.S. and around 3,000 or so lagoons based

4 on the information that we have and so really

5 considering the variables and the types of geographic

6 locations and the types of treatment processes, Ward

7 again reviewed the factors we considered and these are

8 the factors that we believe are the most important in

9 helping to understand the variability between the

10 facilities as well as the uncertainty or the lack of

11 knowledge of those factors that are contributing to the

12 environment concentrations, so it's really a

13 combination of our understanding, our inputs from the

14 regions, and our Office of Water has been quite

15 involved in supporting this activity with us behind the

16 scenes. So it's really a combination of things.

17 FEMALE SPEAKER: Yeah and maybe that kind of

18 brings up the factors and so I think we've had some

19 comments in some of the other stakeholder's responses

20 as well and as well as we take another look at the

21 critical factors and I think that maybe what Karluss

22 was getting at with the design aspect of it, it comes

23 back to what you're trying to achieve and what's the

24 most appropriate design that's needed to do the risk

25 assessment aspect of it.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 12

1 I think with these materials and the

2 understanding that we have and the data that we have

3 for the chemical and physical properties as well as the

4 environmental monitoring, I think we can, with

5 confidence, get what factors are going to be critical

6 and so we provided in the past, for the last conference

7 call we did provide a document on behalf SEHSC,

8 prepared by Jaeshin Kim and I know we had some

9 discussion about it and we still fully support those

10 factors that we have identified as being critical. We

11 may provide additional detail comments on the ones that

12 you have indicated like the known population size and

13 service and things like that.

14 I really think that the knowledge that's

15 available on this material already gives us quite a bit

16 of that information around the uncertainty and what

17 type of levels that you would see when you factor in

18 those different parameters.

19 MR. DYER: Scott Dyer, Proctor and Gamble,

20 representing PCPC.

21 I definitely do recognize the numerical issue

22 with lagoons as definitely being a primary source of

23 treatment within the United States.

24 One of the concerns that we have with the

25 selection of lagoons is their inherent properties to
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 13

1 really treat this waste. So, for instance, we know

2 that these are on the scale of treatment, the poorest,

3 really. They typically discharge greater degrees of

4 DOD, suspended solids, and ammonia.

5 Downstream from these municipal discharges,

6 there's more likely to...actually, these municipal

7 discharges are more likely to have an SNCE, a

8 significant noncompliance event, and we've done a

9 probability analysis and found this to be true.

10 Also one of the things that concerns us is

11 that with these discharges of conventional pollutants,

12 we could actually get ourselves into a situation where

13 you're basically just guilty by association because

14 downstream, on a typical lagoon, you're going to have

15 biological perturbations on the typical, on the average

16 lagoon.

17 So another interesting thing in our analysis

18 and this is in conjunction with the American Cleaning

19 Institute in investigating the lagoons is really kind

20 of looking at the distribution of the population

21 loading into the POTW. Typically, lagoons service low

22 population areas that are in rural environments. It's

23 very, very difficult to find high population loading in

24 POTWs that correspond to the lagoon or stabilization

25 pond types of treatment, so they're actually going to
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 14

1 be really on the rarity.

2 So one of the things that we were curious

3 about and would like to ask some questions about is has

4 the agency considered some of these issues that are

5 common to this type of treatment in the design.

6 MR. PENBERTHY: Yeah, I think we have and

7 clearly we recognize that it might not be lagoons that

8 have high populations and low flows and it might not

9 just be a physical circumstance. You don't know until

10 you do it.

11 MR. GRIFFITH: Hi, this is Patrick Griffith

12 with the LA County Sanitation District. I have a

13 couple of comments.

14 My first comment is there's a lot of white

15 noise on the line that I know that even if you think

16 you're being quiet, for you folks that are calling-in,

17 it still helps if you mute your line. That might help

18 with some of the white noise.

19 The second comment has to do with the lagoons

20 and we, or actually our student-worker, took a look at

21 the 2008 Clean Water Needs Survey Database and I think

22 the largest lagoon plants served about 70,000 people

23 and we actually have two plants that we operate that

24 are lagoon plants. Actually, one of them since the

25 2008 survey converted over to activated sludge and the
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 15

1 other one is undergoing that process as well. So

2 there's definitely an upper limit to what lagoons or

3 the population that lagoons may serve.

4 MS. PLOTZKE: This is Kathy Plotzke from Dow

5 Corning.

6 Just one other comment coming back to the

7 factors and in particular the population size or

8 population served, you know, we do have the ability and

9 we have done modeling exercises that look at what you

10 would basically expect around these different

11 variables. You can actually do that and run the

12 modeling exercises to look at the sensitivity around

13 these variables and even though some of them would lead

14 to variations in the siloxane concentrations, when you

15 actual go out and model what those effluent

16 concentrations would be based on per capita use and

17 that type of aspect, what you find is that it's going

18 to be below the detection limit anyway, so even if you

19 have variability over a range, it still is found or

20 predicted to be at below the detection limit and that's

21 consistent with quite a bit of these effluent

22 monitoring that has already been done in Canada and

23 other places around the world.

24 So I guess, in summary, I think we have some

25 tools already and quite a bit of knowledge that we
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 16

1 could better fine-tune those factors for this site.

2 MR. PENBERTHY: Do you have a specific flow?

3 MS. PLOTZKE: We could definitely provide the

4 modeling exercise that Jaeshin has just completed that

5 demonstrates that, yeah.

6 MR. LEWIS: Yeah, I don't think we're so much

7 interested in modeling as, in its own right, as we're

8 interested in monitoring. That's what we're trying to

9 develop, a monitoring program, so we've made a

10 proposal. Do you have modifications to this proposal

11 or some other method where you would select facilities

12 if that's what you're getting at?

13 MR. THOMAS: I appreciate that and I know

14 that's where we're ultimately going, but I just want to

15 make sure that I have a full understanding of the

16 scientific rationale behind how the existing proposal

17 was developed and just harkening back to the conference

18 calls we had, we had a couple of technical conference

19 calls, the intent of which were...the first one I think

20 we wanted to walk through our rationale for the

21 identification of the five sites and part of what I

22 wanted to make sure that I have is a complete

23 understanding of the scientific rationale for the

24 existing proposal and I just want to make sure I'm

25 clear on the factors in particular.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 17

1 We kind of laid out those factors that we

2 thought were important for site selection. We also got

3 some feedback from a number of the stakeholders

4 regarding site selection factors. Scott just spoke to

5 some of those. I also saw some feedback and at least

6 one of the stakeholder comments with respect to

7 selection factors and my impression was that the

8 ultimate factors that the agency used were not

9 consistent certainly with the feedback that we had

10 provided and also some of the feedback that you got

11 back from some of the other stakeholders, so I just

12 wanted to make sure that I had a full understanding of

13 the reasoning the agency used with respect to moving

14 forward with some of those criteria when guidance was

15 provided that some of them may not be appropriate.

16 MS. FEHRENBACHER: This is Cathy

17 Fehrenbacher.

18 I do appreciate where you're coming from, but

19 we really spent a lot of time in the proposal

20 describing the rationale regarding the factors that we

21 chose and I think it would be helpful if we could take

22 a few minutes and just walk through the rationale for

23 the factors.

24 MR. PENBERTHY: That's fine. In addition,

25 when you look at how the matrix was designed, the
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 18

1 intersection of the population is low, I think that was

2 directly out of your comments, so I think we did try to

3 take in and address your comments as best we could with

4 our proposal, so, you know, we definitely heard you.

5 We definitely got your feedback. We definitely

6 accounted for it and I think it's here on the paper.

7 MR. THOMAS: Are we going to still walk

8 through some of this?

9 MS. FEHRENBACHER: So if you look at page two

10 of the proposal, in the middle of the page it lists the

11 key factors that we believe are critical in choosing

12 the number and type of areas.

13 The first one is population served and we

14 believe that a POTW that serves a large population and

15 a low influent would theoretically result in a worst16 case or the greatest mass and the highest concentration

17 of siloxanes being fed into the POTW.

18 Similarly, a POTW serving a small population

19 but receives a large influent flow would represent a

20 best case as the smallest mass and lowest concentration

21 of siloxanes are being fed into the POTW.

22 The second factor is treatment method used at

23 the POTW and activated sludge is the method used to

24 treat about 80 percent of the volume of waste water

25 across the country. Lagoons are a common method and
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 19

1 generally serve smaller communities and in certain

2 areas that Scott's compared.

3 There are additional treatment methods that

4 are used less frequently and we have not included those

5 methods as the focus of suffer, it does not make sense,

6 we were focusing on the two most commonly used

7 treatment methods.

8 The flow rate of the receiving water body,

9 the amount of dilution provided by the receiving water

10 body could impact concentrations of siloxanes in water.

11 I think that's fairly straightforward.

12 Then there are additional factors of interest

13 for monitoring and monitoring efforts leading to

14 organic content and receiving water body. We believe

15 that siloxanes will partition preferentially to solids,

16 I think there is some disagreement there.

17 We also understand that it would be difficult

18 to identify POTWs for potential monitoring based on

19 this factor, so there would be value in sampling

20 several POTWs that do discharge to a receiving water

21 body with high organic content. We do believe that

22 that would be important so that you will understand,

23 and again, the variabilities associated with high

24 organic content versus not so high, et cetera.

25 Geography, environmental condition in
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 20

1 different parts of the country could affect the

2 partitioning and sedimentation of siloxanes due to the

3 very nature of watersheds. Again, this gets into your

4 question about variability and uncertainty. We do have

5 a variety of different watersheds in the country, and

6 so we would, during the monitoring, hope to consider

7 factors such as temperature and other variables that

8 impact partitioning both during and after treatment.

9 So those are the factors and variables and

10 the rationale that we've included in the proposal.

11 MS. PLOTZKE: I think maybe if we break these

12 out into pieces from a selection of waste water

13 treatment type, then some of those factors become

14 important and I think the only one maybe that was

15 consistently questioned through, I believe, NACWA as

16 well as ACIs and PCPC has also indicated this as well.

17 It's really the inclusion of those, so I don't think we

18 have any disagreement about activated sludge. Your

19 justification around the inclusion of the activated

20 sludge and the actual exclusion of the other types is,

21 you know, very appropriate.

22 Maybe the next question is, is it necessary

23 beyond activated sludge to include lagoons based on

24 some of the comments that have already been made by

25 NACWA, ACI, and PCPC that have had quite a bit of
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 21

1 experience. That's what we're relying on, too.

2 They've had quite a bit of experience already, not with

3 these materials, but doing monitoring on these types of

4 plants.

5 So I think that's probably one of the biggest

6 questions is one that has to do with lagoon access to

7 the type of treatment and then maybe we'll get into the

8 overall design and the numbers. You can use that

9 matrix to do that, too, and there's other ways.

10 MR. PENBERTHY: But in your original proposal

11 you suggested monitoring lagoons.

12 MS. PLOTZKE: Yeah, in fact, what we have

13 done in our proposal is really responded to what we

14 heard from you as to what you would like to see in

15 different types of treatment types, so the proposal for

16 the five municipal waste water treatments try to

17 incorporate your requests of having that variation in

18 treatment types.

19 I think as we've gone through the process and

20 had discussion, like we all agree that probably the

21 most important one is the activated sludge. We agree

22 with that and then the next question is is there really

23 any value in going beyond activated sludge for really

24 understanding the typical aspect of what you would see

25 here in the United States because I know you haven't
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 22

1 even made comments regarding ...

2 MR. PENBERTHY: Well, there's 3,000 lagoons

3 in the United States, and 4,500 activated sludge

4 facilities, so what's the difference there?

5 MS. PLOTZKE: That I'd open up to either

6 Scott or Paul here on the phone, or Cynthia.

7 MR. PENBERTHY: I thought Scott's comments

8 were pretty much described in the lagoon is eventually

9 worst-case.

10 MR. DYER: Okay, this is Scott Dyer again.

11 They're worst-case based on the water quality

12 that's being discharged. Even another examination at

13 the state level and even at the regional EPA level,

14 it's very common that you'll see that the water quality

15 criterion values in each of those conventional lagoons

16 are a little more relaxed for a lagoon than they are

17 for that of activated sludge and I think that's just

18 pragmatism speaking.

19 I think what we're concerned about, though,

20 is that just the process of, you know, absorption,

21 settling phenomenon going on with the lagoons. You've

22 got also intermittent discharge. Some of these lagoons

23 actually don't discharge during 7Q-10 flow. So these

24 are other factors that adds, if you are to include

25 lagoons, that there's another whole layer of selection
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 23

1 criteria that we really need to take into account

2 because they're not, again, most of them are not

3 continually discharging and so if we want to look at

4 the four corners, you know, where we're including the

5 lagoons, you know, there's another layer of

6 understanding that I think needs to be taken into

7 account.

8 MR. PENBERTHY: So how should we pick lagoons

9 then?

10 MR. DYER: Well, I think for one thing, the

11 very first thing is we need to make sure that they do

12 not have a history of SNCEs or E-90s. These are codes

13 that are found within ISIS NPDS or the permanent

14 compliance system. So these are codes that basically

15 tell us whether or not there's some violations in the

16 past. These can range from clerical errors to actual

17 water quality violations, so we can easily query the

18 database to see whether or not these waste water

19 treatment plants are in compliance.

20 If they're in compliance and reach water

21 quality goals that are consistent with activated

22 sludge, then I think you could probably put them into

23 the category of, you know, "maybe." You're still going

24 to need to examine the intricacies that lagoons still

25 have on their discharge characteristics, so even though
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 24

1 they may have decent discharge quality, you still need

2 to make sure that they're going to be discharging

3 enough throughout the year for you to actually get

4 downstream, upstream, you know, comparison with that of

5 the source water information for your siloxanes

6 monitoring.

7 So you could do that by looking, for

8 instance, on the dilution factors for the lagoons at

9 72-10. The question that I have and one of the tools

10 that actually we've had the privilege at ACI and coming

11 and talking with your exposure branch, Cathy is talking

12 about the model ice stream. You can actually use that

13 model to see whether or not you're going to get

14 perennial flow upstream from your municipal sites.

15 It's a very, very easy and publicly available model and

16 it uses U.S. EPA data. So that's another tool that we

17 can use right off the bat that can really be helpful to

18 narrow the scope. And what I think we're going to find

19 is that there will be lagoons that can meet, but we

20 need to be careful in the screening of them and need to

21 make sure that they're meeting their water quality,

22 their legal aspects, as well as actually going to be

23 discharging to a flowing body of water.

24 Was I clear on that?

25 MR. PENBERTHY: Yeah, I understand the
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 25

1 discharge volume. I don't understand the compliance

2 record given. It would seem, I mean, I think there

3 would be some people that monitor facilities that

4 weren't in compliance preferentially. Wouldn't you

5 think? So why is that a relevant factor?

6 MR. DYER: Well, again, if you're trying to

7 create a national risk assessment for these materials,

8 you're going to want to be using waste water treatment

9 plants that are being well-operated within the

10 parameters in which they've been designed. So if

11 they're overbuilt, they're not being run appropriately,

12 that's, I think, a signal that says that perhaps that

13 these are not really the best places to go monitor as

14 being representative for being that particular

15 treatment type class. That's what I'm trying to say.

16 MR. PENBERTHY: Okay, so ...

17 MS. FEHRENBACHER: This is Cathy

18 Fehrenbacher.

19 I think that that's a different ... we're not

20 near intending to develop a risk assessment that

21 accurately represents environmental concentrations in

22 the media in the United States. We're not intending to

23 develop a risk assessment associated with

24 representative POTWs in the United States.

25 MR. THOMAS: So Cathy, just to follow-up on
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 26

1 that, this is Karlus, SCHSE.

2 The idea that you're not necessarily

3 interested in representative POTWs, I think part of my

4 interest in the factors was because it's essentially

5 those factors that are going to drive the matrix; and

6 essentially drive them towards the appropriate number

7 of facilities to monitor and that's why I was

8 especially interested in your thoughts about some of

9 the factors.

10 The one that I thought about the most was the

11 notion that the population served by the POTW and the

12 extent to which that was included as a factor. We got

13 some feedback from a number of the stakeholders on

14 that, so the removal or addition of these factors is

15 going to drive the number of sites, obviously. So that

16 was just my interest there, just to clarify that.

17 I guess with respect to the lagoons in

18 particular, and I know the agency had some difficulty

19 with some of the Canadian database on what I read in

20 the proposal, and again, the whole reason for our

21 proposal was to try and focus-in on monitoring that

22 would allow EPA to develop a worst-case risk assessment

23 of the materials and I guess certainly from our

24 standpoint the Canadian data is representative of the

25 situation in the U.S. and there's no reason to exclude
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 27

1 it. I think that feedback was also provided from at

2 least one of the other stakeholders and I would say

3 those are non-sites and there were some lagoons there,

4 there is some information that could be gleaned that

5 would certainly be helpful in the context of a risk

6 assessment and I think we ought not reject that out of

7 hand.

8 So certainly, I think we could use that to

9 form additional data that we collect here for the

10 purposes of a risk assessment.

11 So again, I guess where I'm driving this is

12 that I think the proposal that was developed with the

13 five sites, and I did see all of the feedback with

14 respect to it being anecdotal and not necessarily would

15 allow you guys to do what you wanted to do, but I just

16 wanted to make sure that I had a complete understanding

17 of one, what was driving the selection of the critical

18 factors because, again, that's going to drive you to

19 the number of sites that you're going to use to develop

20 the risk assessment, and some of the feedback, not only

21 from us, but from other stakeholders as well, with

22 respect to some of those factors, suggested that they

23 could be eliminated without doing any disservice to the

24 quality of the risk assessment.

25 MS. FEHRENBACHER: I think in the proposal on
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 28

1 the top of the second page addressed that issue as well

2 in terms of our goal for the monitoring and developing

3 standpoint.

4 MS. PLOTZKE: I guess maybe with the proposal

5 and I invite Cynthia, she's on the line as well, to

6 comment because looking at their comment, they

7 basically do believe that the lagoons that were

8 monitored in Canada are representative of the United

9 States and so I do think we have a data set there that

10 already gives us quite a bit of information on lagoons

11 and so having activated sludge and lagoons represented

12 in the United States is reasonable and then it's what

13 additional information is really needed and understand

14 and verify what's already known about lagoons.

15 MR. PENBERTHY: But while the Canadian data

16 is informative, but it's all confidential. We have no

17 idea where those lagoons are, what population they

18 serve, what the flow is. We know absolutely nothing

19 except that the water effluent concentrations and the

20 sediment count, so there's no way that we can fully

21 understand what that data means relative to the factors

22 we've used to select the monitoring plants.

23 So the information, don't get me wrong, it

24 certainly can be informative, but it's not...we just

25 don't know what the circumstances we're monitoring to
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 29

1 totally and completely rely on them.

2 MR. THOMAS: And I just wanted to make one

3 other ancillary point, this is Karlus Thomas again.

4 On the second page where there's the

5 discussion about how the data will be used, there's

6 some discussion about risk management that was very

7 difficult for me to sort of reconcile in my mind. I

8 sort of had this impression that you develop data that

9 you think you're going to use to do a risk assessment.

10 That data, depending on whether and to what extent the

11 risk is identified is used to determine what, if any,

12 risk management measures would be necessary to address

13 those risks.

14 So I guess in my mind, I was struggling with

15 how you could develop a monitoring program that would

16 provide useful data for risk management when no need

17 for risk management had yet been established.

18 MR. PENBERTHY: I think what we're trying to

19 say here is that in the end, we want to be able to

20 develop a risk assessment that actually can be useful

21 that there is a risk management action is necessary. So

22 we don't want to do two risk assessments. We want to

23 do one. We don't want to do a less than robust risk

24 assessment that would lead us into a long, drawn-out

25 process. We want to develop a risk assessment that we
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 30

1 can have confidence in and, if necessary, be used for

2 other purposes within the EPA.

3 MR. LEWIS: This is Paul Lewis, EPA.

4 As we're focusing on POTWs, we need to

5 mention in the past hour in terms of comments we've

6 received from other interested parties and I'm

7 wondering if either NACWA or American Cleaning

8 Institute would have any comments focusing on the issue

9 that we've discussed regarding POTWs, especially in

10 terms of NACWA, your comments were addressed several

11 times in the past hour.

12 MS. FINLEY: This is Cynthia Finley, NACWA.

13 I just wanted to say that the speakers in the

14 conference room aren't coming in very well over the

15 phone.

16 MR. LEWIS: Cynthia, this is Paul Lewis.

17 I was saying that we're focusing on POTW

18 discussion and your comments were referenced several

19 times. We would appreciate any remarks that you may

20 have in terms of discussion concerning lagoons and

21 other issues that were addressed.

22 MS. FINLEY: Okay. Well, I think we

23 discussed it in our written comments, I'm not sure how

24 much I have to add to that, but I do feel that majority

25 within the United States for the vast majority of the
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 31

1 population and the flow, although there aren't a lot of

2 lagoons in the United States. They are relegated to

3 very small populations that were mentioned that

4 earlier, so I don't think that including 25 percent of

5 the standard type lagoons is appropriate. I think we

6 would be better focus on the activated sludge treatment

7 plants.

8 As far as the factors in the matrix that the

9 EPA has proposed, I still don't understand why

10 population curve is a factor that's being considered

11 and we stress as well. There is nothing that I know of

12 to suggest that an area of higher population would have

13 any different use of products that have B4 and B5, so I

14 understand that you're trying to get some kind of

15 variation snap in, but more people is not going to

16 necessarily get that result.

17 I think that we have used to a generally

18 fairly consistent across the United States, an area

19 that has a better conservation efforts is going to have

20 less per person than other areas that don't have

21 conservation, but I still don't think that population

22 curve is a factor that should be considered. It should

23 be impact type.

24 MR. GRIFFITH: Yeah, Cynthia, this is Patrick

25 Griffith.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 32

1 I believe you also mentioned in the letter

2 that any EPA may want to look at combining systems

3 versus those that are not combined. Combined, meaning

4 the collection system of the plant with both storm

5 water as well as waste water.

6 MS. FINLEY: Right, yeah you're talking about

7 water factor that evolution at bridge water from there,

8 so I'm trying to properly define what the next course

9 is not always going to work out well at the EPA.

10 Hopeful of finding high level. I think that is

11 realistic and that could be done, but balancing

12 population, I don't that's going to hit the goal that

13 EPA wants to have.

14 MR. PENBERTHY: Is there any source

15 information? Is that just an assertion or is that ...

16 MR. DELEO: This is Paul DeLeo with the

17 American Cleaning Institute.

18 We've provided comments pertaining to that.

19 NACWA submitted because I didn't interact with Cindy at

20 all on this, but in our experience, I cited a study in

21 our favor was that and found that those designs were

22 very linear, so if you go and I think that's a little

23 bit under direct studies that the standards per capita

24 use rate of water of the environment.

25 MR. PENBERTHY: Well, I mean all I can do is
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 33

1 point out the technical document prepared by Dr. Kim

2 and it says when D4 enters waste water from households,

3 it's proportional to population. So how is, I mean, it

4 seems to me that your experts have population support.

5 MR. DELEO: Well, it would be influent flow,

6 so then it's diluted at a scaled rate and the

7 concentration would be updated, identical in different

8 areas of population.

9 MR. PENBERTHY: Well, I think that Dr. Kim

10 also recognized that...the inferences that we drew from

11 his paper is that the combination of population and

12 POTW flow was an important variable, that's why it's on

13 the matrix.

14 MS. PLOTZKE: I think that this probably gets

15 more to the overall design and maybe the fundamental

16 difference between our proposal and yours as far as

17 looking at from the worst-case scenario versus looking

18 at the distribution, so maybe this is the right time to

19 kind of talking about the differences and why we have

20 proposed the worst-case scenario versus the

21 distribution.

22 And for us, again, it comes back to this, all

23 this data set that's with us and has been with us over

24 the last few years that we've been collecting it, so

25 everything that we've put together has incorporated
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 34

1 that kind of information.

2 So if you were starting out with a chemical

3 that you knew very little about and not understanding

4 its chemical and physical properties and what would

5 play a role in its distribution in the environment,

6 doing something like a matrix design, design of

7 experiment, to basically build that matrix and

8 understand what that range would be would be very

9 appropriate and but if you have knowledge and you begin

10 to factor that into the factors, that matrix just

11 becomes smaller and smaller as you begin to really

12 refine those factors and with the data that we provided

13 last time as well and we now have even more data about

14 monitoring of the sediment compartment which is the

15 main compartment where you're going to find these

16 materials.

17 We've already conducted probabilistic risk

18 assessment on D4 and D5 in the sediment to show that

19 there is no risk associated with even the top end of

20 the spectrum of the distribution of these materials.

21 If you then design a program that allows you

22 to get a range which means you're going to get low end

23 and you're going to get high end, what you're going to

24 end up doing is populating even more of that

25 distribution that you have on the low end which just
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 35

1 shifts it to even less of a concern.

2 What we proposed was okay, you still have

3 some concerns, but let's go after and identify and

4 believe that we can do that with confidence with this

5 knowledge. The worst-case scenarios populate the high

6 end. Put more data there for the United States at the

7 high end which would build confidence that that high

8 end is no different than what we've seen anywhere else

9 in the world and even at the high end, there is no risk

10 associated with the presence of these materials in the

11 environment.

12 So that's really the fundamental basis of our

13 approach and we feel by doing that worst-case scenario

14 from a numbers, we have differences in numbers, that

15 having five sites is appropriate to do that.

16 It's not all by itself. It's going to be

17 added to and built on the whole base of information

18 that we already have and we're continuing to generate,

19 so the last time we provided the probabilistic risk

20 assessment for Dr. Woodburn, we now have it updated

21 with more samples from different sites that we have

22 been monitoring over the last two years. So it's an

23 ongoing process and those include sites from the United

24 States and will have even more sites over the next five

25 years.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 36

1 MR. PENBERTHY: Yeah, I think it's just a

2 fundamental difference in how we look at this. We look

3 at D4 as a persistent periodic toxic chemical made in

4 the hundreds of millions of pounds a year and siloxanes

5 are certainly, in terms of their physical and chemical

6 properties and potentially their fate and transport

7 through the environment, are unusual chemicals. That's

8 what makes them so special and so that's why we want to

9 be a lot more careful about this kind of monitoring

10 program than you all are. That's all I can say.

11 MS. PLOTZKE: I certainly can comment on

12 that, too, and we understand that the chemical and

13 physical properties of these materials, from how

14 they're used in models and the models don't do well

15 with predicting them because they weren't used in

16 building the models.

17 We face these challenges all over the world.

18 We've worked with the other government agencies and

19 Canada is a really good example where we understood

20 their concerns based exactly on what you said, the

21 chemical and physical properties were predicted to do,

22 and we went out and we generated this real world data.

23 We provided it to a board of experts in addition to the

24 board of review experts, we have an entire panel of

25 environmental experts that we handed over our data to
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 37

1 prior to that board of review and said you review it

2 all and you tell us.

3 Every one of them came back and said there's

4 nothing here and that's what the board of review

5 concluded looking at this data set, that for D5 it's

6 not going to cause harm now or in the future and the

7 Environmental Minister of Canada agreed with that.

8 So we understand. We've been there with

9 other regulatory authorities as well and we're willing

10 to provide the data. We have that data already and all

11 we're saying is just build on it to get to add to the

12 comments.

13 MR. DOYLE: Ward, this is Trent Doyle.

14 I just want to clarify your comment about why

15 the agency would want to be very careful with the

16 materials because you are seeing a need.

17 My way of thinking, at least traditionally, I

18 thought that a worst-case approach would be a

19 conservative approach. Is there something else I'm not

20 understanding? I mean, I understand about, I guess

21 you're sort of making an efficiency argument here in

22 the proposal, but as far as getting back to the purely

23 the science and the concern that the agency apparently

24 has with these substances is as a worst-case approach

25 ... I mean, what am I missing in terms of is there
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 38

1 something about this that's it's not so conservative?

2 MR. PENBERTHY: Well, we've talked about not

3 wanting to get into an integrated process and then how

4 are you going to define a worst-case approach, when you

5 think that some of these factors are irrelevant?

6 MS. PLOTZKE: I don't think they're all

7 irrelevant. I think they are. Actually, if you look

8 at a matrix and you think about the matrix and you look

9 at what you have designed in your proposal, that upper

10 quadrant really is worst-case, so those factors do

11 play, most of them or some of them, play a role to

12 define worst-case.

13 MR. PENBERTHY: I think we've said many times

14 over that we're not interested in doing a worst-case

15 assessment.

16 MR. DYER: Can I make a comment? Again, this

17 is Scott Dyer.

18 I think the philosophy comes down to whether

19 or not that you're dealing with a deterministic or a

20 probabilistic assessment of risk.

21 So if you use the matrix you have here, it

22 appears with actually a very small set of samples that

23 you're trying to understand the distribution of

24 potential siloxanes concentrations throughout the

25 country of which you already know, based on the matrix,
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 39

1 the vast majority of them are going to be lower than

2 your upper left-hand corner there.

3 So the other opposite side is a deterministic

4 way of looking at the distribution. We already know we

5 can use the Clean Water Needs Survey to use their

6 instantaneous dilution factors. You can use the Ice

7 Stream and actually load it with zero removal and then

8 you basically include upstream contributions and you're

9 still going to basically populate that upper-left and

10 what you'll find is that we're not just talking about

11 just a handful of waste water treatment plants that

12 correspond to this worst-case. You're talking about a

13 relatively large population of waste water treatment

14 plants at a 7Q-10 dilution.

15 So the question that I have for you all when

16 you were assessing and creating the matrix, and I know

17 it was in response to, really, our or the siloxanes

18 industry's initial proposal, is that matrix been based

19 upon a probabilistic understanding and approach or is

20 it based upon a deterministic? Because they don't have

21 to be mutually exclusive and I guess what the point is,

22 and why I guess I want to find out what the answer is,

23 is that the ... based on the deterministic, it's

24 basically a probabilistic distribution, but you're

25 sampling upon, you know, a fixed distribution of which
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 40

1 the agency has already described.

2 So if you could answer that, I think that

3 will provide some wonderful clarity about how this

4 matrix came about and then also, I think, to make sure

5 that when we talk about worst-case, it's not like

6 handpicking them out of the air. This is based upon

7 thousands of waste water treatment plants that have

8 been ranked against each other.

9 MR. PENBERTHY: Clearly, our monitoring plan

10 is oriented around those two factors that I think are

11 very important to understand for POTWs.

12 Another way I think of it sometimes is okay,

13 we have the 16 samples in our matrix. We've got five

14 manufacturing sites, I'm sorry, four direct, five

15 indirect, all probably use similar waste water

16 treatment, those POTWs. So you add those together, you

17 get 16 plus nine. That's 25 sites. Then you start

18 adding the Canadian data which is informative, but not

19 dispositive in our point of view, then you have a

20 pretty good data set to make a judgment.

21 So there is sort of a probabilistic element

22 to this, but, you know, our focus, at least on POTWs

23 has certainly been on what are the key factors. I

24 mean, I think we've thought about this.

25 MR. DYER: The question that I guess what I'm
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 41

1 asking though, are you interested in the variance on

2 the entire distribution or are you interested in the

3 variance upon the tail of the distribution? That's the

4 big key between the designs.

5 Probabilistic is looking at the entire

6 distribution and I think our group here is saying focus

7 in on the variability associated with the tail-end and

8 that's what we call worst.

9 MS. FEHRENBACHER: And I think we've made it

10 very clear that we're not interested in only worst11 case. I think we would like to better understand the

12 range of POTWs and when we get the data and develop our

13 assessment, we will develop the best assessment that we

14 can to inform the risk assessment that we'll be

15 conducting.

16 MR. LEWIS: This is Paul Lewis from the EPA

17 and Cynthia, if you're still on the line, in your notes

18 on daily sampling details, you comment about at the

19 sampling at the five POTWs did not provide sufficient

20 data to evaluate unusual or outlying results.

21 Can you provide greater clarity on that

22 comment you provided?

23 MS. FINLEY: Sure. I think with that you

24 will find results that are different. You're probably

25 going to find one or two that are different for
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 42

1 whatever reason from the other. They represent more of

2 an average. So I, with the main or the first proposal

3 which SEHSC organized using only two activated sludge

4 treatment plants. If you're only using those two,

5 you're only actually, each one, you really don't have a

6 good idea at all what is really happening at all, so I

7 think five is not a large enough number to really be

8 able to take a look at the data and say what is

9 useable.

10 Does that help?

11 MR. LEWIS: Yes, thank you.

12 MR. THOMAS: This is Karluss Thomas again.

13 I just wanted to go back to one of the

14 earlier points you made about not wanting to do the

15 worst-case assessment and, you know, back to the

16 factors.

17 I don't think that the intent was to suggest

18 that any of the factors that you guys chose were

19 irrelevant. I think that the point was more from our

20 standpoint and I think from what we've heard from some

21 of the other stakeholders, some of these factors have

22 greater or lesser importance with respect to the

23 likelihood that you're going to find the materials in

24 the environment at the technical concentrations. So

25 we've intentionally biased our selection of factors to
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 43

1 gear it towards identifying the materials in the

2 environment, so I just wanted to make that point. It

3 wasn't to suggest that any of the factors were, you

4 know, irrelevant, but are biased towards those that are

5 going to give you a greater opportunity to find

6 materials in the environment.

7 And I guess, just with respect to the whole

8 idea of worst-case assessment versus a distribution, I

9 think in a lot of ways we're sort of saying the same

10 thing because we're not...the fact that you are getting

11 information from multiple sites is going to give you a

12 distribution.

13 So I guess what we're really talking about is

14 the range of that distributions, so it's hard to get a

15 sense of that to actually do the monitoring, so I

16 guess, again, I would go back to the original proposal

17 that we made. I mean, I think that that is going to

18 give you a distribution of concentrations that's going

19 to provide sufficient information to do a risk

20 assessment. We characterized it as worst-case. You're

21 characterizing it as the distribution, but in a lot of

22 ways I think we're saying essentially the same thing.

23 MR. PENBERTHY: You know, I'm not sure we are

24 because if I say it, you aren't going to do it and I

25 think there was two or three activated sludge in the
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 44

1 proposal, so again, that's not, that doesn't get you a

2 distribution. It just gets you three points, so

3 that's, I mean, so am I to understand that that's your

4 five sites and that's it?

5 MR. THOMAS: Well, again, where I was going

6 with this conversation is I was trying to make sure

7 that we had a common understanding of the approach that

8 was going to be used from the standpoint of collecting

9 information and then doing the assessment.

10 MR. PENBERTHY: Well, it's clear you don't.

11 You're all interested in a worst-case scenario. We're

12 interested in understanding the range of values. I

13 don't know what to say.

14 MR. THOMAS: Can we take about a ten minute

15 break and then we'll come back?

16 MR. PENBERTHY: Sure.

17 (WHEREUPON, a brief recess was taken.)

18 MR. LEWIS: This is Paul Lewis again. We're

19 reconvening our siloxanes ECA meeting and SEHSC and

20 member companies who want to take a brief break now

21 that we're all going to be, obviously we want to kick22 off in terms of what you want to share with us in terms

23 of your corporation.

24 MR. THOMAS: Sure, absolutely.

25 I understand that there was a problem hearing
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 45

1 in the back of the room. Is this a little bit better?

2 AUDIENCE MEMBER: That's a little better,

3 thank you.

4 MR. THOMAS: All right. We certainly have

5 taken into consideration all of the comments that we've

6 heard today and I guess from the standpoint of

7 efficiency and allowing the generation of a data set

8 that's more consistent with the agency's needs, our

9 suggestion is that we change the mix of the five sites

10 that we have suggested on the POTW side.

11 We certainly heard that there was some

12 discomfort associated with having two activated sludge

13 sites, so our suggestion would be that number be

14 increased to four and there be one lagoon and we would

15 still maintain the total number of POTWs, but make the

16 mix of those more consistent with what the agency has

17 expressed today.

18 MR. PENBERTHY: Okay, I appreciate the

19 rethinking there. Is that the considered opinion of

20 all of your member companies?

21 MR. THOMAS: Yes.

22 MR. PENBERTHY: Okay. So that includes

23 Bluestar, Dow Corning, Evonik, Momentive ...

24 MR. THOMAS: Yes.

25 MR. PENBERTHY: ... and Wacker? Shin Etsu?
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 46

1 MR. THOMAS: Yes.

2 MR. PENBERTHY: Okay.

3 MR. THOMAS: And in addition to that, we

4 would obviously continue to provide the data associated

5 with ongoing programs that the industry has underway.

6 I mean, that's something we do regularly and that's

7 something that we would continue to do.

8 As you know, we have a number of ongoing

9 programs, many of which generate this type of data that

10 would be of interest to the agency and we'll continue

11 to provide that as it becomes available as well.

12 MR. PENBERTHY: Okay. You know, I think at

13 this point, I appreciate your reconsideration of my

14 end. What we would need to do is go back and share

15 that with our managers. I mean, I think we should

16 still fully understand that we don't think five, even

17 at that mix, is going to be adequate, but at least

18 that's the impression I had in dealing with my

19 colleagues that I get, but of course we'll share that

20 offer with our managers and see how they determine

21 whether it's worthwhile going forward based on that

22 offer, but I do appreciate the changes that you've

23 offered.

24 I mean, I think ...

25 AUDIENCE MEMBER: Ward, we can't hear
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 47

1 anything that you're saying.

2 MR. PENBERTHY: Okay. I'm sorry.

3 Basically what I said is we will share their

4 revision to their proposal with our managers and

5 determine with our managers whether they want us to

6 pursue moving forward on that kind of offer and I was

7 also trying to explain that, you know, through all our

8 discussions internally at the EPA, the number five

9 wasn't the right number, so we'll see what happens.

10 Perhaps maybe we should move on to the other

11 topics.

12 MR. LEWIS: So we just finished the terms of

13 the discussion of the POTWs. Next is the industrial

14 sites with on-site waste water treatment, both direct

15 discharge sites and I think there's really not a lot of

16 deliberation here for that. I think all parties agree

17 with EPA, SEHSC member companies, we agree with the

18 four SEHSC member direct discharge sites to be

19 monitored as originally proposed, but I want to make

20 sure that if there are other interested parties either

21 here in the room or on the phone, if they have any

22 comments so that they might have an opportunity to be

23 part of this discussion.

24 So again, we're focusing on the direct

25 discharge sites.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 48

1 I'm hearing none.

2 MS. PLOTZKE: Paul, this is Kathy.

3 I just want to make sure, maybe we'll get to

4 this later in the details part of it, but I just wanted

5 to make sure that we understood and we clarified on

6 what would be included in the direct sites or are you

7 going to cover that later?

8 MR. LEWIS: I think that's in the sampling

9 details.

10 MS. PLOTZKE: So when we get to there is

11 where we'll clarify it?

12 MR. LEWIS: On this is there a special

13 circumstance?

14 MS. PLOTZKE: There was a little bit of

15 difference in the sampling details that you had.

16 MR. LEWIS: Well, why don't you bring that

17 up.

18 MS. PLOTZKE: Okay. So for example, what we

19 had proposed on the direct sites was to sample

20 effluent, surface water, sediment, and that basically

21 you have influent and effluent down below.

22 MS. FEHRENBACHER: So I guess the question is

23 well, we believe that it's important to have

24 information on influent concentrations where if we had

25 factors such as the influent and then the effluent as
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 49

1 well to try to get a sense of the, you know, the

2 overall mass balance and those sorts of things, a

3 better understanding of the environmental contribution

4 from these sites.

5 MR. DOYLE: This is Trent Doyle.

6 One of the concerns that we had about the

7 influent, in particular, and why we didn't include it

8 in our proposal is that we, likewise, were focused on

9 environmental contribution, environmental loading which

10 frankly we didn't we didn't see it there on that, if

11 you will, a major impact on the environment, what

12 happens inside the plant is critical in our sense, but

13 moreover, the bigger issue is there's a concern about

14 those type of data and getting at things like

15 efficiency numbers of facilities which, of course, are

16 very critical to each one of these companies and how

17 they operate and there's much concern about those type

18 of data becoming publicly accessible, being generated

19 and shared among member companies. There's anti-trust

20 concerns there. Other competition and all types of

21 concerns and that's, you know, for us, we would be

22 concerned about those type of data generated in those

23 contexts, particularly if, in fact, the need is to

24 really understand environmental loading and see how

25 that really errs on that. I don't know if there's
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 50

1 anything else, I just wanted to share that.

2 MR. PENBERTHY: So am I to understand that

3 you regard the influent data as confidential

4 information?

5 MR. THOMAS: Just to follow-up on Trent's

6 point, not necessarily that the influent data in

7 particular, but I think these types of data in general

8 that have to do with treatment capability and

9 efficiency are not only the source of what members

10 consider an opportunity for marketplace advantages and

11 necessarily are considered proprietary and

12 confidential, but don't have any bearing on

13 environmental loading.

14 So I think not necessarily that the input

15 coming into the on-site treatment is necessarily

16 proprietary in and of itself, but what it allows you to

17 back-calculation, like treatment efficiencies,

18 treatment capabilities, those are things that are

19 considered marketplace advantages and members consider

20 those things proprietary.

21 And I think, more importantly, they don't

22 tell you anything about what's in the environment which

23 is what our understanding is what we're trying to get

24 at here.

25 MR. PENBERTHY: Yeah, I guess a couple
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 51

1 points.

2 It might be possible that those are

3 confidential business information that you can claim

4 that I'd have to get clarity on that. You know, of

5 course, if you did that, you would have to be able to

6 substantiate that that was the case.

7 I don't think that this kind of data,

8 influent data, would be regarded ... well, if it's part

9 of a spec, I don't think a monitoring study, well, I

10 have to fully understand whether this kind of study

11 would be a health and safety study under TOSCA and then

12 we would have limited protections under CBS. I'd have

13 to get back to you on that. So that's one issue.

14 I think I've had some preliminary

15 conversations with some of our CBI attorneys and they

16 seem to think that there's a fairly good case for it to

17 claimed under CBI, but I'll need to get further

18 information on that.

19 I mean, again, we are truly trying to

20 understand the efficiency of waste water treatment

21 facilities and treatment of siloxanes and so that's a

22 key interest for us and the reason we're interested in

23 it is because there's some of those direct dischargers

24 or formulators and processors and there's hundreds or

25 maybe thousands of those processors across the country,
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 52

1 so we really need to understand, you know, how

2 effective POTWs are in treating siloxanes, so that's

3 what our interest is.

4 So those are two things that are, you know,

5 in the focus of our mind when you talk about this.

6 MR. THOMAS: Well, and I guess I could

7 certainly understand how the agency would be interested

8 in those things, but I think from my memory, this is

9 the first time that I've understood that the agency

10 wanted to collect that type of information as part of

11 this program.

12 I mean, again, if I go back to the original

13 goals that were articulated for this program, you

14 wanted to understand the sources and pathways and the

15 environmental concentrations of D4 and D5 in the

16 environment. I don't remember any of the documents

17 suggesting that it was a part of this program to gather

18 information that related to the treatment efficiency.

19 I think the literature is actually pretty

20 replete with data associated with treatment

21 capabilities for waste water treatment plants for a

22 variety of environmental pollutants, including D4 and

23 D5. I think the Canadian information is a great source

24 of information with respect to treatment with respect

25 to D4 and POTWs for D4 and D5.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 53

1 My memory of that data was that it was in the

2 high 90 percent range, so again, I would certainly

3 understand the agency's interest in those data. I

4 guess my suggestion would be that if this program was

5 intended to capture data to perform a risk assessment,

6 I'm not sure those two things are similar or are

7 necessary from the standpoint of what we are trying to

8 do with this program.

9 MR. PENBERTHY: Okay, and I think I

10 understand your concern on the issue. Again, that's

11 something that we would have to consider and deliberate

12 about with our management.

13 MS. PLOTZKE: Just one last clarification.

14 What you have down here and below under the

15 sampling details for direct is just influent and

16 effluent, so if you're going to revisit the influent

17 and ... it's just effluent?

18 MR. PENBERTHY: I mean, I assume that this is

19 only for direct discharge sites, so it can't be ... I

20 can't understand how this logic would relate to

21 indirect discharge sites because that's clearly a

22 stream that someone who's not part of the company could

23 go pick-up, so I think if we ask for influent in the

24 indirect discharge sites, I don't understand how that

25 would be a problem except philosophically from a point
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 54

1 of view of what kind of assessment we're trying to do.

2 MS. PLOTZKE: And let me clarify, because

3 what I was asking is about having the direct discharge

4 site, so what that statement says is just influent and

5 effluent direct. Let's talk about direct.

6 So then if we revisit influent, then all that

7 leaves is effluent from the direct discharge sites, is

8 that correct?

9 MR. PENBERTHY: I'm not sure what you're

10 asking.

11 Basically, you're asking us not to have, not

12 to include the measurement of influent concentrations

13 in the program.

14 MS. PLOTZKE: Is that ...

15 MR. THOMAS: Not in the program, just with

16 the direct dischargers.

17 MR. PENBERTHY: Right, right. Exactly.

18 MR. DOYLE: I think that the question, Ward,

19 that Kathy is trying to ask is, that we want clarity on

20 the EPA's proposal with respect to direct discharge

21 sites. What parameters are you proposing to have

22 monitored at those sites?

23 Because there was some perceived ambiguity in

24 how it was phrased and I just want to make sure that we

25 understand.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 55

1 So the second bullet point under sampling

2 details, can you, just for everyone's edification, can

3 you articulate the input parameters or the endpoints

4 that will be monitored or are supposed to be monitored

5 at a direct discharge site?

6 MR. PENBERTHY: Well, the flow concentration

7 in the influent and the flow concentration of the

8 effluent is what we have here for all the sites. We

9 didn't...but now you're saying you don't want to

10 measure the influent...

11 MR. DOYLE: Well, yeah. That's a side thing.

12 We just want, I guess, clarity with respect

13 to things like biosolids, sediments and outfalls,

14 surface water.

15 MR. PENBERTHY: Oh no, no, no. Those are all

16 on there. Biosolids, sediment, outfall. They're not

17 in the influent.

18 MS. PLOTZKE: Not for the direct sites.

19 They're only for the POTWs?

20 MR. PENBERTHY: I think what we're looking at

21 for bullet two, what SEHSC proposes is basically to

22 drop influent and you're asking for clarity on

23 effluent.

24 Biosolids, sediment, outfall, and surface

25 water may still also be monitored for direct discharge
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 56

1 sites. Is that your position?

2 MR. DOYLE: That's the simple question,

3 really. We just want to know.

4 MR. PENBERTHY: That's correct. So which I

5 think is ... we're only dropping influent. This is

6 effluent. Now the other factors are still in play.

7 Does that help you?

8 MS. PLOTZKE: It's just the way it was

9 articulated. You had the first bullet that talked

10 about POTWs and in this one ...

11 MR. PENBERTHY: Okay. Yeah, I follow.

12 MR. DOYLE: It was far too painful.

13 MS. PLOTZKE: Sorry.

14 MR. PENBERTHY: Yeah, that was not

15 particularly clear. I appreciate that.

16 Should we move on?

17 MR. LEWIS: So the final site that we want to

18 talk about since all sides are here are the indirect

19 discharge sites.

20 Just to put things into context, the SEHSC

21 proposal did not include monitoring of these sites and

22 we understand that member sites process siloxanes to

23 formulate products containing siloxanes. Monitoring

24 data from these sites will be used to be informative to

25 help characterize potential release of siloxanes from
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 57

1 the country's processing, and formulating sites,

2 including sites of non-SEHSC members.

3 Again, this is a topic that we brought up as

4 part of our discussion among all of the parties here at

5 our last teleconference and there are a total of nine

6 SEHSC indirect discharge sites and the agency believes

7 that of these nine sites, only five sites should be

8 monitored and they should provide the agency the names

9 of three sites that demonstrate no release to water and

10 that one site discharges directly to a tertiary site,

11 so that kind of goes through the process in terms of

12 the work with the original nine. How we came up with

13 in terms of only five sites to be monitored.

14 So this is an area that requires a discussion

15 among SEHSC member companies as the parties in terms of

16 this is an important piece of information for the

17 agency to have an understanding in terms of siloxanes,

18 in terms of the processing and formulation of the

19 product, and in terms of its environmental load.

20 MR. THOMAS: I'll start. This is Karluss

21 Thomas again from SEHSC.

22 I guess from our perspectives, those indirect

23 sites do not have environmental releases. Those sites

24 discharge to POTWs.

25 POTWs are the source of another component of
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 58

1 this program, so it's not clear why additional

2 monitoring at exclusively the SEHSC indirect

3 dischargers would provide added value from the

4 standpoint of giving a sense to what the environmental

5 loads are.

6 We've already offered to provide all of the

7 information associated with the direct dischargers, so

8 the thought...I just want to have a clear understanding

9 of how these data are going to conform to the

10 environmental concentrations.

11 MR. PENBERTHY: Let me try to explain that.

12 In our proposal, you'll...with respect to

13 POTWs, you know, one of the selection criteria was that

14 they would have a limited amount of industrial

15 contribution to the flow. Okay, so we just look at the

16 POTWs as primarily a non...POTWs contributing primarily

17 non-industrial waste water and then we look at the

18 indirect discharges as POTWs that are treating

19 siloxanes in industrial waste water, so we see those as

20 two different sampling pools that need to be understood

21 and as Paul said, and I think you've said, there's

22 hundreds, maybe even thousands of formulators and

23 processors going to POTWs, so we need to know. Does

24 that circumstancethat circumstance differentiatable

25 from a low treatment percentage, industrial treatment
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 59

1 percentage of POTWs?

2 So that's why. That was our logic.

3 MR. THOMAS: Well, I guess one of the

4 questions would be it's probably tens of thousands and,

5 very likely tens of thousands of facilities as opposed

6 to thousands and I guess it's not clear why monitoring,

7 exclusively, the SEHSC indirect dischargers would

8 necessarily give you any better understanding of that

9 whole universe.

10 MR. PENBERTHY: Okay, I guess I'll try to

11 explain that to you.

12 First of all, the primary reason is we're

13 talking to you. We're negotiating with you, right? So

14 you have this monitoring to offer in our point of view

15 and I'll also read you section two of TOSCA where it

16 states, "It's the policy of the United States that

17 adequate data should be developed with respect to the

18 effective chemical substances and mixtures on the

19 health and the environment and that the development of

20 such data should be the responsibility of those who

21 manufacture", you guys, "and those who process."

22 So sorry. In view of the statute and that

23 was passed in 1976, so it's a long-time policy, you

24 guys are responsible for the testing. So that's where

25 we are.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 60

1 MR. DOYLE: Ward, I'm just confused by it a

2 little bit. Which pool of processors did the statute

3 specify are subject to TOSCA?

4 MR. PENBERTHY: It says manufacturers and

5 processors.

6 MR. DOYLE: Manufacturers and processors, but

7 which manufacturers? Is it just a general term,

8 manufacturers? Does that mean all processors or just

9 certain processors?

10 MR. PENBERTHY: It is the responsibility of

11 those manufacturers and those who process those

12 chemicals. What are you trying to say?

13 MR. DOYLE: Well, you said that you were

14 interested in talking to us and we were being held to

15 it because we're the ones in front of you.

16 MR. PENBERTHY: You're the manufacturers,

17 aren't you?

18 MR. DOYLE: Okay.

19 MR. PENBERTHY: There's four manufacturers, I

20 know that for a fact.

21 MR. DOYLE: And how many processors are

22 there?

23 MR. PENBERTHY: Thousands, but you guys are

24 processors, too.

25 MR. DOYLE: So the act empowers the agency to
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 61

1 focus on a select group of processors?

2 MR. PENBERTHY: No, we're talking ... okay,

3 let me explain here. Since 1976, I don't think there's

4 ever been a manufacturer engaged in a testing action

5 under section four of TOSCA that has deferred testing

6 and pushed that onto a processor, which are usually

7 their customers.

8 So, you know, unless you want to break sort

9 of a tradition of how TOSCA has been implemented,

10 that's why we're talking to you and that's why I think

11 that this is important for you to undertake.

12 MR. DOYLE: Well, I mean, by breaking

13 tradition, how many section four test rules for

14 environmental monitoring have there been since TOSCA

15 was enacted?

16 MR. PENBERTHY: There's a first time for

17 everything.

18 MR. DOYLE: Likewise.

19 MR. PENBERTHY: It doesn't, I mean, we

20 clearly have the authority to do that. That's the law.

21 MR. THOMAS: I'm not a lawyer even though I

22 did, at one time, stay at a Holiday Inn Express, but I

23 guess I'll say from the standpoint of that, Ward, with

24 respect to the manufacturers, again, we've offered to

25 do all of the direct discharges, which, you know, could
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 62

1 be presumed to be some environmental consequence. The

2 testing will determine that.

3 I guess, again, with respect to the indirect

4 dischargers, it's not clear to me that there's any

5 consequence of that because those releases are not to

6 the environment, they're to POTWs and we have a POTW

7 component of this testing which allows you to get that

8 data.

9 I guess with respect to the broader issues of

10 processor, you know, that's something that the agency

11 will have to consider, you know, on its own.

12 Certainly, we represent a very small subset

13 of the processors of these materials. There is a much

14 larger subset out there and I guess that's all I can

15 really say about what our members are able to provide

16 in terms of data with respect to doing an environmental

17 risk assessment.

18 MR. PENBERTHY: Okay. I'll offer one more

19 comment and that is the POTWs in Canada who receive

20 industrial waste water had significantly different

21 concentrations going to the POTWs, so there is a

22 rationale for the distinction between POTWs who don't

23 receive industrial waste water and the POTWs that do.

24 MR. THOMAS: Well, I guess, again, what we're

25 focusing on is what is going to the environment. It's
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 63

1 not clear to me that what's going to the POTW is

2 necessarily indicative of what gets into the

3 environment because what we care about is what's in the

4 environment and what harm that causes, not what goes to

5 the POTW.

6 The POTWs are there for a purpose and that's

7 to treat these materials and the treatment efficiencies

8 in Canada were extraordinarily high and I think if you

9 look at the environmental releases, even for those that

10 received effluent from industrial sources, I don't know

11 if I would say that the overall environmental

12 consequence of that was substantially different.

13 MS. FEHRENBACHER: I think that we do

14 understand where...your position. We don't have this

15 data in the United States. It would be part of the

16 risk assessment that we conduct as we've stated, the

17 POTW component and the proposal that we offered applies

18 to POTWs not receiving industrial waste and so for the

19 risk assessment in terms of the influent, this is an

20 important point.

21 MR. THOMAS: Would it be possible to even

22 have POTWs selected even within the construct of what

23 we've proposed? Have POTWs selected that have some

24 received effluent from industrial sources, some not?

25 Would that also allow you to capture that information?
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 64

1 MR. FEHRENBACHER: I think we can make the

2 point very clear that five POTWs, regardless of what

3 everything else says, industrial effluent is not

4 sufficient for the risk assessment that we intend to

5 conduct.

6 MR. THOMAS: Yeah, I guess just one other

7 note about the Canadian data, one of the things that I

8 was struck by and you're right, Ward, those POTWs, or

9 at least the one POTW that had some industrial effluent

10 had higher levels, but in terms of environmental

11 consequence, I didn't see a whole lot of difference

12 between that site and the others and I guess in terms

13 of the impact of the overall conclusion from the board

14 of review that looked at those data extensively, they

15 found that there was no risk. Not now or in the

16 future.

17 MR. PENBERTHY: Yeah, I don't think they

18 relied on one data point to make that judgment.

19 MR. THOMAS: I don't think they did, either.

20 MR. PENBERTHY: I guess, so you're not

21 interested in testing the indirect discharge sites? Is

22 that the case in this circumstance?

23 MR. THOMAS: Well, I guess, again, it's

24 difficult to understand how testing those indirect

25 sites gives you any information on the environmental
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 65

1 loadings which I thought is what we were after.

2 MR. PENBERTHY: It allows us to differentiate

3 or understand the difference between the POTWs that

4 receive industrial waste water and those that don't.

5 MR. THOMAS: I understand that.

6 MR. PENBERTHY: That's our interest.

7 MR. THOMAS: Okay.

8 MS. MIHIACH: Can I just ask a question? I'm

9 sorry, Ellen Mihaich.

10 I was wondering if Cynthia and others on the

11 phone had more knowledge. I don't. Are there many

12 POTWs actually in the country that don't actually

13 receive some type of industrial water, waste water?

14 There are?

15 I was just wondering because especially when

16 you start talking about the thousands of formulators

17 and processors that are out there, you would think that

18 finding that one or two, you would then have to start

19 the question are they relevant or...in our matrix, if

20 you do try. I don't know, I mean Scott, you've done

21 work in this area, too.

22 MS. FINLEY: Hi, this is Cynthia with NACWA.

23 I'm still on the line, again, it's just a little hard

24 to hear. Can you repeat the first part of your

25 question, please?
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 66

1 MR. MIHIACH: The question was if ... is that

2 one better?

3 The question is if there is that many POTWs

4 in the country, we're trying to say that there's some

5 that have or don't have any industrial influent at all,

6 either from a processor or a formulator or something

7 like that and we know that there are tens of thousands

8 of these in the country, would we actually even find a

9 domestic-only non-industrial waste input POTW that

10 would be relevant to study within the five or however

11 many of these that we settle on for the non-industrial

12 versus ones that have indirect discharge? I'm just

13 trying to get a sense of this.

14 MS. FINLEY: Maybe Patrick can comment if

15 he's still on the line, but I think you would have a

16 tough time finding a POTW that wouldn't have any type

17 of industrial discharge. You might be able to find

18 POTWs that...well, I honestly don't know. It depends on

19 the distribution of your manufacturers. You might be

20 able to find a POTW that has very low contributions or

21 possibly not and I just don't know. It's hard to say,

22 but...I'm not sure.

23 Patrick, do you have any comments on this?

24 MR. GRIFFITH: Well, to find one that doesn't

25 have a drop of industrial, I think it could be a
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 67

1 challenge, but to find a plant that would have less

2 than the ten percent, I think that would be very easy

3 to do. There are also plants that have much more than

4 ten percent. Our system has both.

5 And again, when you talk industrial, are you

6 talking refinery or dry cleaners or manufacturing or

7 are you talking about industrial in terms of

8 manufacturers or processors of siloxanes?

9 MR. MIHAICH: I think the question was do we

10 have to have another whole set of POTWs that have

11 indirect dischargers from processors and formulators, I

12 think, and so that was the question.

13 MS. FINLEY: Well, they're trying to separate

14 out the domestic discharges versus the indirect

15 dischargers of siloxanes. I think you're going to have

16 a tough time doing that.

17 I'm not sure if it's really relevant to do

18 that, either. It seems like I think perhaps it would

19 be best to take a look at everything as a whole rather

20 than try and separate those out.

21 MR. GRIFFITH: Yeah, this is Patrick Griffith

22 again.

23 I think that the way, one way that we would

24 determine if the ... actually kind of looking at what

25 happened with the biogas, we know that there were some
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 68

1 plants that have major, major problems with siloxanes

2 in the biogas and so I think that could be an indicator

3 that you have a manufacturer or a processor upstream.

4 MR. DYER: Yeah, this is Scott Dyer.

5 I just want to add on top of those, yeah,

6 there's a wonderful distribution of percent industry

7 that we can look at the Clean Water Needs Survey. It

8 already identifies that.

9 There's a huge fraction of the distribution

10 that actually has less than ten percent, but it was

11 already commented that there's an equally, a very large

12 percentage that has some 50 percent, 40 percent.

13 The devil in the details, though, is to try

14 and understand what are those sources of industrial

15 sources and so on. In other words, you know, really

16 naming them. That's not so easy.

17 A check to really understand the impact on

18 flow, though, is very easy. You just look at the per

19 capita use per day of that waste water treatment plant.

20 Dilution is the solution, so if you've got, if you've

21 got a high per capita water use, you've got a fairly

22 good, a good surrogate indicator that you've got a

23 manufacturing source of some type into the influent of

24 that particular POTW.

25 Whether or not they use these materials at
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 69

1 all is another question and so screening them out is

2 going to be difficult, but I think there's ways in

3 which we can do that.

4 MR. MAY: Russell May from Evonik and I want

5 to amplify what's just been said.

6 I did take the opportunity to take a look at

7 applications and uses of these materials throughout the

8 value chain and, as I stated in the meeting before,

9 there are numerous industries, you can actually go to

10 our website and see one, that are engaged in processing

11 and formulating our materials.

12 With that in mind, I took a look at where

13 these things might be and, frankly, then looked at the

14 manufacturing capability throughout the United States.

15 We're talking tens of thousands of facilities and, I

16 agree with you Scott, that it would be difficult to

17 find a waste water treatment plant that is receiving

18 industrial water that can argue that they did not

19 receive these materials in some fashion from a

20 manufacturer or a processor.

21 MS. FINLEY: This is Cynthia from NACWA.

22 I think that being the case, it would make

23 sense to go with something like the EPA proposal where

24 you just say we're going to let the POTWs that have

25 less than ten percent industrial contributions to
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 70

1 influent and then would that be a direct discharging

2 manufacturing site. I don't understand why any

3 indirect dischargers would be substantially different

4 than direct dischargers. I'm not sure what you gain by

5 adding those in.

6 MR. DYER: Bob DeLeo from ACI commented on

7 this earlier and I think that Cynthia did, too, but the

8 per capita water use kind of normalizes when you have

9 industrial sources, so obviously when you've got more

10 industrial sources, the per capita of that particular

11 siloxane is actually lower, so given exactly like what

12 Cynthia was describing, do we really need to have it,

13 you know, since the majority of waste water treatment

14 plants in the country are actually going to be

15 receiving some level of industrial input,

16 unquantifiable, but are going to be expressed as a per

17 capita water use metric.

18 So that may be one way in which we could

19 evaluate things, but I think it would be extremely

20 difficult, so concentrating, again, on your domestic

21 sources is probably going to be your best way of being

22 able to understand, truly, what your most

23 representative cases look like if that's clear.

24 MR. THOMAS: And this is Karluss Thomas

25 again.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 71

1 Just to make one other point related to that.

2 The D4 and D5 in POTWs it's not only from consumer

3 sources, consumer products, but it's also going to be

4 from polymer degradation, but I think that's just

5 another point to emphasize the difficulty associated

6 with differentiating among the different sources.

7 But just to go back to an earlier point I

8 made, I went back and went through some of the original

9 goals that EPA had articulated for the program and it

10 was to develop a better understanding of the sources of

11 and pathways to the environmental concentrations of D4

12 and D5 in environmental media and biota.

13 And I think part of the difficulty with the

14 whole process has been that there's this perception

15 that what EPA intends to capture from this program, it

16 seems to have evolved over time and I think what we're

17 hearing today, in particular, I guess, from my

18 standpoint, is this whole idea that we're also going to

19 use the program to capture information on POTW

20 treatment efficiency. I'm not sure we've heard that

21 before. And I think it's also interesting now that

22 we're going to collect information that allows us to

23 apportion the relative contributions in the environment

24 to consumer sources versus industrial sources and it's

25 not clear why you need that to do an ecological risk
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 72

1 assessment.

2 Again, if the focus is on what's ultimately

3 in the environment, it's not clear, it's not clear from

4 the standpoint of what difference does it make how it

5 got there and I think part of it might be is that

6 there's this, there seems to be this need to also drive

7 this to risk management and I think, again, if you take

8 a step back and focus it on the risk assessment and

9 going back to the sources and pathways to the

10 environmental concentrations, I think the proposal that

11 we provided sufficiently allows the agency to do that.

12 Now, if you indeed want to do all of these

13 other things, I probably would have to concede that our

14 proposal does not allow you to do that, but that's not

15 our understanding of what we were being asked to do.

16 MR. PENBERTHY: So I take it you're not

17 interested in sampling indirect discharge sites, is

18 that where you stand?

19 MR. THOMAS: Well, I think, again...

20 MR. PENBERTHY: We've made a proposal, so

21 it's pretty straightforward. We've tried to explain

22 it's we're trying to understand the industrial

23 contribution to these kinds of facilities to POTWs

24 versus domestic, so that's the rationale. I think

25 that's pretty clear.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 73

1 MR. THOMAS: Yeah, we're not prepared to do

2 monitoring at the indirect sites because we don't think

3 it further enhances the goal of the program as it was

4 originally articulated.

5 MR. PENBERTHY: Okay.

6 MR. LEWIS: So let's move along.

7 Any comments before I move on to the next

8 phase?

9 Okay. We want to talk about it anyway. We

10 touched upon this previously, the sample details for

11 all monitoring sites. Let's just kind of review where

12 we are.

13 Looking at two sampling events from each site

14 and media sample will include the POTW influent, this

15 is for POTWs, effluent, biosolids, sediment, outfall,

16 and surface water, and we spoke about before for the

17 direct discharge sites, SEHSC had a comment about the

18 rationale of why influent and there is a difference of

19 opinion in terms of the agency and SEHSC, so that's an

20 issue that requires a decision on.

21 For direct, indirect discharge sites, we

22 spoke about in terms of differences of opinion between

23 direct discharge sites a few moments ago, influent and

24 effluent from on-site pre-treatment, and treatment

25 systems, if applicable, would also be monitored.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 74

1 So again, we know the issues there. SEHSC

2 recommended having one site where air monitoring would

3 occur at a covered site and we support that proposal,

4 that part.

5 In terms of biota sampling, benthic and

6 multiple fish species of all SEHSC direct and indirect

7 discharge sites provided they are sufficient biotical

8 presence and monitors. So again, it's important to

9 understand in terms of what the population actually is

10 existing and in terms of whether there is sufficient

11 population to monitor.

12 EPA believes that monitoring of all these

13 sites will lead to developing data sets for assessment

14 at this time and let's have a discussion about sample

15 details and SEHSC have any comments about where we are

16 right now.

17 MS. PLOTZKE: Probably just another

18 clarification, so for me, putting it sort of like in a

19 bucket.

20 So POTWs, can we go through that and make

21 sure we're in agreement. The way this reads, I'm just

22 not clear.

23 So for POTWs, what we have proposed is

24 influent, effluent, biosolids, sediment, surface water,

25 and biota.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 75

1 So is EPA in agreement with that for POTWs?

2 Sorry if I'm not close enough. Is EPA in agreement

3 with what we have proposed for POTWs?

4 MR. PENBERTHY: Cathy? Ward?

5 MS. PLOTZKE: Well, it's just the way it's

6 laid out for me, because you talk about POTWs and then

7 we talk about direct and indirect, the pieces are just

8 in different places, that's all.

9 MR. PENBERTHY: There is a minor difference.

10 MS. PLOTZKE: Okay. What is it? If you

11 point that out, maybe that will help.

12 MR. PENBERTHY: Our biota was targeted at the

13 industrial sites.

14 MS. PLOTZKE: Only at the industrial sites?

15 MR. PENBERTHY: Right, but if the offer is

16 there, we wouldn't refuse it.

17 AUDIENCE MEMBER: I'm sorry, we didn't hear.

18 MR. PENBERTHY: Our biota monitoring is

19 targeted for the industrial facilities, but if there's

20 an offer to do it at the POTWs, too, we would certainly

21 not object to that.

22 MS. PLOTZKE: That was in our original

23 proposal.

24 MR. PENBERTHY: I know.

25 MS. PLOTZKE: Okay. Well, if you think
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 76

1 there's value in it, we're also open to hearing that.

2 MR. PENBERTHY: We were trying to be

3 efficient.

4 MS. PLOTZKE: Okay. And then maybe when we

5 talk about what biota because I also noticed that you

6 have, you say benthic and multiple fish species, so

7 maybe it's important to understand what your objective

8 is compared to what we were proposing. We were

9 proposed benthic and a fish species, so something that

10 would be more of a marker of exposure in those areas.

11 MR. PENBERTHY: I'll get out of my expertise

12 here, but I think the thought was that multiple fish

13 species so that you could go up the, I'm not sure of

14 the vocabulary, but the predatory chain and

15 accumulation and magnification.

16 MS. PLOTZKE: Does somebody else want to go

17 for that or should I just go on?

18 MS. EISENREICH: Karen Eisenreich, EPA.

19 Basically, the idea is to have a lower and

20 higher trophic level of fish, so two fish species to

21 represent the lower and the higher trophic level so

22 that we can understand where the source is. So are

23 they accumulating from another fish species or are they

24 accumulating from eating the benthic fish species?

25 That's the purpose of two species.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 77

1 MS. PLOTZKE: What I would clarify is what we

2 had in our proposal was to look more specifically at

3 markers and exposures in that area to not include a

4 food web assessment because that is included in our

5 other program and we've actually already completed

6 numerous food web studies, two of which that are close

7 to publication, but also a number of other ones that

8 are well underway and part of our voluntary produce

9 switch initiative as well.

10 So that was not included in this proposal.

11 MR. THOMAS: This is Karluss Thomas, just one

12 question.

13 Does the agency typically do food web

14 assessments as part of a typical risk assessment?

15 MS. FEHRENBACHER: I think we do that where

16 it's appropriate and, in this case, we're looking at

17 bioaccumulation and a better understanding that so

18 MR. THOMAS: Well, again, I'll just kind of

19 go back to the original reason that we all started

20 sitting around the table to do a risk assessment.

21 It was not my understanding that a food web

22 evaluation would be done as part of a routine

23 ecological risk assessment and again, I think it just

24 kind of goes to the point of evolution of the whole

25 goals for the program where we're now talking about
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 78

1 doing food web evaluations. We're talking about

2 assessing waste water treatment plant treatment

3 efficiencies. We're talking about apportionment of

4 relative contribution of industrial sources versus

5 consumer sources to environmental concentrations.

6 I mean the scope of what we discussed today

7 is far greater than what we had originally talked about

8 in the context of doing a risk assessment for D4 and

9 D5. I just wanted us to all sort of understand that.

10 MR. LEWIS: Do you also want to offer the

11 other parts for clarification?

12 MS. PLOTZKE: Yes. Okay.

13 MR. LEWIS: So you want to talk about the

14 direct discharge?

15 MS. PLOTZKE: Yes. So here's what we had

16 proposed about the direct discharge. We propose the

17 effluent, surface water, sediment, and biota again and

18 I think one marker fish at the direct discharge site.

19 So what we did not propose was influent or

20 biosolids, so that first bullet, you know, covers

21 everything in there, so I just want to make sure that

22 we all understand what's going with what site. So for

23 us, direct is just effluent, surface water, sediment,

24 and biota.

25 MR. LEWIS: Can you provide comment about the
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 79

1 rationale, we spoke before about influent.

2 This is Paul Lewis.

3 Can you comment about biosolid rationale?

4 MS. PLOTZKE: Yes and I think it's very

5 similar to the effluent from the standpoint that it

6 doesn't really help you to understand the environmental

7 loading because it's really the effluent that's driving

8 that.

9 MR. LEWIS: But you would still keep that for

10 the POTWs?

11 MS. PLOTZKE: We have put that in there.

12 MR. LEWIS: Okay.

13 We open the floor to the interested parties

14 that may be able to hear on the line.

15 Any comments about what you've heard so far

16 with respect to the sampling details with POTW and the

17 direct discharge?

18 MS. PLOTZKE: Yeah, and just to clarify,

19 Paul, because I'll remind you that even biota...so the

20 biota, again, there's a difference there for us.

21 MR. LEWIS: Correct

22 MS. PLOTZKE: The direct sites, it is only

23 one benthic species, one fish, not a food web study.

24 MR. LEWIS: So it's the same comment you had

25 before.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 80

1 MS. PLOTZKE: It the same, yes.

2 MR. LEWIS: Okay.

3 Again, I'm just asking in terms of any

4 interested parties have a comment either on the line or

5 here at the table?

6 Scott?

7 MR. DYER: Yeah. This is Scott Dyer again.

8 Just ask a point of clarification. We have

9 benthic species, but you talked about lower trophic

10 level fish and upper trophic level fish.

11 Are these lower trophic level fish benthic

12 species?

13 MS. EISENREICH: It's really difficult to say

14 when you don't...Karen Eisenreich again.

15 It's really difficult to say what your fish

16 species are when you have no idea what is at the site,

17 when you don't have any idea what the sites are and

18 what's there, so it's going to be nearly impossible to

19 pinpoint what species and what exactly they're feeding

20 on without knowing or having the site characterization

21 done prior to that assessment.

22 Same thing with the invertebrates; the reason

23 why it's benthic invertebrates is that you're likely to

24 reflect more than one invertebrate species in a sample

25 and there might be more than one there and there might
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 81

1 be only one. You just don't know until you do a site

2 characterization.

3 MR. DYER: And just another question and

4 clarification.

5 So we're really looking at the fate of the

6 material into the biology. We're not talking about the

7 biological integrity of the biological communities that

8 are being measured?

9 MS. EISENREICH: I'm not sure I understand.

10 When you're talking about biological integrity, are you

11 saying...

12 MR. DYER: Whether or not the communities are

13 actually impacted in terms of their population, their

14 community structure has been altered beyond that of a

15 reference condition?

16 MS. EISENREICH: No. That's not the point.

17 It's ... we're not looking at the integrity. We're

18 simply looking at what fish are there to collect. We

19 just, we don't know because we don't know the sites and

20 we don't have a site characterization.

21 MR. DYER: May I add a suggestion?

22 I think it would be a good idea to find out

23 whether or not the site that you know you select or a

24 series of sites, if this maintains, you know, stays in

25 the protocol, that we have an idea about whether or not
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 82

1 this is a healthy site, you know, according to the

2 state, regional EPA or not.

3 MS. EISENREICH: I think that when the sites

4 are chosen, that will become evident, but until, again,

5 until we know, we're talking about hypothetical sites

6 for the most part, so you don't know anything about the

7 site, but once you do know the exact sites that you're

8 sampling at, we'll know more about the site in general.

9 It's general health, what else is there, what else can

10 be impacting the ecosystem. So that will be a part of

11 it.

12 There may be some sites without a fish

13 species, who knows until you do a site

14 characterization. Or there may not be a higher trophic

15 level or a lower trophic level fish to collect.

16 MR. DYER: I started my job actually at a

17 facility in Cincinnati and we had a discharge that

18 discharged to a concrete raceway.

19 MS. EISENREICH: Right. Exactly.

20 MR. DYER: And it was several miles before it

21 got to a meandering creek.

22 MS. EISENREICH: Right, so there might not be

23 a species there to sample and that's...what species you

24 sample is dependent upon the site's characteristics and

25 that will be revisited if you do a site
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 83

1 characterization and there's nothing there to sample,

2 you can't sample it, so we'll revisit it at that point.

3 MR. DYER: Okay. Thanks.

4 MR. GRIFFITH: This is Patrick Griffith from

5 LA County Sanitation District.

6 I understand that one of the sites that you

7 are going to look at the air emissions from one of the

8 treatment plants and I noticed in one of the, I think I

9 mentioned this before, but in one of the conceptual

10 site models, air exposure is one of the, or it's an

11 important pathway to the risk assessment.

12 Now, I don't know if it's going to be

13 necessary for this process to develop a full mass

14 balance around the treatment plant and maybe you're

15 going to take that one air sample that you'll give off

16 from one treatment plant and try to apply it to the

17 others, but if it is necessary to do a mass balance, I

18 think you're going to have to do or you're going to

19 want to look at the siloxanes from the digester gas.

20 Otherwise you may be forced to assume that those, that

21 what would otherwise report to the digest gas is going

22 to be released or emitted somewhere else and those

23 releases would then factor into the risk assessment.

24 MR. LEWIS: Other comments on where we are

25 with the POTWs for the direct discharge sites?
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 84

1 Any other comments on the POTW or the direct

2 discharge site sampling details?

3 I see none.

4 The last is indirect discharge sites and,

5 obviously, our conversation will run. There is a

6 difference of opinion in terms of the use of that

7 information and I think what we see in terms of the

8 agency's position is on that and in terms of the media

9 being sampled.

10 So, what I want to know is to open the floor

11 for are there any general comments from SEHSC, member

12 companies, interested parties, in terms of what was

13 discussed today and any particular perspectives or

14 ideas?

15 MR. THOMAS: This is Karluss Thomas again,

16 SEHSC.

17 I guess I would just make a kind of a general

18 point. I think or I know the discussion have been, you

19 know, animated and in certain places difficult, but I

20 guess I can say certainly from the standpoint of SEHSC,

21 we're absolutely committed to this process. We are

22 certainly absolutely committed to the proposal that

23 we've put forth and believe that it represents an

24 excellent opportunity for the agency to collect data,

25 to perform the risk assessment, and I know you guys are
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 85

1 tired of me going back to the original language of what

2 was suggested we had all, you know, kind of embarked on

3 this program to accomplish, but that was essentially

4 what we used as the guide post for the development of

5 our proposal and part of the difficulty in expanding it

6 in terms of scope is it's very difficult to give

7 reasonable explanations of that to the senior

8 management of these companies and they're always going

9 to go back to why are you doing this.

10 You told me you were doing this for one

11 reason and now it seems that you want to collect

12 information to better understand waste water treatment

13 plant efficiencies, to apportion relative contribution

14 to different sources, to allow you to do food web

15 assessments, you know, to do a whole lot of other

16 things that weren't originally envisioned or certainly

17 weren't discussed when we set out on this path.

18 We absolutely believe it's appropriate for

19 the agency to conduct its own national risk assessment

20 for these materials. That makes sense. We support the

21 agencies need to do that.

22 We're committed to providing the data to the

23 agency to do that and we think that the proposal that's

24 been prepared provides the agency with the data that's

25 going to allow you to do that risk assessment.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 86

1 MR. LEWIS: EPA colleagues? Any comments in

2 terms of what was discussed today?

3 I just want to make a comment again. When we

4 met in June, as you know, it was part of the ECA

5 process. This process needs to be completed within six

6 months, so I want to remind everyone that we are half

7 way through the process and there's still work to be

8 done, so based on what we heard today, I will be

9 working with my colleagues and obviously any management

10 and briefing them on what they heard, what we heard,

11 and getting their direction and so on.

12 Ward, anything else to add?

13 MR. PENBERTHY: No.

14 MR. LEWIS: I think our next step is to...we

15 need to caucus in terms of our management. We want to

16 reconvene the next meeting of the ECA very soon and get

17 back to you in terms of the timeline.

18 As I mentioned, we'll get into the process

19 and the materials that were presented today are in the

20 docket. A transcript will also be available.

21 I want to thank SEHSC, member companies,

22 interested parties, and my EPA colleagues in terms of

23 the work to prepare for today's meeting and for

24 deliberations.

25 I want to thank everyone.
SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 87

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SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 91

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SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 92

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20:23 22:11

36:20 38:25

39:18 39:20

39:23 40:6 46:21

86:8

basically 8:17

9:12 9:13

13:13 15:10

23:14 28:7

34:7 39:8 39:9

39:24 47:3 48:20

54:11 55:21

76:19

basis 35:12

bat 24:17

bearing 50:12

become 20:13 82:4

becomes 34:11

46:11

becoming 49:18

begin 3:5 4:4

34:9 34:11

behalf 4:15 12:7

behind 11:15

16:16

believe 11:8

18:11 18:14

19:14 19:21
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 93

20:15 28:7

32:1 35:4

48:23 84:23

85:18

believes 57:6

74:12

Bell 5:24 5:24

benthic 74:5 76:6

76:9 76:24 79:23

80:9 80:11 80:23

best 18:3 18:20

25:13 41:13

67:19 70:21

Betsy 5:3

better 16:1

31:6 31:19 41:11

45:1 45:2 49:3

59:8 66:2

71:10 77:17

85:12

beyond 20:23

21:23 81:14

biased 42:25 43:4

bigger 49:13

biggest 21:5

bioaccumulation

77:17

biogas 67:25 68:2

biological

13:15 81:7

81:7 81:10

biology 81:6

biosolid 79:3

biosolids 55:13

55:16 55:24

73:15 74:24

78:20

biota 71:12

74:5 74:25 75:12

75:18 76:5 78:17

78:24 79:20

biota...so 79:19

biotical 74:7

bit 10:13 12:15

15:21 15:25

20:25 21:2 28:10

32:23 45:1 48:14

60:2

Bluestar 4:25 5:3

45:23

board 36:23 36:24

37:1 37:4 64:13

Bob 70:6

body 9:9 9:11

19:8 19:10 19:14

19:21 24:23

branch 5:13 24:11

break 20:11 44:15

44:20 61:8

breaking 61:12

bridge 32:7

brief 8:9 44:17

44:20

briefing 86:10

bring 48:16

brings 11:18

broader 62:9

brought 57:3

Browning 4:21

4:21

bucket 74:19

build 34:7 35:7

37:11

building 36:16

built 35:17

bullet 55:1 55:21

56:9 78:20

business 51:3

but...I'm 66:22

C

called-in 6:7

calling-in 14:16

Canada 15:22 28:8

36:19 37:7 62:19

63:8

Canadian 26:19

26:24 28:15

40:18 52:23 64:7

capabilities

50:18 52:21

capability 50:8

69:14

capita 15:16

32:23 68:19

68:21 70:8 70:10

70:17

capture 53:5

63:25 71:15

71:19

care 4:17 63:3

careful 24:20

36:9 37:15

Carlson 5:3 5:3

case 18:16
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 94

18:20 41:11 51:6

51:16 64:22

69:22 77:16

cases 70:23

catch 6:13

category 23:23

Cathy 4:9 10:17

17:16 24:11

25:17 25:25 75:4

caucus 86:15

cause 37:6

causes 63:4

CBI 51:15 51:17

CBS 51:12

certain 19:1 60:9

84:19

certainly 17:9

26:23 27:5

27:8 28:24

36:5 36:11 40:23

45:4 45:11

52:7 53:2

62:12 75:20

84:20 84:22

85:16

cetera 19:24

chain 69:8 76:14

challenge 67:1

challenges 36:17

change 3:18 45:9

changes 46:22

characteristics

23:25 82:24

characterization

80:20 81:2 81:20

82:14 83:1

characterize

56:25

characterized

43:20

characterizing

43:21

Charles 4:12

check 68:17

chemical 4:23

12:3 34:2 34:4

36:3 36:5

36:12 36:21

59:18

chemicals 36:7

60:12

choosing 18:11

chose 17:21 42:18

chosen 82:4

Cincinnati 82:17

Cindy 32:19

circumstance 14:9

48:13 58:24

64:22

circumstances

28:25

circumstancethat

58:24

cited 32:20

claim 51:3

claimed 51:17

clarification

10:4 53:13 74:18

78:11 80:8 81:4

clarified 48:5

clarify 26:16

37:14 48:11 54:2

77:1 79:18

clarity 40:3

41:21 51:4 54:19

55:12 55:22

class 25:15

Clean 14:21

39:5 68:7

cleaners 67:6

Cleaning 6:10 8:2

13:18 30:7 32:17

clear 10:14 10:24

16:25 24:24

41:10 44:10

56:15 58:1

58:8 59:6 62:4

63:1 64:2

70:23 71:25 72:3

72:3 72:25 74:22

clearly 14:7 40:9

53:21 61:20

clerical 23:16

close 75:2 77:6

codes 23:12 23:14

colleagues 8:14

46:19 86:1

86:9 86:22

collect 27:9

52:10 71:22

81:18 82:15

84:24 85:11

collecting

33:24 44:8

collection 32:4
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 95

combination 11:13

11:16 33:11

combined 32:3

32:3

combining 32:2

comes 11:22 33:22

38:18

comfortable 8:8

coming 7:21 10:18

15:6 17:18 24:10

30:14 50:15

comment 7:17

14:14 14:19 15:6

28:6 28:6

36:11 37:14

38:16 41:18

41:22 62:19

66:14 73:17

78:25 79:3 79:24

80:4 86:3

commented 68:11

70:6

comments 8:1

8:6 11:19

12:11 14:13 17:6

18:2 18:3

20:24 22:1

22:7 30:5 30:8

30:10 30:18

30:23 32:18

37:12 45:5 47:22

66:23 73:7 74:15

79:15 83:24 84:1

84:11 86:1

committed 84:21

84:22 85:22

common 14:5 18:25

22:14 44:7

commonly 19:6

communities

19:1 81:7 81:12

community 3:24

81:14

companies 44:20

45:20 47:17

49:16 49:19

57:15 84:12 85:8

86:21

company 53:22

compared 19:2

76:8

comparison 24:4

compartment 34:14

34:15

competition 49:20

complete 16:22

27:16

completed 16:4

77:5 86:5

completely 29:1

compliance

23:14 23:19

23:20 25:1 25:4

component 57:25

62:7 63:17

components 8:18

concede 72:13

concentrating

70:20

concentration

18:16 18:20 33:7

55:6 55:7

concentrations

10:22 11:12

15:14 15:16

19:10 25:21

28:19 38:24

42:24 43:18

48:24 52:15

54:12 58:10

62:21 71:11

72:10 78:5

conceptual 83:9

concern 8:24 35:1

37:23 49:13

49:17 53:10

concerned 22:19

49:22

concerning 30:20

concerns 12:24

13:10 35:3 36:20

49:6 49:20 49:21

concluded 37:5

87:1

conclusion 64:13

concrete 82:18

condition 19:25

81:15

conduct 63:16

64:5 85:19

conducted 34:17

conducting 41:15

conference 12:6

16:17 16:18

30:14

confidence 12:5

30:1 35:4 35:7

confidential
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 96

28:16 50:3 50:12

51:3

conform 58:9

confused 60:1

conjunction 13:18

consensus 3:13

4:3

consequence

62:1 62:5

63:12 64:11

conservation

31:19 31:21

conservative

37:19 38:1

consider 20:6

50:10 50:19

53:11 62:11

consideration

45:5

considerations

9:17

considered

10:19 11:7

14:4 31:10 31:22

45:19 50:11

50:19

considering 11:5

consistent

15:21 17:9 23:21

31:18 45:8 45:16

consistently

20:15

construct 63:22

Consultant 5:20

consultations 9:6

consumer 71:2

71:3 71:24 78:5

contact 8:13

containing 56:23

content 9:10

19:14 19:21

19:24

context 27:5

56:20 78:8

contexts 49:23

continually 23:3

continue 10:3

46:4 46:7 46:10

continuing 35:18

contributing

11:11 58:16

contribution 49:3

49:9 58:15 72:23

78:4 85:13

contributions

39:8 66:20 69:25

71:23

Control 3:8

conventional

13:11 22:15

conversation 44:6

84:5

conversations

51:15

converted 14:25

corner 39:2

corners 23:4

Corning 4:14 6:16

6:18 6:19 6:20

15:5 45:23

corporation

4:24 6:24 44:23

correct 54:8 56:4

79:21

correspond

13:24 39:12

Council 4:18

counsel 4:11 5:24

6:1 8:16

count 11:1 28:20

country 18:25

20:1 20:5

38:25 51:25

65:12 66:4

66:8 70:14

country's 57:1

County 6:21 14:12

83:5

couple 14:13

16:18 50:25

course 32:8 46:19

49:15 51:5

cover 48:7

covered 74:3

covers 78:20

create 25:7

creating 39:16

creek 82:21

criteria 17:14

23:1 58:13

criterion 22:15

critical 11:21

12:5 12:10 18:11
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 97

27:17 49:12

49:16

curious 14:2

curve 31:10 31:22

customers 61:7

Cynthia 22:6 28:5

30:12 30:16

31:24 41:17

65:10 65:22

69:21 70:7 70:12

D

D4 33:2 34:18

36:3 52:15 52:22

52:25 52:25 71:2

71:11 78:8

D5 34:18 37:5

52:15 52:23

52:25 71:2 71:12

78:9

daily 41:18

Danesi 5:11 5:11

data 12:2 24:16

26:24 27:9

28:9 28:15 28:21

29:5 29:8

29:10 29:16

33:23 34:12

34:13 35:6 36:22

36:25 37:5 37:10

37:10 40:18

40:20 41:12

41:20 42:8

45:7 46:4 46:9

49:14 49:18

49:22 50:3

50:6 50:7 51:7

51:8 52:20

53:1 53:3 53:5

56:24 58:9 59:17

59:20 62:8 62:16

63:15 64:7 64:14

64:18 74:13

84:24 85:22

85:24

database 14:21

23:18 26:19

David 5:18 6:20

day 68:19

dealing 38:19

46:18

decent 24:1

decision 73:20

deferred 61:5

define 32:8

38:4 38:12

definitely

12:21 12:22 15:2

16:3 18:4 18:5

18:5

degradation 71:4

degrees 13:3

DeLeo 6:9 6:9

32:16 32:16 33:5

70:6

deliberate 53:11

deliberation

47:16

deliberations

86:24

demonstrate 57:9

demonstrates 16:5

demurphy 6:25

DeMurphy 6:25

dependent 82:24

depending 11:1

29:10

depends 66:18

described 10:18

22:8 40:1

describing

17:20 70:12

design 11:22

11:24 14:5

21:8 33:15

34:6 34:6 34:21

designed 17:25

25:10 38:9

designs 32:21

41:4

detail 12:11

details 3:23 9:20

41:18 48:4

48:9 48:15 53:15

55:2 68:13 73:10

74:15 79:16 84:2

detection 15:18

15:20

determine 3:13

29:11 46:20 47:5

62:2 67:24

deterministic

38:19 39:3 39:20

39:23

develop 8:16 9:18

16:9 25:20 25:23

26:22 27:19 29:8

29:15 29:20

29:25 41:12
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 98

41:13 71:10

83:13

developed 8:10

16:17 27:12

59:17

developing 28:2

74:13

development 59:19

85:4

devil 68:13

dialed 3:4

didn't...but 55:9

difference 22:4

33:16 36:2 48:15

64:11 65:3

72:4 73:18

75:9 79:20 84:6

differences 33:19

35:14 73:22

different 10:9

12:18 15:10 20:1

20:5 21:15 25:19

31:13 33:7

35:8 35:21 41:24

41:25 58:20

62:20 63:12 70:3

71:6 75:8 85:14

differentiatable

58:24

differentiate

65:2

differentiating

71:6

difficult 13:23

19:17 29:7 64:24

69:2 69:16 70:20

80:13 80:15

84:19 85:6

difficulty

26:18 71:5 71:13

85:5

digest 83:21

digester 83:19

diluted 33:6

dilution 19:9

24:8 39:6

39:14 68:20

direct 3:15

3:21 8:19

32:23 40:14

47:14 47:18

47:24 48:6 48:19

51:23 53:15

53:19 54:3

54:5 54:5 54:7

54:16 54:20 55:5

55:18 55:25 58:7

61:25 70:1

70:4 73:17 73:21

73:23 74:6

75:7 78:14 78:16

78:18 78:23

79:17 79:22

83:25 84:1

direction 86:11

directly 18:2

57:10

disagreement

19:16 20:18

discharge 3:15

3:15 3:21 3:22

13:3 19:20 22:22

22:23 23:25 24:1

25:1 47:15 47:18

47:25 53:19

53:21 53:24 54:3

54:7 54:20

55:5 55:25 56:19

57:6 57:24 64:21

66:12 66:17

72:17 73:17

73:21 73:23 74:7

78:14 78:16

78:18 79:17

82:17 83:25 84:2

84:4

discharged

22:12 82:18

dischargers 51:23

54:16 58:3

58:7 59:7 62:4

67:11 67:15 70:3

70:4

discharges 8:19

8:20 13:5 13:7

13:11 57:10

58:18 61:25

67:14

discharging

23:3 24:2

24:23 70:1

discomfort 45:12

discuss 3:10 7:25

discussed 8:7

30:9 30:23

78:6 84:13 85:17

86:2

discussing 3:6

discussion 3:20

8:25 12:9

21:20 29:5

29:6 30:18 30:20

47:13 47:23 57:4
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 99

57:14 74:14

84:18

discussions 9:5

10:3 10:19 47:8

dispositive 40:19

disservice 27:23

distinction 62:22

distribution

13:20 33:18

33:21 34:5 34:20

34:25 38:23 39:4

39:24 39:25 41:2

41:3 41:6 43:8

43:12 43:18

43:21 44:2 66:19

68:6 68:9

distributions

43:14

District 6:22

14:12 83:5

Division 3:8

docket 7:7 7:9

8:3 86:20

document 12:7

33:1

documents 52:16

DOD 13:4

domestic 67:14

70:20 72:24

domestic-only

66:9

done 13:8 15:9

15:22 21:13

32:11 65:20

77:22 80:21 86:8

Donovan 5:15 5:15

don't...Karen

80:14

Dow 4:14 6:15

6:17 6:19 6:20

15:4 45:23

downstream 13:5

13:14 24:4

Doyle 4:10 4:10

37:13 37:13 49:5

49:5 54:18 55:11

56:2 56:12

60:1 60:6

60:13 60:18

60:21 60:25

61:12 61:18

Dr 33:1 33:9

35:20

drawn-out 29:24

drew 33:10

drive 26:5 26:6

26:15 27:18 72:6

driving 27:11

27:17 79:7

drop 55:22 66:25

dropping 56:5

dry 67:6

due 20:2

DuMars 5:2 5:2

during 8:4 20:6

20:8 22:23

Dyer 4:19 4:19

12:19 12:19

22:10 22:10

23:10 25:6 38:16

38:17 40:25 68:4

68:4 70:6 80:7

80:7 81:3

81:12 81:21

82:16 82:20 83:3

E

E-90s 23:12

earlier 31:4

42:14 70:7 71:7

easily 23:17

easy 24:15 67:2

68:16 68:18

eating 76:24

ECA 3:2 3:6 4:3

44:19 86:4 86:16

ecological

71:25 77:23

ecosystem 82:10

edification 55:2

effective 52:2

59:18

efficiencies

50:17 63:7

78:3 85:13

efficiency

37:21 45:7 49:15

50:9 51:20 52:18

71:20

efficient 10:21

76:3

effluent 15:15

15:21 28:19

48:20 48:21

48:25 53:16

53:17 54:5

54:7 55:8

55:23 56:6 63:10
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 100

63:24 64:3

64:9 73:15 73:24

74:24 78:17

78:23 79:5 79:7

effort 9:10

efforts 19:13

31:19

Eisenreich

76:18 76:18

80:13 80:14 81:9

81:16 82:3 82:19

82:22

either 22:5

30:7 47:20 64:19

66:6 67:18 80:4

Elaine 5:16

element 40:21

eliminated 27:23

Ellen 4:25 65:9

else 7:1 35:8

37:19 50:1

64:3 76:16

82:9 82:9

83:22 86:12

email 8:2

embarked 85:2

emissions 83:7

emitted 83:22

emphasize 71:5

empowers 60:25

enacted 61:15

endpoints 55:3

engaged 61:4

69:10

enhances 73:3

enters 33:2

entire 36:24 41:2

41:5

environment 11:12

32:24 34:5 35:11

36:7 42:24

43:2 43:6

49:11 50:22

52:16 59:19 62:6

62:25 63:3

63:4 71:23 72:3

environmental 3:8

12:4 19:25 25:21

36:25 37:7

49:3 49:9 49:9

49:24 50:13

52:15 52:22

57:19 57:23 58:4

58:10 61:14 62:1

62:16 63:9 63:11

64:10 64:25

71:11 71:12

72:10 78:5 79:6

environments

13:22

envisioned 85:16

EPA 3:1 3:7 4:8

4:9 5:5 5:14

5:15 5:16 5:17

5:18 5:22 5:23

5:24 5:25 8:10

8:15 10:2

10:18 22:13

24:16 26:22 30:2

30:3 31:9 32:2

32:9 32:13 41:16

47:8 47:17 69:23

71:9 71:15 74:12

75:1 75:2

76:18 82:2

86:1 86:22

EPA's 3:10 5:9

5:11 54:20

equally 68:11

errors 23:16

errs 49:25

especially 26:8

30:9 65:15

essentially

26:4 26:6

43:22 85:3

established 29:17

et 19:24

Etsu 45:25

evaluate 41:20

70:19

evaluation 77:22

evaluations 78:1

event 13:8

events 73:13

eventually 22:8

everyone 3:5

4:5 7:5 7:20

86:6 86:25

everyone's 55:2

everything

33:25 61:17 64:3

67:19 78:21

evident 82:4

evolution 32:7

77:24

evolved 71:16
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 101

Evonik 4:16

5:20 45:23 69:4

exact 82:7

exactly 8:25

36:20 54:17

70:11 80:19

82:19

examination 22:12

examine 23:24

example 36:19

48:18

excellent 84:24

except 28:19

53:25

exclude 26:25

exclusion 20:20

exclusive 39:21

exclusively

58:2 59:7

exercise 16:4

exercises 15:9

15:12

existing 16:16

16:24 74:10

expanding 85:5

expect 15:10

experience 21:1

21:2 32:20

experiment 34:7

expertise 76:11

experts 33:4

36:23 36:24

36:25

explain 47:7

58:11 59:11 61:3

72:21

explanations 85:7

exposure 24:11

76:10 83:10

exposures 77:3

express 8:6 61:22

expressed 45:17

70:16

extensively 64:14

extent 26:12

29:10

extraordinarily

63:8

extremely 70:19

F

face 36:17

facilities

11:10 16:11 22:4

25:3 26:7

49:15 51:21 59:5

69:15 72:23

75:19

facility 82:17

fact 21:12

43:10 49:23

60:20

factor 12:17

18:22 19:19 25:5

26:12 31:10

31:22 32:7 34:10

83:23

factors 9:4 9:7

9:17 10:9

10:11 11:7

11:8 11:11 11:18

11:21 12:5 12:10

15:7 16:1

16:25 17:1

17:4 17:7 17:8

17:20 17:23

18:11 19:12 20:7

20:9 20:13 22:24

24:8 26:4 26:5

26:9 26:14 27:18

27:22 28:21 31:8

34:10 34:12 38:5

38:10 39:6 40:10

40:23 42:16

42:18 42:21

42:25 43:3 48:25

56:6

fairly 19:11

31:18 51:16

68:21

fashion 69:19

fate 36:6 81:5

favor 32:21

fed 18:17 18:21

feedback 3:12

10:13 17:3

17:5 17:9

17:10 18:5 26:13

27:1 27:13 27:20

feeding 80:19

feel 30:24 35:13

Fehrenbacher

4:9 4:9 10:17

10:17 17:16

17:17 18:9 25:17

25:18 27:25 41:9

48:22 63:13 64:1

77:15
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 102

FEMALE 11:17

final 56:17

finally 9:19

finding 32:10

65:18 66:16

fine 17:24

fine-tune 16:1

finished 47:12

Finley 30:12

30:12 30:22 32:6

41:23 65:22

66:14 67:13

69:21

first 3:20 4:4

8:21 9:23 10:4

14:14 16:19

18:13 23:11 42:2

52:9 56:9

59:12 61:16

65:24 78:20

fish 74:6 76:6

76:9 76:12 76:20

76:20 76:23

76:24 78:18

79:23 80:10

80:10 80:11

80:15 81:18

82:12 82:15

five 10:25

16:21 21:16

27:13 35:15

35:24 40:13

40:14 41:19 42:7

44:4 45:9

46:16 47:8

57:7 57:13

64:2 66:10

fixed 39:25

Flack 4:23 4:23

floor 79:13 84:10

flow 9:8 9:15

16:2 18:19

19:8 22:23 24:14

28:18 31:1

33:5 33:12

55:6 55:7

58:15 68:18

flowing 24:23

flows 14:8

focus 3:9 3:20

19:5 31:6

40:22 41:6

52:5 61:1 72:2

72:8

focused 49:8

focus-in 26:21

focusing 19:6

30:4 30:8

30:17 47:24

62:25

folks 14:16

follow-up 25:25

50:5

food 77:4 77:6

77:13 77:21 78:1

79:23 85:14

forced 83:20

form 27:9

formulate 56:23

formulating

57:1 69:11

formulation 57:18

formulator 66:6

formulators 51:24

58:22 65:16

67:11

forth 84:23

forward 7:21

17:14 46:21 47:6

fraction 68:9

frankly 49:10

69:13

frequently 19:4

front 60:15

full 16:15

17:12 83:13

fully 12:9

28:20 46:16

51:10

fundamental 33:15

35:12 36:2

future 37:6 64:16

G

gain 70:4

Gamble 4:19 12:19

Gary 6:17

gas 83:19 83:21

gather 52:17

gear 43:1

Gene 4:21

general 5:24 50:7

60:7 82:8 82:9

84:11 84:17

generally 19:1

31:17
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 103

generate 35:18

46:9

generated 36:22

49:18 49:22

generation 45:7

geographic 11:5

geography 9:11

19:25

George 6:3

gets 20:3 33:14

44:2 63:2

getting 11:22

16:12 37:22

43:10 49:14

86:11

given 25:2 70:11

gives 3:11

12:15 28:10

64:25

giving 58:4

gleaned 27:4

goal 3:12 4:2

28:2 32:12 73:3

goals 23:21 52:13

71:9 77:25

gone 21:19

government 36:18

Gram 6:25 6:25

great 52:23

greater 13:3

41:21 42:22 43:5

78:7

greatest 8:24

8:24 18:16

Griffith 6:21

6:21 14:11 14:11

31:24 31:25

66:24 67:21

67:21 83:4 83:4

group 4:22 9:5

41:6 61:1

groups 8:11

Guerrero 5:19

5:19

guess 10:3

15:24 26:17

26:23 27:11 28:4

29:14 37:20

39:21 39:22

40:25 43:7 43:13

43:16 45:6 48:22

50:25 52:6

53:4 55:12 57:22

59:3 59:6

59:10 61:23 62:3

62:9 62:14 62:24

64:6 64:12 64:20

64:23 71:17

84:17 84:20

guidance 17:14

guide 85:4

guilty 13:13

guys 10:12

27:15 42:18

59:21 59:24

60:23 84:25

H

half 86:6

hand 27:7

handed 36:25

handful 39:11

handpicking 40:6

happened 67:25

happens 47:9

49:12

hard 43:14

65:23 66:21

harkening 16:17

harm 37:6 63:4

haven't 21:25

having 10:21

21:17 28:11

35:15 45:12 54:3

74:2 80:20

health 51:11

59:19 82:9

healthy 82:1

hear 46:25

65:24 75:17

79:14

heard 18:4

21:14 42:20 45:6

45:11 71:20

79:15 86:8 86:10

86:10

hearing 44:25

48:1 71:17 76:1

Heckman 4:10 6:4

held 60:14

help 4:2 7:15

7:18 14:17 42:10

56:7 56:25 75:11

79:6

helpful 8:12

17:21 24:17 27:5
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 104

helping 11:9

helps 14:17

here's 78:15

he's 66:15

Hi 14:11 65:22

high 13:23 14:8

19:21 19:23

19:24 32:10

34:23 35:5

35:7 35:7 35:9

53:2 63:8 68:21

higher 31:12

64:10 76:20

76:21 82:14

highest 18:16

Hiley 6:11 6:11

history 8:18

23:12

hit 32:12

Holiday 61:22

honestly 66:18

hope 8:1 20:6

hopeful 10:12

32:10

hour 30:5 30:11

House 5:25

households 33:2

huge 68:9

Hugh 4:23

hundreds 36:4

51:24 58:22

hypothetical 82:5

I

ice 24:12 39:6

I'd 4:4 10:2 22:5

51:4 51:12

idea 26:2 28:17

42:6 43:8

71:18 76:19

80:16 80:17

81:22 81:25

ideas 84:14

identical 33:7

identification

16:21

identified 7:2

12:10 29:11

identifies 6:5

68:8

identify 5:7

6:8 19:18 35:3

identifying 43:1

I'll 51:17

57:20 59:10

59:15 61:23

62:18 76:11

77:18 79:19

I'm 3:7 7:21

16:24 25:15

27:11 30:6 30:23

32:8 37:19 40:14

40:25 43:23 47:2

48:1 53:6 54:9

60:1 61:21

65:8 65:23 66:12

67:17 70:4 71:20

74:21 75:2 75:17

76:13 80:3 81:9

impact 19:10 20:8

31:23 49:11

64:13 68:17

impacted 81:13

impacting 82:10

implemented 61:9

importance 42:22

important 11:8

17:2 19:22 20:14

21:21 33:12

40:11 48:23

57:16 61:11

63:20 74:8

76:7 83:11

importantly 50:21

impossible 80:18

impression 17:7

29:8 46:18

Inaudible 6:14

include 20:23

22:24 35:23 39:8

49:7 54:12 56:21

73:14 77:3

included 19:4

20:10 26:12 48:6

77:4 77:10

includes 45:22

including 23:4

31:4 52:22 57:2

inclusion 20:17

20:19

incorporate 21:17

incorporated

33:25

increased 45:14

indeed 72:12

indicated 12:12
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 105

20:16

indicative 63:2

indicator 68:2

68:22

indirect 3:15

3:22 8:19

40:15 53:21

53:24 56:18 57:6

57:22 58:2 58:18

59:7 62:3

64:21 64:24

66:12 67:11

67:14 70:3 72:17

73:2 73:21

74:6 75:7 84:4

individuals 6:6

industrial 8:18

8:19 8:22

47:13 58:14

58:19 58:25

62:20 62:23

63:10 63:18

63:24 64:3

64:9 65:4

65:13 66:5 66:17

66:25 67:5

67:7 68:14 69:18

69:25 70:9 70:10

70:15 71:24

72:22 75:13

75:14 75:19 78:4

industries 69:9

industry 46:5

68:6

industry's 39:18

inferences 33:10

influent 18:15

18:19 33:5 48:21

48:24 48:25 49:7

50:3 50:6 51:8

53:15 53:16

53:23 54:4

54:6 54:12

55:7 55:10 55:17

55:22 56:5 63:19

66:5 68:23

70:1 73:14 73:18

73:23 74:24

78:19 79:1

inform 41:14

information

7:15 11:4

12:16 24:5

27:4 28:10 28:13

28:23 32:15 34:1

35:17 43:11

43:19 44:9 48:24

50:4 51:3

51:18 52:10

52:18 52:23

52:24 57:16 58:7

63:25 64:25

71:19 71:22 84:7

85:12

informative 28:16

28:24 40:18

56:24

inherent 12:25

initial 9:3 39:18

initiative 77:9

Inn 61:22

input 3:24 7:22

50:14 55:3

66:9 70:15

inputs 11:13

inside 49:12

instance 13:1

24:8

instantaneous

39:6

Institute 6:10

8:2 13:19 30:8

32:17

integrated 38:3

integrity 81:7

81:10 81:17

intend 64:4

intended 53:5

intending 25:20

25:22

intends 71:15

intent 16:19

42:17

intentionally

42:25

interact 32:19

interest 19:12

26:4 26:16 46:10

51:22 52:3

53:3 65:6

interested 3:11

3:14 10:21

16:7 16:8 26:3

26:8 30:6

38:14 41:1

41:2 41:10 44:11

44:12 47:20

51:22 52:7 60:14

64:21 72:17

79:13 80:4 84:12

86:22

interesting 13:17
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 106

71:21

interests 10:20

interjections

9:24

intermittent

22:22

internally 47:8

intersection 18:1

intricacies 23:24

introduce 4:5

introduction 3:17

invertebrate

80:24

invertebrates

80:22 80:23

investigating

13:19

invite 28:5

involved 11:15

irrelevant 38:5

38:7 42:19 43:4

ISIS 23:13

issue 8:7 8:24

12:21 28:1

30:8 49:13 51:13

53:10 73:20

issues 14:4 30:21

62:9 74:1

item 9:23

it's 8:13 11:12

11:16 13:22

15:17 18:6 20:17

22:14 24:15 26:4

28:12 28:16

28:24 33:3

33:6 33:12 35:16

35:16 35:22 36:1

37:5 38:1

39:23 40:5 43:14

44:10 46:21

48:23 51:8 53:17

56:8 58:1 59:4

59:6 59:16 59:23

62:4 62:25 64:23

65:23 66:21

67:17 71:2

71:3 71:21 71:24

72:3 72:3

72:21 72:22 74:8

75:5 75:5 76:7

77:16 79:4

79:7 79:24 80:13

80:15 80:18

80:23 81:17 82:9

83:10 83:12 85:6

85:18

I've 51:14 52:9

J

Jaeshin 6:19 12:8

16:4

Jenny 5:21

Jessica 5:23 5:24

job 82:16

Joe 4:17 5:13

judgment 40:20

64:18

June 86:4

justification

20:19

K

Karen 76:18

Karlus 26:1 29:3

Karluss 4:13

11:21 42:12

57:20 70:24

77:11 84:15

Kathy 4:14 15:4

48:2 54:19

Keating 5:16 5:16

Keira 5:17

Keller 4:10 6:3

Kent 6:15

key 9:4 9:6 18:11

40:23 41:4 51:22

kick 44:21

Kim 6:19 6:19

12:8 33:1 33:9

kinds 72:23

knew 34:3

knowledge 11:11

12:14 15:25 34:9

35:5 65:11

known 12:12 28:14

Koch 5:20 5:20

Kozerski 6:17

6:17

Krowka 4:17 4:17

L

LA 6:21 14:12

83:5

lack 11:10

lagoon 13:14

13:16 13:24

14:22 14:24 21:6
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 107

22:8 22:16 45:14

lagoons 11:3

12:22 12:25

13:19 13:21 14:7

14:19 15:2

15:3 18:25 20:23

21:11 22:2 22:15

22:21 22:22

22:25 23:5

23:8 23:24

24:8 24:19 26:17

27:3 28:7

28:10 28:11

28:14 28:17

30:20 31:2 31:5

laid 17:1 75:6

laid-out 9:16

language 85:1

large 18:14 18:19

39:13 42:7 68:11

larger 62:14

largest 14:22

last 6:13 12:6

33:24 34:13

35:19 35:22

53:13 57:5 84:4

later 9:21 48:4

48:7

law 61:20

lawyer 61:21

layer 22:25 23:5

lead 15:13

29:24 74:13

leading 19:13

least 17:5 27:2

37:17 40:22

46:17 64:9

leaves 54:7

left-hand 39:2

legal 24:22

less 19:4 29:23

31:20 35:1

67:1 68:10 69:25

lesser 42:22

let's 35:3 54:5

73:6 73:11 74:14

letter 32:1

letters 8:7

level 22:13 22:13

32:10 70:15

76:20 76:21

80:10 80:10

80:11 82:15

82:15

levels 12:17

64:10

Lewis 3:4 3:7 5:6

6:5 6:12 7:1

7:19 16:6 30:3

30:3 30:16 30:16

41:16 41:16

42:11 44:18

44:18 47:12 48:8

48:12 48:16

56:17 73:6 78:10

78:13 78:25 79:2

79:9 79:12 79:21

79:24 80:2 83:24

86:1 86:14

likelihood 42:23

likely 13:6

13:7 59:5 80:23

likewise 49:8

61:18

limit 15:2

15:18 15:20

limited 51:12

58:14

line 14:15

14:17 28:5 41:17

65:23 66:15

79:14 80:4

linear 32:22

Lisa 5:2 6:23

Liscoe 6:3 6:3

lists 18:10

literature 52:19

little 10:13

22:16 32:22 34:3

45:1 45:2

48:14 60:2 65:23

load 39:7 57:19

loading 13:21

13:23 49:9 49:24

50:13 79:7

loadings 65:1

loads 58:5

locations 11:6

logic 53:20 59:2

long 29:24

long-time 59:23

lot 8:10 8:13

8:14 9:2 14:14

17:19 31:1

36:9 43:9

43:21 47:15

64:11 85:15
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 108

low 13:21 14:8

18:1 18:15 34:22

34:25 58:25

66:20

lower 39:1

70:11 76:19

76:21 80:9 80:11

82:15

lowest 18:20

LUCHESKI 6:2

Luckeski 6:2

M

magnification

76:15

main 34:15 42:2

maintain 45:15

maintains 81:24

major 3:14

49:11 68:1 68:1

majority 30:24

30:25 39:1 70:13

management 29:6

29:12 29:16

29:17 29:21

53:12 72:7

85:8 86:9 86:15

managers 46:15

46:20 47:4 47:5

manufacture 59:21

manufacturer 61:4

68:3 69:20

manufacturers

60:4 60:6 60:7

60:8 60:11 60:16

60:19 61:24

66:19 67:8

manufacturing

40:14 67:6 68:23

69:14 70:2

Marcus 5:5 7:13

marker 76:10

78:18

markers 77:3

marketplace 50:10

50:19

mass 18:16

18:20 49:2 83:13

83:17

material 12:15

81:6

materials 7:6

12:1 21:3 25:7

26:23 34:16

34:20 35:10

36:13 37:16

42:23 43:1

43:6 62:13

63:7 68:25

69:7 69:11 69:19

85:20 86:19

matrix 9:16 17:25

21:9 26:5 31:8

33:13 34:6

34:7 34:10

38:8 38:8

38:21 38:25

39:16 39:18 40:4

40:13 65:19

may 4:16 4:16

12:11 15:3 17:15

24:1 30:19

32:2 55:25

69:4 69:4

70:18 79:14

81:21 82:12

82:14 83:20

maybe 9:22

11:17 11:21

20:11 20:14

20:22 21:7 23:23

28:4 33:15 33:18

47:10 48:3 51:25

58:22 66:14

75:11 76:4

76:7 83:14

mean 25:2 32:25

33:3 37:20 37:25

40:24 43:17 44:3

46:6 46:15 46:24

51:19 52:12

53:18 60:8 61:12

61:19 65:20 78:6

meandering 82:21

meaning 32:3

means 28:21 34:22

measure 55:10

measured 81:8

measurement 54:12

measures 29:12

Measury 5:17 5:17

media 25:22 71:12

73:14 84:8

meet 24:19

meeting 3:2 3:6

3:9 3:19 4:1 4:7

6:6 7:4 7:6

7:8 7:11 7:23

8:4 10:25

24:21 44:19 69:8
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 109

86:16 86:23 87:1

meetings 8:11

8:23 9:3

member 44:20 45:2

45:20 46:25

47:17 47:18

49:19 56:22

57:15 75:17

84:11 86:21

members 50:9

50:19 57:2 62:15

memory 52:8 53:1

mention 30:5

mentioned 8:21

31:3 32:1 83:9

86:18

met 86:4

method 9:8

16:11 18:22

18:23 18:25

methods 19:3 19:5

19:7

metric 70:17

mic 5:8

microphone 4:7

middle 18:10

Mihaich 4:25 4:25

65:9 67:9

MIHIACH 65:8 66:1

miles 82:20

millions 36:4

mind 29:7 29:14

52:5 69:12

Minister 37:7

minor 3:18 75:9

minute 44:14

minutes 17:22

missing 37:25

mix 45:9 45:16

46:17

mixtures 59:18

model 15:15 24:12

24:13 24:15

modeling 15:9

15:12 16:4 16:7

models 36:14

36:14 36:16

83:10

modifications

16:10

Momentive 5:2

6:11 45:23

moments 73:23

monitor 25:3

25:13 26:7 74:11

monitored 10:8

28:8 47:19 54:22

55:4 55:4

55:25 57:8 57:13

73:25

monitoring 3:10

7:24 8:16 8:17

8:25 9:10 9:20

10:6 12:4

15:22 16:8

16:9 19:13 19:13

19:18 20:6

21:3 21:11

24:6 26:21

28:2 28:22 28:25

29:15 34:14

35:22 36:9

40:9 43:15

51:9 56:21 56:23

58:2 59:6

59:14 61:14 73:2

73:11 74:2 74:12

75:18

monitors 74:8

months 86:6

moreover 49:13

move 47:10

56:16 73:6 73:7

moving 17:13 47:6

multiple 43:11

74:6 76:6 76:12

municipal 13:5

13:6 21:16 24:14

mute 14:17

mutually 39:21

N

NACWA 8:3 20:15

20:25 30:7 30:10

30:12 32:19

65:22 69:21

Nahn 5:14

narrow 24:18

narrowed 9:6

national 25:7

85:19

nature 20:3

nearly 80:18

necessarily

26:2 27:14 31:16

50:6 50:11 50:14
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 110

50:15 59:8 63:2

necessary 20:22

29:12 29:21 30:1

53:7 83:13 83:17

negotiating 59:13

Nguyen 5:14 5:14

nine 40:17 57:5

57:7 57:12

noise 14:15 14:18

non...POTWs 58:16

noncompliance

13:8

none 48:1 84:3

non-industrial

58:17 66:9 66:11

non-SEHSC 57:2

non-sites 27:3

normalizes 70:8

not...the 43:10

not...we 28:24

note 9:24 10:6

64:7

notes 41:17

nothing 28:18

31:11 37:4 83:1

noticed 76:5 83:8

notion 26:11

NPDS 23:13

numerical 12:21

numerous 69:9

77:6

O

object 75:21

objective 76:7

obviously 7:23

9:1 26:15

44:21 46:4

70:9 84:5 86:9

occur 74:3

o'clock 4:2

offer 46:20 46:22

47:6 59:14 62:18

75:15 75:20

78:10

offered 46:23

58:6 61:24 63:17

Office 5:9 5:11

11:14

offices 8:14

ofthey 9:14

Oh 55:15

okay 3:4 7:3 9:25

10:1 22:10 25:16

30:22 35:2 40:12

45:18 45:22 46:2

46:12 47:2 48:18

53:9 56:11 58:15

59:10 60:18 61:2

62:18 65:7

73:5 73:9

75:10 75:25 76:4

78:12 79:12 80:2

83:3

ones 12:11

60:15 66:12 77:7

ongoing 35:23

46:5 46:8

on-site 47:14

50:15 73:24

onto 61:6

open 22:5 76:1

79:13 84:10

operate 14:23

49:17

operations 7:11

opinion 45:19

73:19 73:22 84:6

opportunity

3:11 3:24 10:3

43:5 47:22 50:10

69:6 84:24

opposed 59:5

opposite 39:3

or...in 65:19

organic 9:10

19:14 19:21

19:24

organizations 8:5

organized 42:3

oriented 40:10

original 21:10

43:16 52:12

57:12 71:8 75:22

77:19 85:1

originally

47:19 73:4

78:7 85:16

others 9:6

64:12 65:10

83:17

otherwise 83:20

83:21

ought 27:6
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 111

ourselves 13:12

outfall 55:16

55:24 73:15

outfalls 55:13

outlying 41:20

outside 4:11

overall 21:8

33:15 49:2 63:11

64:13

overbuilt 25:11

overview 8:9

P

p.m 87:2

page 18:9 18:10

28:1 29:4

painful 56:12

panel 36:24

paper 18:6 33:11

parameters

12:18 25:10

54:21 55:3

participating

7:21

particular 10:6

15:7 16:25 25:14

26:18 49:7

50:7 68:24 70:10

71:17 84:13

particularly

49:23 56:15

parties 3:11 3:14

10:21 30:6 47:16

47:20 57:4 57:15

79:13 80:4 84:12

86:22

partition 19:15

partitioning 20:2

20:8

passed 59:23

past 8:23 8:23

10:25 12:6 23:16

30:5 30:11

path 85:17

pathway 83:11

pathways 52:14

71:11 72:9

Patrick 6:21

14:11 31:24

66:14 66:23

67:21 83:4

Paul 3:7 6:9 22:6

30:3 30:16 32:16

41:16 44:18 48:2

58:21 79:2 79:19

PCPC 4:20 12:20

20:16 20:25

Penberthy 4:8 4:8

7:5 7:20 14:6

16:2 17:24 21:10

22:2 22:7 23:8

24:25 25:16

28:15 29:18

32:14 32:25 33:9

36:1 38:2

38:13 40:9 43:23

44:10 44:16

45:18 45:22

45:25 46:2 46:12

47:2 50:2

50:25 53:9 53:18

54:9 54:17

55:6 55:15 55:20

56:4 56:11 56:14

58:11 59:10 60:4

60:10 60:16

60:19 60:23 61:2

61:16 61:19

62:18 64:17

64:20 65:2

65:6 72:16 72:20

73:5 75:4 75:9

75:12 75:15

75:18 75:24 76:2

76:11 86:13

people 3:4

14:22 25:3 31:15

per 15:16 31:20

32:23 68:18

68:19 68:21 70:8

70:10 70:16

perceived 54:23

percent 18:24

31:4 53:2 67:2

67:4 68:6

68:10 68:12

68:12 69:25

percentage

58:25 59:1 68:12

perception 71:14

perennial 24:14

perform 53:5

84:25

perhaps 25:12

47:10 67:18

perimeter 5:7

periodic 36:3

permanent 23:13

Perricane 6:23
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 112

6:23

persistent 36:3

person 31:20

Personal 4:17

perspectives

57:22 84:13

pertaining 32:18

perturbations

13:15

phase 73:8

phenomenon 22:21

philosophically

53:25

philosophy 38:18

phone 7:1 22:6

30:15 47:21

65:11

phrased 54:24

physical 12:3

14:9 34:4 36:5

36:13 36:21

pick 23:8

pick-up 53:23

piece 57:16

pieces 20:12 75:7

pinpoint 80:19

places 15:23

25:13 75:8 84:19

plan 4:1 8:16

40:9

plant 32:4

49:12 67:1 68:19

69:17 78:2 83:14

83:16 85:13

plants 11:3 14:22

14:23 14:24 21:4

23:19 25:9 28:22

31:7 39:11 39:14

40:7 42:4

52:21 67:3

68:1 70:14 83:8

play 34:5 38:11

38:11 56:6

please 6:8 6:12

7:14 65:25

Plotzke 4:14 4:14

15:4 15:4 16:3

20:11 21:12 22:5

28:4 33:14 36:11

38:6 48:2

48:10 48:14

48:18 53:13 54:2

54:14 55:18 56:8

56:13 74:17 75:5

75:10 75:14

75:22 75:25 76:4

76:16 77:1 78:12

78:15 79:4 79:11

79:18 79:22 80:1

plus 40:17

point 8:4 29:3

33:1 39:21 40:19

42:19 43:2 46:13

50:6 53:25

55:1 59:14 63:20

64:2 64:18

71:1 71:5 71:7

75:11 77:24 80:8

81:16 83:2 84:18

points 42:14 44:2

51:1

policy 59:16

59:23

pollutants

13:11 52:22

polymer 71:4

pond 13:25

pool 60:2

pools 58:20

poorest 13:2

populate 35:5

39:9

populating 34:24

population 9:7

12:12 13:20

13:22 13:23 15:3

15:7 15:8 18:1

18:13 18:14

18:18 26:11

28:17 31:1 31:10

31:12 31:21

32:12 33:3

33:4 33:8

33:11 39:13 74:9

74:11 81:13

populations

9:15 14:8 31:3

position 56:1

63:14 84:8

possible 51:2

63:21

possibly 66:21

post 85:4

potential 19:18

38:24 56:25

potentially 36:6

POTW 3:20 9:8

10:5 13:21 18:14

18:17 18:18
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 113

18:21 18:23

26:11 30:17

33:12 45:10 62:6

63:1 63:5

63:17 64:9

66:9 66:16 66:20

68:24 71:19

73:14 79:16 84:1

POTWs 3:16 9:1

9:13 9:13 9:23

10:7 10:23 13:24

19:18 19:20

25:24 26:3

30:4 30:9

40:11 40:16

40:22 41:12

41:19 45:15

47:13 52:2 52:25

55:19 56:10

57:24 57:25

58:13 58:16

58:18 58:23 59:1

62:6 62:19 62:21

62:22 62:23 63:6

63:18 63:22

63:23 64:2

64:8 65:3

65:12 66:3 66:18

67:10 69:24 71:2

72:23 73:15

74:20 74:23 75:1

75:3 75:6

75:20 79:10

83:25

pounds 36:4

Powell 6:20 6:20

practical 10:21

pragmatism 22:18

predatory 76:14

predicted 15:20

36:21

predicting 36:15

preferentially

19:15 25:4

preliminary 51:14

prepare 86:23

prepared 12:8

33:1 73:1 85:24

preparing 7:7

presence 35:10

74:8

present 6:6

presented 86:19

presumed 62:1

pre-treatment

73:24

pretty 8:22

9:16 22:8

40:20 52:19

72:21 72:25

previous 8:11

previously 73:10

primarily 58:16

58:16

primary 12:22

59:12

prior 9:3 10:19

37:1 80:21

privilege 24:10

probabilistic

34:17 35:19

38:20 39:19

39:24 40:21 41:5

probability 13:9

probably 21:5

21:20 23:22

33:14 40:15

41:24 59:4 70:21

72:13 74:17

problem 44:25

53:25

problems 68:1

process 15:1

21:19 22:20

29:25 35:23 38:3

56:22 57:11

59:21 60:11

71:14 83:13

84:21 86:5

86:5 86:7 86:18

processes 11:6

processing 57:1

57:18 69:10

processor 61:6

62:10 66:6

68:3 69:20

processors

51:24 51:25

58:23 60:2

60:5 60:6 60:8

60:9 60:21 60:24

61:1 62:13 65:17

67:8 67:11

Proctor 4:19

12:19

produce 77:8

product 57:19

products 4:18

31:13 56:23 71:3

program 16:9
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 114

29:15 34:21

36:10 52:11

52:13 52:17 53:4

53:8 54:13 54:15

58:1 71:9

71:15 71:19 73:3

77:5 77:25 85:3

programs 46:5

46:9

properly 32:8

properties 12:3

12:25 34:4

36:6 36:13 36:21

proportional 33:3

proposal 3:10

3:15 7:24 8:10

8:18 9:3 9:19

10:15 16:10

16:10 16:16

16:24 17:19 18:4

18:10 20:10

21:10 21:13

21:15 26:20

26:21 27:12

27:25 28:4 33:16

37:22 38:9 39:18

42:2 43:16

44:1 47:4 49:8

54:20 56:21

58:12 63:17

69:23 72:10

72:14 72:20 74:3

75:23 77:2 77:10

84:22 85:5 85:23

propose 78:16

78:19

proposed 9:12

31:9 33:20

35:2 47:19 48:19

63:23 74:23 75:3

76:9 78:16

proposes 55:21

proposing 54:21

76:8

proprietary 50:11

50:16 50:20

protections 51:12

protocol 81:25

provide 3:12 12:7

12:11 16:3 29:16

37:10 40:3 41:19

41:21 43:19 46:4

46:11 57:8

58:3 58:6

62:15 78:25

provided 8:15

12:6 17:10 17:15

19:9 27:1

32:18 34:12

35:19 36:23

41:22 72:11 74:7

provides 85:24

providing 85:22

public 7:6 7:9

publication 77:7

publicly 24:15

49:18

publicly-owned

8:20

purely 37:22

purpose 63:6

76:25

purposes 27:10

30:2

pursue 47:6

pushed 61:6

putting 74:18

Q

quadrant 38:10

quality 22:11

22:14 23:17

23:21 24:1 24:21

27:24

query 23:17

question 10:4

20:4 20:22 21:22

24:9 39:15 40:25

48:22 54:18 56:2

65:8 65:19 65:25

66:1 66:3 67:9

67:12 69:1 77:12

81:3

questioned 20:15

questions 7:10

14:3 21:6 59:4

quiet 14:16

quite 11:14 12:15

15:21 15:25

20:25 21:2 28:10

R

raceway 82:18

range 10:7

15:19 23:16 34:8

34:22 41:12

43:14 44:12 53:2

ranked 40:8

rarity 14:1

rate 9:8 19:8
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 115

32:24 33:6

rates 9:15

rather 67:19

rationale 16:16

16:20 16:23

17:20 17:22

20:10 62:22

72:24 73:18 79:1

79:3

Ray 6:2 6:11

reach 23:20

reached 3:13

reads 74:21

real 36:22

realistic 32:11

really 3:12

7:18 7:25

10:19 11:4 11:12

11:16 12:14 13:1

13:3 13:19

14:1 17:19 20:17

21:13 21:22

21:23 23:1 24:17

25:13 28:13

34:11 35:12

36:19 38:10

39:17 42:5

42:6 42:7

43:13 47:15

49:24 49:25 52:1

56:3 62:15 67:17

68:15 68:17

70:12 79:6

79:7 80:13 80:15

81:5

reason 26:20

26:25 42:1 51:22

59:12 77:19

80:22 85:11

reasonable

28:12 85:7

reasoning 17:13

receive 9:1 62:19

62:23 65:4 65:13

69:19

received 8:2 30:6

63:10 63:24

receives 18:19

receiving 9:9

9:10 19:8 19:9

19:14 19:20

63:18 69:17

70:15

recess 44:17

recognize 12:21

14:7

recognized 33:10

recommended 74:2

reconcile 29:7

reconsideration

46:13

reconvene 86:16

reconvening 44:19

record 7:14 25:2

recorded 4:7

reference 81:15

referenced 30:18

refine 34:12

refinery 67:6

reflect 80:24

refuse 75:16

regard 50:3

regarded 51:8

regarding 17:4

17:20 22:1 30:9

regardless 64:2

regional 8:14

22:13 82:2

regions 11:14

regularly 46:6

regulatory 37:9

reject 27:6

relate 53:20

related 8:6 8:7

52:18 71:1

relative 28:21

71:23 78:4 85:13

relatively 39:13

relaxed 22:16

release 56:25

57:9

released 83:22

releases 9:1

57:23 62:5

63:9 83:23

relegated 31:2

relevant 25:5

65:19 66:10

67:17

relied 64:18

rely 29:1

relying 21:1

remarks 30:19
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 116

remember 52:16

remind 7:5

79:19 86:6

removal 26:14

39:7

repeat 6:12 65:24

replete 52:20

report 83:21

reporter 5:21

represent 18:19

42:1 62:12 76:21

representative

25:14 25:24 26:3

26:24 28:8 70:23

representatives

8:5

represented 28:11

representing 4:20

4:21 12:20

represents

25:21 84:23

requests 21:17

requires 57:14

73:20

respect 10:5 17:6

17:13 26:17

27:14 27:22

42:22 43:7 52:24

52:24 54:20

55:12 58:12

59:17 61:24 62:3

62:9 62:16 79:16

responded 21:13

response 39:17

responses 11:19

responsibility

59:20 60:10

responsible 59:24

result 18:15

31:16

results 41:20

41:24

rethinking 45:19

review 36:24 37:1

37:1 37:4

64:14 73:11

reviewed 11:7

revised 3:10 7:24

8:10

revision 47:4

revisit 53:16

54:6 83:2

revisited 82:25

Rick 5:9

risk 11:24 25:7

25:20 25:23

26:22 27:5 27:10

27:20 27:24 29:6

29:9 29:11 29:12

29:16 29:17

29:20 29:21

29:22 29:23

29:25 34:17

34:19 35:9 35:19

38:20 41:14

43:19 53:5 62:17

63:16 63:19 64:4

64:15 71:25 72:7

72:8 77:14 77:20

77:23 78:8 83:11

83:23 84:25

85:19 85:25

risks 29:13

robust 29:23

Robyn 5:11

role 34:5 38:11

room 5:7 6:6

7:2 30:14 45:1

47:21

routine 77:22

rules 61:13

run 4:1 15:11

25:11 84:5

rural 13:22

Russell 4:16 69:4

S

safety 51:11

sample 48:19

73:10 73:14

74:14 80:24

82:23 82:24 83:1

83:2 83:15

sampled 84:9

samples 35:21

38:22 40:13

sampling 3:23

9:20 19:19 39:25

41:18 41:19 48:8

48:15 53:15 55:1

58:20 72:17

73:13 74:5 79:16

82:8 84:2

Sanitation 6:22

14:12 83:5

saw 17:5

scale 13:2
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 117

scaled 33:6

scenario 33:17

33:20 35:13

44:11

scenarios 35:5

scenes 11:16

SCHSE 26:1

science 37:23

scientific

16:16 16:23

scope 24:18

78:6 85:6

Scott 4:19

12:19 17:4

22:6 22:10 38:17

65:20 68:4 69:16

80:6 80:7

Scott's 19:2 22:7

screening 24:20

69:1

seated 8:11

second 14:19

18:22 28:1

29:4 55:1

section 59:15

61:5 61:13

sediment 28:20

34:14 34:18

48:20 55:16

55:24 73:15

74:24 78:17

78:23

sedimentation

20:2

sediments 55:13

seeing 37:16

seem 25:2 51:16

seems 33:4

67:18 71:16 72:6

85:11

seen 35:8

SEHSC 4:11 4:12

4:13 4:15 5:19

12:7 42:3

44:19 47:17

47:18 55:21

56:20 57:6 57:15

57:21 58:2

59:7 73:17 73:19

74:1 74:6

74:15 84:11

84:16 84:20

86:21

select 16:11

28:22 61:1 81:23

selected 63:22

63:23

selection 12:25

17:2 17:4 17:7

20:12 22:25

27:17 42:25

58:13

selfexplanatory 8:22

senior 85:7

sense 19:5

43:15 49:1 49:12

58:4 66:13 69:23

85:20

sensitivity 15:12

sent 7:24

separate 67:13

67:20

series 81:24

serve 9:15 15:3

19:1 28:18

served 9:7

14:22 15:8 18:13

26:11

serves 18:14

service 12:13

13:21

serving 18:18

sets 74:13

settle 66:11

settling 22:21

several 3:4 6:7

9:4 19:20

30:10 30:18

82:20

share 44:22 46:14

46:19 47:3 50:1

shared 49:19

sheet 7:13

she's 28:5

shifts 35:1

Shin 45:25

Shin-Etsu 4:22

sides 56:18

signal 25:12

significant 13:8

significantly 9:7

62:20

sign-up 7:13

Silicone 4:22
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 118

Silicones 5:1 5:4

siloxane 3:2

9:1 15:14 70:11

siloxanes 3:6

3:10 18:17 18:21

19:10 19:15 20:2

24:5 36:4

38:24 39:17

44:19 51:21 52:2

56:22 56:23

56:25 57:17

58:19 67:8 67:15

68:1 83:19

similar 40:15

53:6 79:5

Similarly 18:18

simple 56:2

simply 81:18

site 16:1 17:2

17:4 54:4 55:5

56:17 57:10

57:10 64:12 70:2

73:13 74:2

74:3 78:18 78:22

80:16 80:20 81:1

81:20 81:23 82:1

82:7 82:8

82:13 82:25

83:10 84:2

sites 3:15 3:16

3:21 3:22 3:23

8:18 8:19 8:22

9:20 10:15 16:21

24:14 26:15

27:13 27:19

35:15 35:21

35:23 35:24

40:14 40:17

43:11 44:4

45:9 45:13 47:14

47:15 47:18

47:25 48:6 48:19

49:4 53:19 53:21

53:24 54:7 54:21

54:22 55:8 55:18

56:1 56:19 56:21

56:22 56:24 57:1

57:2 57:6 57:7

57:7 57:9

57:13 57:23

57:23 64:21

64:25 72:17 73:2

73:11 73:17

73:21 73:23 74:7

74:13 75:13

75:14 79:22

80:17 81:19

81:24 82:3

82:5 82:7

82:12 83:6 83:25

84:4

site's 82:24

sitting 77:20

situation 13:12

26:25

six 86:5

size 12:12 15:7

slight 3:18

sludge 9:14

11:2 14:25 18:23

20:18 20:20

20:23 21:21

21:23 22:3 22:17

23:22 28:11 31:6

42:3 43:25 45:12

small 18:18

31:3 38:22 62:12

smaller 19:1

34:11 34:11

smallest 18:20

snap 31:15

SNCE 13:7

SNCEs 23:12

solids 13:4 19:15

solution 68:20

somebody 76:16

someone 53:22

somewhere 83:22

sorry 40:14

47:2 56:13 59:22

65:9 75:2 75:17

sort 29:7 29:8

37:21 40:21 43:9

61:8 74:18 78:9

sorts 49:2

source 12:22 24:5

32:14 50:9 52:23

57:25 68:23

76:22

sources 52:14

63:10 63:24

68:14 68:15 70:9

70:10 70:21 71:3

71:6 71:10 71:24

71:24 72:9

78:4 78:5 85:14

speak 4:6 5:8

10:11

SPEAKER 6:14

11:17

speakers 30:13
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 119

speaking 22:18

spec 51:9

special 36:8

48:12

species 74:6 76:6

76:9 76:13 76:20

76:23 76:24

76:25 79:23 80:9

80:12 80:16

80:19 80:24

82:13 82:23

82:23

specific 10:11

10:15 16:2

specifically 77:2

specify 60:3

spectrum 34:20

spent 9:2 17:19

spoke 17:4

73:16 73:22 79:1

stabilization

13:24

stakeholder

3:24 17:6

stakeholders 17:3

17:11 26:13 27:2

27:21 42:21

stakeholder's

11:19

stand 72:18

standard 31:5

standards 32:23

standpoint

26:24 28:3 42:20

44:8 45:6 53:7

58:4 61:23 71:18

72:4 79:5 84:20

Staples 4:12 4:12

start 9:22 10:1

10:2 40:17 57:20

65:16 65:18

started 77:19

82:16

starting 34:2

state 7:16

22:13 82:2

stated 63:16 69:8

statement 54:4

states 12:23

21:25 22:3 25:22

25:24 28:9 28:12

30:25 31:2 31:18

35:6 35:24 59:16

59:16 63:15

69:14

statute 59:22

60:2

stay 61:22

stays 81:24

step 72:8 86:14

steps 3:25

Steve 5:25

Stevens 5:9 5:9

storm 32:4

straightforward

19:11 72:21

stream 24:12 39:7

53:22

stress 31:11

struck 64:8

structure 81:14

struggling 29:14

student-worker

14:20

studies 32:23

77:6

subject 60:3

submitted 32:19

subset 62:12

62:14

substances

37:24 59:18

substantially

63:12 70:3

substantiate 51:6

suffer 19:5

sufficient

41:19 43:19 64:4

74:7 74:10

sufficiently

72:11

suggest 31:12

42:17 43:3

suggested 21:11

27:22 45:10 85:2

suggesting 52:17

suggestion 10:5

45:9 45:13

53:4 81:21

summary 15:24

support 12:9 33:4

74:3 85:20

supporting 11:15
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 120

supposed 55:4

sure 7:15 16:15

16:22 16:24

17:12 23:11 24:2

24:21 27:16

30:23 40:4 41:23

43:23 44:6 44:16

44:24 47:20 48:3

48:5 53:6 54:9

54:24 66:22

67:17 70:4 71:20

74:21 76:13

78:21 81:9

surface 48:20

55:14 55:24

73:16 74:24

78:17 78:23

surrogate 68:22

survey 14:21

14:25 39:5 68:7

suspended 13:4

switch 77:9

system 23:14 32:4

67:4

systems 32:2

73:25

T

table 4:5 77:20

80:5

tail 41:3

tail-end 41:7

talk 40:5 52:5

54:5 56:18

67:5 73:9 75:6

75:7 76:5 78:13

talked 38:2

56:9 78:7 80:9

talking 24:11

24:11 32:6 33:19

39:10 39:12

43:13 59:13

60:14 61:2 61:10

65:16 67:6

67:7 69:15 77:25

78:1 78:3 81:6

81:10 82:5

targeted 75:12

75:19

technical 16:18

33:1 42:24

teleconference

57:5

TELEPHONE 6:14

temperature 20:7

ten 44:14 67:2

67:4 68:10 69:25

tens 59:4 59:5

66:7 69:15

term 60:7

terms 3:18 4:3

7:10 28:2 30:5

30:10 30:20 36:5

37:25 44:22

44:22 47:12

57:11 57:13

57:15 57:17

57:18 57:19

62:16 63:19

64:10 64:12 67:7

73:19 73:22 74:5

74:9 74:10

80:3 81:13

84:6 84:7 84:8

84:12 85:6

86:2 86:15 86:17

86:22

tertiary 57:10

test 61:13

testing 59:24

61:4 61:5 62:2

62:7 64:21 64:24

thank 6:5 7:3

7:19 10:2

42:11 45:3 86:21

86:25

thanks 7:20 83:3

that...the 33:10

that...well 66:18

that's 7:25 11:24

12:14 15:20 16:8

16:12 16:14

17:24 19:11 21:1

21:5 22:12 22:17

24:16 25:12

25:15 25:19 26:7

27:18 31:10

32:12 32:22

33:12 33:23

35:12 36:7

36:8 36:10

37:4 38:1

40:17 41:3

41:8 43:18

44:1 44:3 44:3

44:4 45:2 45:8

46:6 46:6

46:18 48:8 49:21

51:13 51:21 52:2

53:10 53:21

55:11 56:2

56:4 59:2

59:24 61:10

61:10 61:20
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 121

62:10 62:14 63:6

65:6 68:16 70:23

71:4 72:14 72:24

72:25 73:19 75:8

76:25 79:7 81:16

85:23 85:24

that's...what

82:23

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themselves 4:5

7:2

theoretically

18:15

there's 9:19 9:23

13:6 14:14

15:2 21:9 22:2

22:25 23:5 23:15

26:25 28:20 29:4

29:5 37:3

47:15 49:13

49:17 49:19

49:25 51:16

51:23 51:24

58:21 60:19 61:3

61:16 62:4

66:4 68:6 68:9

68:11 69:2 71:14

72:6 75:19

76:1 79:20

83:1 86:7

they're 13:25

22:11 23:2 23:20

24:2 24:21 25:11

25:11 36:14 38:6

55:16 55:19 62:6

67:13 80:19 85:8

they've 21:2

25:10

Thomas 4:13

4:13 10:1

16:13 18:7 25:25

29:2 29:3

42:12 42:12 44:5

44:14 44:24 45:4

45:21 45:24 46:1

46:3 50:5 52:6

54:15 57:20

57:21 59:3 61:21

62:24 63:21 64:6

64:19 64:23 65:5

65:7 70:24 70:24

72:19 73:1 77:11

77:11 77:18

84:15 84:15

thought...I 58:8

thoughts 26:8

thousands 40:7

51:25 58:22 59:4

59:5 59:6

60:23 65:16 66:7

69:15

throughout 24:3

38:24 69:7 69:14

timeline 86:17

tired 85:1

to...actually

13:6

to...we 86:14

Tobias 5:18 5:18

today 3:12 4:2

7:25 9:21 45:6

45:17 71:17 78:6

84:13 86:2

86:8 86:19

today's 3:6 3:9

3:19 7:23 86:23

tool 24:16

tools 15:25 24:9

top 28:1 34:19

68:5

topic 57:3

topics 47:11

TOSCA 51:11 59:15

60:3 61:5 61:9

61:14

total 45:15 57:5

totally 29:1

touched 73:10

tough 66:16 67:16

towards 26:6 43:1

43:4

toxic 36:3

track 9:9

Tracy 5:19

tradition 61:9

61:13

traditionally

37:17

transcript 7:7

7:16 7:17 86:20

transport 36:6

treat 13:1

18:24 63:7

treating 52:2

58:18

treatment 8:20

9:8 11:2 11:6

12:23 13:2 13:25

14:5 18:22

19:3 19:7 20:8
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 122

20:13 21:7 21:15

21:18 23:19 25:8

25:15 31:6 39:11

39:13 40:7 40:16

42:4 47:14

50:8 50:15 50:17

50:18 51:20

51:21 52:18

52:20 52:21

52:24 58:25

58:25 63:7 68:19

69:17 70:13

71:20 73:24 78:2

78:2 83:8

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85:12

treatments 21:16

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37:13 49:5

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76:21 80:9 80:10

80:11 82:14

82:15

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try 18:2 21:16

26:21 49:1 58:11

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67:20 68:13

83:16

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25:6 25:15 29:18

31:14 32:8 38:23

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54:1 54:19 60:12

66:4 66:13 67:13

72:22 76:2

turn 7:4

type 12:17 14:5

15:17 18:12

20:13 21:7 25:15

31:5 31:23

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49:22 52:10

65:13 66:16

68:23

types 11:5 11:6

13:25 20:20 21:3

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77:14

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U

U.S 3:1 11:3

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ultimate 17:8

ultimately

16:14 72:2

uncertainty

10:8 10:14 10:16

11:10 12:16 20:4

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understand 11:9

19:17 19:22

24:25 25:1 28:13

28:21 31:9 31:14

34:8 36:12

37:8 37:20 38:23

40:11 41:11 44:3

44:25 46:16

49:24 50:2 51:10

51:20 52:1

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53:3 53:10 53:20

53:24 54:25

56:22 63:14

64:24 65:3

65:5 68:14 68:17

70:2 70:22 72:22

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76:22 78:9 78:22

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85:12

understanding

10:16 10:22

11:13 12:2 16:15

16:23 17:12

21:24 23:6 27:16

34:3 37:20 39:19

44:7 44:12

49:3 50:23 57:17

58:8 59:8

71:10 72:15

77:17 77:21

understood

36:19 48:5

52:9 58:20

undertake 61:11

underway 46:5

77:8

United 12:23

21:25 22:3 25:22

25:24 28:8 28:12

30:25 31:2 31:18

35:6 35:23 59:16

63:15 69:14

universe 59:9

unless 9:23 61:8
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 123

unquantifiable

70:16

unusual 36:7

41:20

updated 33:7

35:20

upon 39:19

39:20 39:25 40:6

41:3 73:10 82:24

upper 15:2 38:9

39:2 80:10

upper-left 39:9

upstream 24:4

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useful 29:16

29:20

usually 61:6

V

value 19:19 21:23

58:3 69:8 76:1

values 22:15

44:12

variabilities

19:23

variability

10:9 10:14 10:16

11:9 15:19

20:4 41:7

variable 33:12

variables 11:5

15:11 15:13 20:7

20:9

variance 41:1

41:3

variation 21:17

31:15

variations 15:14

variety 9:14 9:15

20:5 52:22

vast 30:25 39:1

verify 28:14

versus 19:24 32:3

33:17 33:20 43:8

66:12 67:14

71:24 72:24 78:4

view 40:19 54:1

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violations

23:15 23:17

vocabulary 76:14

volume 18:24 25:1

voluntary 77:8

W

Wacker 4:23

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32:5 33:2

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40:15 47:14

51:20 52:21

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19:9 19:10 19:14

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21:16 22:11

22:14 23:17

23:18 23:20 24:5

24:21 24:23 25:8

28:19 32:5

32:5 32:7 32:7

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40:7 40:15 47:14

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watersheds 20:3

20:5

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43:22 69:2

web 77:4 77:6

77:13 77:21 78:1

79:23 85:14
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 124

website 69:10

welcoming 3:5

we'll 9:21 21:7

41:14 44:15

46:10 46:19 47:9

48:3 48:11

82:8 83:2 86:18

well-operated

25:9

Wendy 5:20

we're 16:6 16:7

16:8 16:14

21:1 22:19

23:4 24:18 25:19

25:22 28:25

29:18 30:4 30:17

35:18 37:9 37:11

38:14 39:10

41:10 43:9 43:10

43:13 43:22

44:11 44:18

44:21 47:24

50:23 51:22 54:1

55:20 56:5 59:12

59:13 60:15 61:2

61:10 62:24 66:4

69:15 69:24

71:16 71:18

71:22 72:22 73:1

74:21 76:1 77:16

77:25 78:1

78:3 81:5 81:6

81:17 81:17 82:5

84:21 85:22

were...the 16:19

we've 9:2 9:6

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13:8 16:9

20:10 21:19

24:10 28:22 30:5

30:9 32:18 33:24

33:25 34:17 35:8

36:18 37:8

38:2 38:13 40:13

40:24 41:9 42:20

42:25 45:5

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72:20 72:21 77:5

84:23

whatever 42:1

where...your

63:14

WHEREUPON 44:17

87:1

whether 23:15

23:18 24:13

29:10 38:18

46:21 47:5 51:10

68:25 74:10

81:12 81:23

81:25

white 14:14 14:18

whole 22:25 26:20

35:17 43:7

59:9 64:11 67:10

67:19 71:14

71:18 77:24

85:15

who's 53:22

WICKER 6:15

Wilkinson 5:21

5:21

willing 37:9

wonderful 40:3

68:6

wondering 30:7

65:10 65:15

Woodburn 6:15

35:20

work 8:11 32:9

57:12 65:21 86:7

86:23

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working 86:9

works 8:20

world 15:23

35:9 36:17 36:22

worst 18:15

41:8 41:10

worst-case 22:9

22:11 26:22

33:17 33:20 35:5

35:13 37:18

37:24 38:4 38:10

38:12 38:14

39:12 40:5 42:15

43:8 43:20 44:11

worthwhile 46:21

written 30:23

wrong 28:23

Y

yet 10:21 29:17

you'll 22:14

39:10 83:15

you'll...with

58:12

yours 33:16

yourself 5:7

6:8 6:12
SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 125

you've 22:21

46:22 58:21

65:20 68:20

68:20 68:21

68:22 70:9 79:15

Yvette 5:15

Z

zero 39:7