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 25SILOXANES 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 BluestarSILOXANES 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 HouseSILOXANES 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 DeMurphySILOXANES 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 monitoringSILOXANES 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 fewSILOXANES 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 toSILOXANES 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 toSILOXANES 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 theSILOXANES 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 weSILOXANES 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, theSILOXANES 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 andSILOXANES 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 inSILOXANES 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 ofSILOXANES 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'tSILOXANES 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 selectionSILOXANES 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 thoughSILOXANES 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 theSILOXANES 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 onSILOXANES 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 excludeSILOXANES 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 onSILOXANES 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 toSILOXANES 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 weSILOXANES 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 theSILOXANES 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 isSILOXANES 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 incorporatedSILOXANES 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 justSILOXANES 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 toSILOXANES 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 thereSILOXANES 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 whichSILOXANES 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'mSILOXANES 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 forSILOXANES 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 toSILOXANES 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 theSILOXANES 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 hearingSILOXANES 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 hearSILOXANES 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 asSILOXANES 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'sSILOXANES 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 coupleSILOXANES 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 pointSILOXANES 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 dischargeSILOXANES 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 fromSILOXANES 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 ofSILOXANES 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 treatmentSILOXANES 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 toSILOXANES 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, couldSILOXANES 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'sSILOXANES 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 environmentalSILOXANES 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 aSILOXANES 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 someSILOXANES 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 atSILOXANES 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 toSILOXANES 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 riskSILOXANES 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 thinkSILOXANES 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 aboutSILOXANES 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 theSILOXANES 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 mightSILOXANES 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 notSILOXANES 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 siteSILOXANES 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 areSILOXANES 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

1 (WHEREUPON, the Meeting was concluded at 3:34 2 p.m.) 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 88

1 CAPTION 2 3 The foregoing matter was taken on the date, and at the 4 and place set out on the Title page hereof. 5 6 It was requested that the matter be taken by the 7 and that the same be reduced to typewritten form. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25SILOXANES ECA MEETING September 20, 2012 Case Ref # 16840-2 Page 89

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 90 1 12 9:13 16 9:13 10:13 10:15 10:19 40:13 40:17 1976 59:23 61:3

2 2008 14:21 14:25 2012 3:3 25 31:4 40:17

3 3,000 11:3 22:2 3:34 87:1

4 4,500 11:2 22:3 40 68:12

5 50 68:12

7 7 3:3 70,000 14:22 72-10 24:9 7Q-10 22:23 39:14

8 80 18:24

9 90 53:2

A a...this 7:13 ability15:8 able 10:10 29:19 42:8 51:5 62:15 66:17 66:20 70:22 79:14 absolutely 28:18 44:24 84:21 84:22 85:18 absorption 22:20 access 21:6 accessible 49:18 accomplish85:3 according82:1 account10:8 23:1 23:7 accounted18:6 accumulating 76:23 76:24 accumulation 76:15 accurate 7:16 7:18 accurately25:21 achieve 11:23 ACI 20:25 24:10 70:6 ACIs 20:16 across 18:25 31:18 51:25 act60:25 action 29:21 61:4 activated9:14 11:2 14:25 18:23 20:18 20:19 20:23 21:21 21:23 22:3 22:17 23:21 28:11 31:6 42:3 43:25 45:12 activity 11:15 actual 15:15 20:20 23:16 actually 13:12 13:25 14:20 14:23 14:24 15:11 22:23 24:3 24:10 24:12 24:22 29:20 38:7 38:22 39:7 42:5 43:15 52:19 65:12 65:12 66:8 67:24 68:10 69:9 70:11 70:14 74:9 77:5 81:13 82:16 add30:24 37:11 40:16 68:5 81:21 86:12 added35:17 58:3 adding40:18 70:5 addition 7:7 7:23 17:24 26:14 36:23 46:3 additional 12:11 19:3 19:12 27:9 28:13 58:1 address 18:3 29:12 addressed28:1 30:10 30:21SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 91

addresses 10:13 adds 22:24 adequate 46:17 59:17 adjourn 3:25 advantages 50:10 50:19 affect20:1 affiliation 4:6 afternoon 7:11 against40:8 agencies 36:18 85:21 agency8:14 10:7 14:4 17:8 17:13 26:18 37:15 37:23 40:1 45:16 46:10 52:7 52:9 57:6 57:8 57:17 60:25 62:10 72:11 73:19 77:13 84:24 85:19 85:23 85:24 agency's 10:5 45:8 53:3 84:8 agenda 3:9 3:18 9:21 ago 73:23 agreed 37:7 agreement 4:3 74:21 75:1 75:2 Aguilar 5:5 5:5 7:12 7:13 air 40:6 74:2 83:7 83:10 83:15 allow10:15 26:22 27:15 63:25 72:14 85:14 85:25 allowing45:7 allows 34:21 50:16 62:7 65:2 71:22 72:11 already12:15 15:22 15:25 20:24 21:2 28:10 28:14 34:17 35:18 37:10 38:25 39:4 40:1 58:6 68:8 68:11 77:5 altered

81:14 am 37:25 44:3 50:2 ambiguity 54:23 America 4:22 American 6:10 8:2 13:18 30:7 32:17 ammonia 13:4 among 10:20 49:19 57:4 57:15 71:6 amount8:24 10:22 19:9 58:14 amplify69:5 analysis 13:9 13:17 ancillary 29:3 Anderson 5:25 5:25 Andrea 6:25 anecdotal 27:14 animated84:19 answer 39:22 40:2 anti-trust49:19 anyone 7:1 9:24 anything47:1 50:1 50:22 82:6 86:12 anyway15:18 73:9 anywhere 35:8 apparently37:23 appears 38:22 applicable 73:25 applications 69:7 applies 63:17 apply 83:16 apportion 71:23 85:13 apportionment 78:3 appreciate 8:12 16:13 17:18 30:19 45:18 46:13 46:22 56:15 approach 8:25 35:13 37:18 37:19 37:24 38:4 39:19 44:7 appropriate 11:24 17:15 20:21 26:6 31:5 34:9 35:15 77:16SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 92

85:18 appropriately 25:11 area 31:12 31:18 57:14 65:21 77:3 areas 13:22 18:12 19:2 31:20 33:8 76:10 aren't30:14 31:1 43:24 60:17 argue 69:18 argument37:21 articulate 55:3 articulated

52:13 56:9 71:9 73:4 aspect11:22 11:25 15:17 21:24 aspects 24:22 assertion 32:15 assessing39:16 78:2 assessment 11:25 25:7 25:20 25:23 26:22 27:6 27:10 27:20 27:24 29:9 29:20 29:24 29:25 34:18 35:20 38:15 38:20 41:13 41:13 41:14 42:15 43:8 43:20 44:9 53:5 54:1 62:17 63:16 63:19 64:4 72:1 72:8 74:13 77:4 77:14 77:20 77:23 78:8 80:21 83:11 83:23 84:25 85:19 85:25 assessments 29:22 77:14 85:15 associated

10:9 10:23 19:23 25:23 34:19 35:10 41:7 45:12 46:4 52:20 58:7 71:5 association 13:13 assume 53:18 83:20 Asta 5:13 attorneys 51:15 AUDIENCE 45:2 46:25 75:17 AUGUST 3:3 authorities 37:9 authority 61:20 available 7:6 7:8 12:15 24:15 46:11 86:20 AVCIN 5:13 average 13:15 42:2

B B4 31:13 B5 31:13 back-calculation 50:17 balance 49:2 83:14 83:17 balancing32:11 Barkas 5:23 5:23 base 35:17 based8:10 9:4 11:3 15:16 19:18 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 bat24:17 bearing50:12 become 20:13 82:4 becomes 34:11 46:11 becoming49:18 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 19:21SILOXANES 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 best18:3 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 biggest21:5 bioaccumulation 77:17 biogas 67:25 68:2 biological 13:15 81:7 81:7 81:10 biology81:6 biosolid79:3 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 bit10:13 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 board36:23 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 branch5:13 24:11 break 20:11 44:15 44:20 61:8 breaking61:12 bridge 32:7 brief 8:9 44:17 44:20 briefing86:10 bring 48:16 brings 11:18 broader 62:9 brought57:3 Browning4:21 4:21 bucket74:19 build34:7 35:7 37:11 building36:16 built 35:17 bullet55:1 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 capability50:8 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 18:16SILOXANES 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 choosing18:11 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 cited32:20 claim 51:3 claimed

51:17 clarification 10:4 53:13 74:18 78:11 80:8 81:4 clarified48:5 clarify26:16 37:14 48:11 54:2 77:1 79:18 clarity40:3 41:21 51:4 54:19 55:12 55:22 class 25:15 Clean 14:21 39:5 68:7 cleaners 67:6 Cleaning6:10 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 clearly14:7 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 collect27:9 52:10 71:22 81:18 82:15 84:24 85:11 collecting 33:24 44:8 collection 32:4SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 95

combination 11:13 11:16 33:11 combined32:3 32:3 combining32:2 comes 11:22 33:22 38:18 comfortable 8:8 coming7:21 10:18 15:6 17:18 24:10 30:14 50:15 comment7:17 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 commented68:11 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 committed84:21 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 company53:22 compared19:2 76:8 comparison 24:4 compartment34:14 34:15 competition 49:20 complete 16:22 27:16 completed16:4 77:5 86:5 completely29:1 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 concerned22:19 49:22 concerning30:20 concerns 12:24 13:10 35:3 36:20 49:6 49:20 49:21 concluded37:5 87:1 conclusion 64:13 concrete 82:18 condition 19:25 81:15 conduct63:16 64:5 85:19 conducted34:17 conducting41:15 conference 12:6 16:17 16:18 30:14 confidence 12:5 30:1 35:4 35:7 confidentialSILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 96

28:16 50:3 50:12 51:3 conform

58:9 confused60:1 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 considering11:5 consistent 15:21 17:9 23:21 31:18 45:8 45:16 consistently 20:15 construct 63:22 Consultant5:20 consultations 9:6 consumer 71:2 71:3 71:24 78:5 contact8:13 containing56:23 content9:10 19:14 19:21 19:24 context27:5 56:20 78:8 contexts 49:23 continually23:3 continue 10:3 46:4 46:7 46:10 continuing35:18 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 converted14:25 corner 39:2 corners 23:4 Corning4:14 6:16 6:18 6:19 6:20 15:5 45:23 corporation 4:24 6:24 44:23 correct54:8 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 country18:25 20:1 20:5 38:25 51:25 65:12 66:4 66:8 70:14 country's 57:1 County6:21 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 creating39:16 creek 82:21 criteria 17:14 23:1 58:13 criterion 22:15 critical 11:21 12:5 12:10 18:11SILOXANES 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 David5:18 6:20 day 68:19 dealing38:19 46:18 decent24:1 decision 73:20 deferred61:5 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 depending11:1 29:10 depends 66:18 described10:18 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 designed17:25 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 41:12SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 98

41:13 71:10 83:13 developed8:10 16:17 27:12 59:17 developing28:2 74:13 development59:19 85:4 devil 68:13 dialed 3:4 didn't...but55:9 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 digest83:21 digester 83:19 diluted

33:6 dilution 19:9 24:8 39:6 39:14 68:20 direct3:15 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 discomfort45:12 discuss 3:10 7:25 discussed8:7 30:9 30:23 78:6 84:13 85:17 86:2 discussing3:6 discussion 3:20 8:25 12:9 21:20 29:5 29:6 30:18 30:20 47:13 47:23 57:4SILOXANES 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 District6:22 14:12 83:5 Division 3:8 docket7:7 7:9 8:3 86:20 document12:7 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 Dow4:14 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 drew33:10 drive 26:5 26:6 26:15 27:18 72:6 driving27:11 27:17 79:7 drop 55:22 66:25 dropping56:5 dry 67:6 due 20:2 DuMars 5:2 5:2 during8:4 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 easily23:17 easy 24:15 67:2 68:16 68:18 eating76:24 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 effluent15:15 15:21 28:19 48:20 48:21 48:25 53:16 53:17 54:5 54:7 55:8 55:23 56:6 63:10SILOXANES 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 effort9:10 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 element40:21 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 embarked85:2 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 environment11:12 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 equally68:11 errors 23:16 errs 49:25 especially26:8 30:9 65:15 essentially 26:4 26:6 43:22 85:3 established

29:17 et19:24 Etsu 45:25 evaluate 41:20 70:19 evaluation 77:22 evaluations 78:1 event 13:8 events 73:13 eventually22:8 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 evident82:4 evolution 32:7 77:24 evolved

71:16SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 101

Evonik 4:16 5:20 45:23 69:4 exact 82:7 exactly8:25 36:20 54:17 70:11 80:19 82:19 examination 22:12 examine 23:24 example 36:19 48:18 excellent 84:24 except28:19 53:25 exclude 26:25 exclusion 20:20 exclusive 39:21 exclusively 58:2 59:7 exercise 16:4 exercises 15:9 15:12 existing16:16 16:24 74:10 expanding85:5 expect15:10 experience 21:1 21:2 32:20 experiment34:7 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 expressed45:17 70:16 extensively64:14 extent26:12 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 fact21:12 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 fairly19:11 31:18 51:16 68:21 fashion 69:19 fate 36:6 81:5 favor 32:21 fed18:17 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 feeding80:19 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 77:15SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 102

FEMALE 11:17 final 56:17 finally9:19 finding32:10 65:18 66:16 fine 17:24 fine-tune 16:1 finished47:12 Finley30:12 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 fixed39:25 Flack 4:23 4:23 floor 79:13 84:10 flow9:8 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 flowing24:23 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 focusing19:6 30:4 30:8 30:17 47:24 62:25 folks 14:16 follow-up 25:25 50:5 food77:4 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 frankly49:10 69:13 frequently19:4 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 31:17SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 103

generate 35:18 46:9 generated36:22 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 getting11:22 16:12 37:22 43:10 49:14 86:11 given 25:2 70:11 gives 3:11 12:15 28:10 64:25 giving58:4 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 government36:18 Gram 6:25 6:25 great 52:23 greater 13:3 41:21 42:22 43:5 78:7 greatest8:24 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 guilty13:13 guys 10:12 27:15 42:18 59:21 59:24 60:23 84:25

H half 86:6 hand27:7 handed 36:25 handful 39:11

handpicking40:6 happened67:25 happens 47:9 49:12 hard43:14 65:23 66:21 harkening16:17 harm 37:6 63:4 haven't21:25 having10:21 21:17 28:11 35:15 45:12 54:3 74:2 80:20 health51:11 59:19 82:9 healthy82:1 hear 46:25 65:24 75:17 79:14 heard18:4 21:14 42:20 45:6 45:11 71:20 79:15 86:8 86:10 86:10 hearing44:25 48:1 71:17 76:1 Heckman 4:10 6:4 held60:14 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 27:5SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 104

helping11:9 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 highest18:16 Hiley 6:11 6:11 history8:18 23:12 hit32:12 Holiday61:22 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'd4:4 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 identifying43:1 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 impact19:10 20:8 31:23 49:11 64:13 68:17 impacted81:13 impacting82:10 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 importantly50:21 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 included19:4 20:10 26:12 48:6 77:4 77:10 includes 45:22 including23:4 31:4 52:22 57:2 inclusion 20:17 20:19 incorporate 21:17 incorporated 33:25 increased45:14 indeed 72:12 indicated12:12SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 105

20:16 indicative 63:2 indicator 68:2 68:22 indirect3:15 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 influent18:15 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 inherent12:25 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 intended53:5 intending25:20 25:22 intends 71:15 intent16:19 42:17 intentionally 42:25 interact32:19 interest19:12 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 interesting13:17SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 106

71:21 interests 10:20 interjections 9:24 intermittent 22:22 internally47:8 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 involved11:15 irrelevant38:5 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 judgment40:20 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 Keating5:16 5:16 Keira 5:17 Keller 4:10 6:3 Kent6:15 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 knew34:3 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 21:6SILOXANES 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 laid17:1 75:6 laid-out9:16 language 85:1 large 18:14 18:19 39:13 42:7 68:11 larger 62:14 largest14:22 last6:13 12:6 33:24 34:13 35:19 35:22 53:13 57:5 84:4 later 9:21 48:4 48:7 law61:20 lawyer 61:21 layer 22:25 23:5 lead15:13 29:24 74:13 leading19:13 least 17:5 27:2 37:17 40:22 46:17 64:9 leaves 54:7 left-hand39:2 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 likely13:6 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 load39:7 57:19 loading13:21 13:23 49:9 49:24 50:13 79:7 loadings 65:1 loads 58:5 locations 11:6 logic 53:20 59:2 long29:24 long-time 59:23 lot8:10 8:13 8:14 9:2 14:14 17:19 31:1 36:9 43:9 43:21 47:15 64:11 85:15SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 108

low13:21 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 lowest18:20 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 management29:6 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 matrix9:16 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 meandering82:21 meaning32:3 means 28:21 34:22 measure 55:10 measured81:8 measurement54:12 measures 29:12 Measury5:17 5:17 media 25:22 71:12 73:14 84:8 meet24:19 meeting3:2 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 69:8SILOXANES 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 memory52:8 53:1 mention 30:5 mentioned8:21 31:3 32:1 83:9 86:18 met86:4 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 Mihaich4:25 4:25 65:9 67:9 MIHIACH65:8 66:1 miles 82:20 millions 36:4 mind29:7 29:14 52:5 69:12 Minister 37:7 minor 3:18 75:9 minute 44:14 minutes 17:22 missing37:25 mix 45:9 45:16 46:17 mixtures 59:18 model 15:15 24:12 24:13 24:15 modeling15:9 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 monitored10:8 28:8 47:19 54:22 55:4 55:4 55:25 57:8 57:13 73:25 monitoring3:10 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 moving17:13 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 NACWA8:3 20:15 20:25 30:7 30:10 30:12 32:19 65:22 69:21 Nahn 5:14 narrow24:18 narrowed9:6 national 25:7 85:19 nature 20:3 nearly80:18 necessarily 26:2 27:14 31:16 50:6 50:11 50:14SILOXANES 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 negotiating59:13 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 nothing28:18 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 object75:21 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 ofthey9:14 Oh55:15 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 ongoing35:23 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 organized42:3 oriented40:10 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 27:6SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 111

ourselves 13:12 outfall 55:16 55:24 73:15 outfalls 55:13 outlying41:20 outside 4:11 overall 21:8 33:15 49:2 63:11 64:13 overbuilt 25:11 overview8:9

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 partitioning20:2 20:8 passed 59:23 past8:23 8:23 10:25 12:6 23:16 30:5 30:11 path 85:17 pathway83:11 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 perceived54:23 percent18:24 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 6:23SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 112

6:23 persistent36:3 person 31:20 Personal 4:17 perspectives 57:22 84:13 pertaining32:18 perturbations 13:15 phase 73:8 phenomenon 22:21 philosophically 53:25 philosophy38:18 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 pinpoint80:19 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 policy59:16 59:23 pollutants 13:11 52:22 polymer 71:4 pond13:25 pool 60:2 pools 58:20 poorest13:2 populate 35:5 39:9 populating34:24 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 post85:4 potential 19:18 38:24 56:25 potentially36:6 POTW3:20 9:8 10:5 13:21 18:14 18:17 18:18SILOXANES 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 predicted15:20 36:21 predicting36:15 preferentially 19:15 25:4 preliminary51:14 prepare 86:23 prepared12:8 33:1 73:1 85:24 preparing7:7 presence 35:10 74:8 present6:6 presented86:19 presumed62:1 pre-treatment 73:24 pretty8:22 9:16 22:8 40:20 52:19 72:21 72:25 previous 8:11 previously73:10 primarily 58:16 58:16 primary12:22 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 probability13:9 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 processing57:1 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 product57:19 products 4:18 31:13 56:23 71:3 program

16:9SILOXANES 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 proposed9:12 31:9 33:20 35:2 47:19 48:19 63:23 74:23 75:3 76:9 78:16 proposes 55:21 proposing54:21 76:8 proprietary50:11 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 provided8:15 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 providing85:22 public 7:6 7:9 publication 77:7 publicly 24:15 49:18 publicly-owned 8:20 purely37:22 purpose 63:6 76:25 purposes 27:10 30:2 pursue 47:6 pushed 61:6 putting74:18

Q quadrant38:10 quality22:11 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 raceway82:18 range 10:7 15:19 23:16 34:8 34:22 41:12 43:14 44:12 53:2 ranked 40:8 rarity14:1 rate 9:8 19:8SILOXANES 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 really3:12 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 reasoning17:13 receive 9:1 62:19 62:23 65:4 65:13 69:19 received8:2 30:6 63:10 63:24 receives 18:19 receiving9:9 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 reconvening44:19 record 7:14 25:2 recorded4:7 reference 81:15 referenced

30:18 refine 34:12 refinery 67:6 reflect80:24 refuse 75:16 regard 50:3 regarded51:8 regarding17:4 17:20 22:1 30:9 regardless 64:2 regional 8:14 22:13 82:2 regions 11:14 regularly 46:6 regulatory37:9 reject27:6 relate 53:20 related

8:6 8:7 52:18 71:1 relative 28:21 71:23 78:4 85:13 relatively39:13 relaxed

22:16 release 56:25 57:9 released83:22 releases 9:1 57:23 62:5 63:9 83:23 relegated31:2 relevant25:5 65:19 66:10 67:17 relied 64:18 rely 29:1 relying21:1 remarks 30:19SILOXANES 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 repeat6:12 65:24 replete 52:20 report83:21 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 representing4:20 4:21 12:20 represents 25:21 84:23 requests 21:17 requires 57:14 73:20 respect10:5 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 responded21:13 response 39:17 responses 11:19 responsibility 59:20 60:10 responsible 59:24 result18:15 31:16 results 41:20 41:24 rethinking45:19 review36:24 37:1 37:1 37:4 64:14 73:11 reviewed11:7 revised

3:10 7:24 8:10 revision 47:4 revisit53:16 54:6 83:2 revisited82:25 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 robust29:23 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 safety51:11 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 sampling3:23 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 saw17:5 scale 13:2SILOXANES 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 screening24:20 69:1 seated 8:11 second 14:19 18:22 28:1 29:4 55:1 section 59:15 61:5 61:13 sediment28:20 34:14 34:18 48:20 55:16 55:24 73:15 74:24 78:17 78:23 sedimentation 20:2 sediments 55:13 seeing37:16 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 select16:11 28:22 61:1 81:23 selected63:22 63:23 selection 12:25 17:2 17:4 17:7 20:12 22:25 27:17 42:25 58:13selfexplanatory8:22 senior 85:7 sense 19:5 43:15 49:1 49:12 58:4 66:13 69:23 85:20 sensitivity15:12 sent7:24 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 serving18:18 sets 74:13 settle 66:11 settling22:21 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 significant13:8 significantly 9:7 62:20 sign-up 7:13 Silicone 4:22SILOXANES 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 simply81:18 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 sitting77:20 situation 13:12 26:25 six 86:5 size 12:12 15:7 slight3:18 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 smallest18:20 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 sort29:7 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 30:13SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 119

speaking22:18 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 specify60:3 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 stand72:18 standard31:5 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 starting34:2 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 struggling29:14 student-worker 14:20 studies 32:23 77:6 subject60:3 submitted32:19 subset62:12 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 suggest31:12 42:17 43:3 suggested21:11 27:22 45:10 85:2 suggesting52:17 suggestion 10:5 45:9 45:13 53:4 81:21 summary15:24 support12:9 33:4 74:3 85:20 supporting11:15SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 120

supposed55:4 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 survey14:21 14:25 39:5 68:7 suspended13:4 switch77:9 system 23:14 32:4 67:4 systems 32:2 73:25

T table 4:5 77:20 80:5 tail 41:3 tail-end41:7 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

talking24:11 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 targeted75:12 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 test61:13 testing59:24 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 61:20SILOXANES 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 the...from

8:6 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 throughout24:3 38:24 69:7 69:14 timeline 86:17 tired85:1 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 TOSCA51:11 59:15 60:3 61:5 61:9 61:14 total 45:15 57:5 totally29:1 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 transcript7:7 7:16 7:17 86:20 transport 36:6 treat 13:1 18:24 63:7 treating52:2 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 20:8SILOXANES 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 83:14 83:16 85:12 treatments 21:16 Trent 4:10 37:13 49:5 Trent's 50:5 tried72:21 trophic 76:20 76:21 80:9 80:10 80:11 82:14 82:15 true 13:9 truly 51:19 70:22 try 18:2 21:16 26:21 49:1 58:11 59:10 65:20 67:20 68:13 83:16 trying11:23 16:8 25:6 25:15 29:18 31:14 32:8 38:23 44:6 47:7 50:23 51:19 53:7 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 46:9 49:14 49:17 49:22 52:10 65:13 66:16 68:23 types 11:5 11:6 13:25 20:20 21:3 21:15 21:15 21:18 49:20 50:7 typical 13:14 13:15 21:24 77:14 typically 13:3 13:21 77:13

U U.S 3:1 11:3 24:16 26:25 ultimate 17:8 ultimately 16:14 72:2 uncertainty 10:8 10:14 10:16 11:10 12:16 20:4 undergoing15:1 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 52:7 52:14 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 74:9 76:7 76:22 78:9 78:22 79:6 81:9 83:6 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 61:8SILOXANES 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-left39:9 upstream

24:4 24:14 39:8 68:3 useable 42:9 useful 29:16 29:20 usually61:6

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 variety9:14 9:15 20:5 52:22 vast30:25 39:1 verify28:14 versus 19:24 32:3 33:17 33:20 43:8 66:12 67:14 71:24 72:24 78:4 view40:19 54:1 59:14 59:22 violations 23:15 23:17 vocabulary76:14 volume 18:24 25:1 voluntary 77:8

W Wacker 4:23 6:23 45:25 walk 16:20 17:22 18:7 Ward4:8 7:4 10:18 11:6 37:13 46:25 54:18 60:1 61:23 64:8 75:4 86:12 wasn't10:14 43:3 47:9 waste 13:1 18:24 20:12 21:16 23:18 25:8 32:5 33:2 39:11 39:13 40:7 40:15 47:14 51:20 52:21 58:17 58:19 62:20 62:23 63:18 65:4 65:13 66:9 68:19 69:17 70:13 78:2 85:12 water 5:10 5:12 9:11 11:14 14:21 18:24 19:8 19:9 19:10 19:14 19:20 20:12 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 32:24 33:2 39:5 39:11 39:13 40:7 40:15 47:14 48:20 51:20 52:21 55:14 55:25 57:9 58:17 58:19 62:20 62:23 65:4 65:13 65:13 68:7 68:19 68:21 69:17 69:18 70:8 70:13 70:17 73:16 74:24 78:2 78:17 78:23 85:12 watersheds 20:3 20:5 ways 21:9 43:9 43:22 69:2 web 77:4 77:6 77:13 77:21 78:1 79:23 85:14SILOXANES ECA MEETING September 20, 2012 Case Ref #16840-2 Page 124

website 69:10 welcoming3:5 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 9:12 11:18 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 58:6 61:24 63:16 63:23 71:20 72:20 72:21 77:5 84:23 whatever 42:1 where...your 63:14 WHEREUPON44:17 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 willing37:9 wonderful 40:3 68:6 wondering30:7 65:10 65:15 Woodburn 6:15 35:20 work 8:11 32:9 57:12 65:21 86:7 86:23 worked 36:18 working86:9 works 8:20 world15:23 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 yet10:21 29:17 you'll 22:14 39:10 83:15 you'll...with 58:12 yours 33:16 yourself 5:7 6:8 6:12SILOXANES 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