U.S. ENVIRONMENTAL PROTECTION AGENCY

 SILOXANE TECHNICAL WORKING GROUP

 POTW Monitoring

 U.S. ENVIRONMENTAL PROTECTION AGENCY

 1201 CONSTITUTION AVENUE, NORTHWEST

 EAST BUILDING, ROOM 4238

 WASHINGTON, DC 20460

 JULY 24, 2012

 1:00 P.M.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 2

1 APPEARANCES

2 ON BEHALF OF THE EPA: (present in person)

3 Paul Lewis

4 Cathy Fehrenbacher

5 Jessica Bell

6 Karen Eisenreich

7 Todd Stedeford

8 David Tobias

9 Bob Jones

10 Ward Penberthy

11 Marcus Aguilar

12 Bradley Grams (on the phone)

13

14 ALSO PRESENT:

15 Paul DeLeo, American Cleaning Institute

16 Betsy Carlton, Bluestar Silicones

17 Ellen Mihaich, Bluestar Silicones

18 Jaeshin Kim, Dow Corning

19 Debra McNett, Dow Corning

20 Gary Kozerski, Dow Corning

21 Kathleen P. Plotzke, Dow Corning

22 David Powell, Dow Corning

23 Wendy Koch, Consultant to Evonik

24 Ray Hiley, Momentive Performance Materials

25 Kevin West, Momentive Performance Materials
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 3

1 APPEARANCES, CONTINUED

2 ALSO PRESENT:

3 Dr. Cynthia A Finley, NACWA

4 Patrick Griffith, NACWA member

5 Scott Belanger, Personal Care Products Council

6 Scott Dyer, Personal Care Products Council

7 Karluss Thomas, SEHSC

8 Tracy Guerrero, SEHSC

9 Hugh Flack, Wacker Chemical Corp.

10 Elaine Boyd, Wacker Chemical Corp.

11 Lisa Perricase, Wacker Chemical Corp.

12 Carl, SEHSC

13 Lisa Dumar, Momentive Performance Materials

14 Gene Browning, Shin-Etsu Silicones of America

15 Trent Keller, SEHSC

16

17

18

19

20

21

22

23

24

25
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 4

1 SILOXANE TECHNICAL WORKING GROUP

2 POTW MONITORING

3 MEETING

4 TUESDAY, JULY 24, 2012

5 MR. LEWIS: Good afternoon. This is Paul

6 Lewis from EPA, Office of Pollution Prevention and

7 Toxics. I want to welcome everyone to our

8 teleconference today, discussing siloxane informed

9 consent agreement, and focusing on the major factors

10 impacting environmental levels of siloxane and POTWs.

11 I want to at least begin by going around the

12 table here at EPA, the individuals present, and then I

13 have a role of others that have identified themselves

14 to participate in this meeting, and then we'll over the

15 charge, objectives and some other procedural matters

16 before we go into the meeting.

17 So, should we begin?

18 MS. FEHRENBACHER: Cathy Fehrenbacher with the

19 EPA.

20 MS. FOWLER: This is Jessica Fowler with EPA,

21 acting for the general council.

22 MS. EISENREICH: Karen Eisenreich, EPA.

23 MR. STEDEFORD: Todd Stedeford, EPA.

24 MR. TOBIAS: Davis Tobias, EPA.

25 MR. JONES: Robert Jones, EPA.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 5

1 MR. PENBERTHY: Ward Penberthy, EPA.

2 MR. AGUILAR: Marcus Aguilar, EPA.

3 MR. LEWIS: Great. Thank you. I'd like to

4 now go through a list of people that have registered to

5 attend this meeting or have asked to speak ... to

6 attend this meeting and then if there are others,

7 please identify yourself.

8 Paul DeLeo.

9 MR. DELEO: Present.

10 MR. LEWIS: Great. Betsy Carlton. Betsy?

11 MR. DELEO: She is here also.

12 MR. LEWIS: Okay. Great. Ellen from Bluestar.

13 MS. MIHAICH: Yes, Ellen Mihaich.

14 MR. LEWIS: Great. Thank you. Jaeshin Kim

15 from Dow.

16 MS. KIM: Yes, I'm here.

17 MR. LEWIS: Great. Gary from Dow.

18 MR. KOZERSKI: Yes, here.

19 MR. LEWIS: Debra McNett.

20 MS. KIM: I'm not sure if she's on yet.

21 MR. LEWIS: Okay. Well, I will wait.

22 Kathleen.

23 MS. KIM: Kathleen's here.

24 MR. LEWIS: Great. And David.

25 MS. KIM: David's here too.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 6

1 MR. LEWIS: Great. From Evonik, Russell.

2 Russell? No? Okay. And Wendy.

3 MS. KOCH: I'm on.

4 MR. LEWIS: Great. From Momentive, Ray Hiley.

5 MR. HILEY: I'm here.

6 MR. LEWIS: Great. Kristen Smith. Kevin

7 West.

8 MR. WEST: Here.

9 MR. LEWIS: Great. From NACWA, Cynthia

10 Finley.

11 DR. FINLEY: Here.

12 MR. LEWIS: Great. Patrick Griffith.

13 MR. GRIFFITH: Here.

14 MR. LEWIS: And David Rothbart. David?

15 MR. GRIFFITH: He's at another meeting.

16 MR. LEWIS: Okay. Thank you. From Personal

17 Care Products Council, John Krowka. John? No? Halya?

18 Halyna, Pardon me. Scott Belanger.

19 MR. BELANGER: Here.

20 MR. LEWIS: Great. And Scott Dyer.

21 MR. DYER: Here.

22 MR. LEWIS: And from SEHSC, Karluss.

23 MR. THOMAS: I'm here.

24 MR. LEWIS: Great. And Tracy.

25 MS. GUERRERO: Yes, I'm here.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 7

1 MR. LEWIS: And from Wacker Chemical, Hugh

2 Flack.

3 MR. FLACK: Yes, here.

4 MR. LEWIS: Great. Is there anyone that has

5 joined the call that has not identified themselves?

6 UNIDENTIFIED FEMALE: Yes.

7 MR. FLACK: From Visar [PH] Chem ... from

8 Visar Chemical, we also have Elaine Boyd and Lisa

9 Perricase.

10 MR. LEWIS: And Lisa ... how do you spell your

11 last name, Lisa?

12 MS. PERRICASE: P-E-R-R-I-C-A-S-E.

13 MR. LEWIS: Okay. Anyone else?

14 MS. MCNETT: From Dow ... from Dow Corning,

15 Debra McNett.

16 MR. STABLE: From SEHSC, Charles Stable.

17 MS. DUMAR: And from Momentive, Lisa Dumar.

18 MR. LEWIS: Okay.

19 MR. GRAMS: From EPA, Region 5, Brad Grams.

20 MR. LEWIS: Okay.

21 MR. BROWNING: From Shin-Etsu Silicones of

22 America, Gene Browning.

23 MR. DOYLE: Trent Doyle with Keller and

24 Heckman Agency.

25 MR. LEWIS: Anyone else? Okay. Hearing none,
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 8

1 I just want to go over a quick procedural matter. This

2 ... we have a transcript that will be prepared for this

3 meeting and we'll make that available in the docket

4 once we get the transcript back and make it available

5 for public inspection. So in terms of making sure we

6 have an accurate transcript, when a person is speaking,

7 please identify yourself by name. If you're not

8 speaking, if you can put your phone on mute so that we

9 can reduce the background noise. We will also have all

10 materials that were presented today available at

11 docket, including the agenda.

12 Before we go into the discussion, let me at

13 least provide some background in terms of our meeting.

14 You may recall we met on last month in terms of our

15 first meeting focusing on the siloxanes ECA, and we

16 agreed in terms of having a subsequent discussion

17 focusing on the factors in terms of D4 and D5 levels at

18 POTW sites. And basically, our objective today is to

19 build on the SEHSC proposal developing science-based,

20 rational proposal for monitoring of POTW sites, which

21 provides sufficient information and data on the

22 presence and concentrations of D4 and D5 in the

23 environment near POTWs, to support a national risk

24 assessment.

25 So that provides some context in terms of our
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 9

1 charge and our objective is a ... developing a sampling

2 strategy which should collect monitoring data that

3 scans a variety of POTWs that have attributes that

4 could be used to characterize the likely range of

5 siloxane environmental concentrations around those

6 POTWs.

7 So that's our objective for today in terms of

8 our call. Anyone have any questions before we go into

9 the discussion? Okay. Hearing none, Karluss, I want

10 to give you the opportunity to provide some remarks

11 about materials that we sent out and put it in context

12 and then we'll go into the EPA presentation.

13 MR. THOMAS: Okay. Thanks, Paul. I'd just

14 like to start by thanking you and EPA for organizing

15 the call. I guess I don't have anything substantive to

16 add at this point on the materials that were provided.

17 I think many of our questions and comments on the

18 material will probably come out during the discussion.

19 So if you guys are okay, I think we can kind of go

20 right into some of the things that we thought about, in

21 terms of the preparation of the proposal and

22 specifically, the number of sites that we could use for

23 the municipal wastewater treatment portion of the

24 proposal.

25 MR. LEWIS: Okay. Thank you, Karluss. Ward,
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 10

1 do you want to kick things off?

2 MR. PENBERTHY: Go ahead.

3 MR. LEWIS: Or, Cathy, do you want to begin

4 the discussion in terms of some of the factors?

5 MR. PENBERTHY: I think he just said? Didn't

6 he say he had something to say about ...

7 MR. LEWIS: Karluss, do you have something to

8 ... more to ...

9 MR. THOMAS: Yeah, I do. I kind of want to

10 start out with some of the thinking that went into the

11 wastewater treatment portion of the proposal, and in

12 particular, the number of sites that were selected.

13 And I just wanted to start back at the beginning in

14 terms of the initial goals that were laid out for the

15 program, and we highlighted these during the

16 presentation that we made at the initial negotiation

17 meeting. But I just want to remind folks that at the

18 outset, that the stated goal for the monitoring program

19 was really to provide additional information on the

20 presence and the concentration of D4 and D5 in the

21 environment and on sources of and pathways to the

22 environmental concentrations of D4 and D5.

23 So to do that, the conceptual site models

24 were developed to simulate the D4 and D5 releases from

25 wastewater treatment plants. And I think the
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 11

1 conceptual site models in particular were something

2 that a representative of EPA were very adamant that

3 should be developed prior to the development of a

4 sampling plant.

5 If you go back to the letter ... I think it

6 was dated September 19th of 2011, that was very

7 prominently mentioned as really the basis that would

8 initiate the development of the monitoring program.

9 So that's what we started out with. And our

10 view is that the empirical sampling data that would be

11 generated from the plants ... so that's not only the

12 municipal wastewater treatment sites, but also the

13 manufacturer, processor and formulator sites. That's

14 going to provide actual environmental exposure data to

15 not only validate the conceptual site models, but maybe

16 more importantly to facilitate the ecological risk

17 assessment for D4 and D5, and I think that's something

18 that we were ... that we saw in the additional document

19 that was sent around on yesterday by EPA, where in the

20 first couple of sentences, it laid out the goal which

21 was really to develop this national risk assessment for

22 D4 and D5. So it's our view, that the date that's

23 going to be generated from this will help to facilitate

24 that. But more specifically, sort of get into how we

25 arrived at the number of sites. I think folks are well
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 12

1 aware of the fact that we engaged the services of an

2 expert environmental engineering firm to assist us with

3 this matter, so to validate that the POTW conceptual

4 site models ... that consultant, ERM, developed a

5 procedure to determine the appropriate number of POWs

6 that should be sampled to validate the exposure and

7 distribution pathways for D4 and D5.

8 And it's also important to point out that

9 there really isn't a standard statistical guidance or

10 at least none that we're aware of, for determining the

11 number of sites that should be used to validate the

12 conceptual site model. So ERM used standard

13 statistical procedures to determine the number of sites

14 that would be necessary for validating the conceptual

15 site models.

16 I think it's also extremely important to

17 point out, that an EPA convention for environmental

18 statistical sampling was used for this procedure. So

19 using that, they came up with a recommendation for five

20 sites and those are the five sites we talked about in

21 the initial meeting, which would include two activated

22 sludge, one oxidated ditch, one lagoon and one

23 trickling filter site. Again, that would not only

24 verify the key sources, receptors and exposure

25 distribution pathways for D4 and D5, but also would
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 13

1 provide the actual environmental exposure data to

2 support the risk assessment.

3 So just kind of again, going back to the

4 original goal, the view is that these data would

5 provide sufficient information to develop the risk

6 assessments for D4 and D5 that we thought that were the

7 goals of the program.

8 So I'll stop there ... I will point out ...

9 I'm not going to go into the actual methodological

10 details that were used for that, but ERM is in the

11 process of developing a more complete report that's

12 going to have all that in it. We're going to make that

13 report available to the agency early next week. I'm

14 not a statistician, so I'm not really prepared to speak

15 to those details, but all of that will be in the report

16 that we provide early next week.

17 So I'll stop there and just ask if there are

18 any questions or comments.

19 MR. PENBERTHY: One comment, Karluss, this is

20 Ward Penberthy. We noticed that the ... well, it

21 appeared based on the factors used to pick the sites,

22 that you're getting out of pretty much ... well; our

23 impression was, you're trying to get at a worst case

24 scenario. Is that your approach? For instance, you

25 were using ...
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 14

1 MR. THOMAS: Well ...

2 MR. PENBERTHY: ... high pollution ... sorry

3 ... high population and low dilutions in most cases.

4 Is that really where you were going?

5 MR. THOMAS: I think that ... I think that's

6 fair to say that the site that would be selected, as

7 part of the proposal would target ... it would target

8 the high end of the releases.

9 MR. PENBERTHY: Okay. So I guess what we were

10 trying to get at, is a more of a sense of the range of

11 concentrations at various POTW configurations and how

12 the various factors ... which of the factors, like

13 population or dilution or the treatment types used, you

14 know which of those variables impact siloxane

15 concentrations and see if we could find, you know sort

16 of the relative contributions of those, in terms of not

17 getting a worst case risk assessment, but more of a

18 risk assessment that spans the ranges of

19 concentrations. I don't know if a central tendency

20 would make sense here for all POTWs, but at least you'd

21 somehow be able to understand the variability in

22 concentrations in the various media, from the various

23 kinds of POTWs and the attributes that they're dealing

24 with.

25 MS. PLOTZKE: Karluss, this is Kathy. I can
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 15

1 respond to that. So this is Kathy Plotzke from Dow

2 Corning. And I just wanted to emphasize, Ward, what

3 we've done really, as an industry over the last several

4 years is really just that already. So, we've been

5 building the database that we have on the monitoring

6 produced materials, as well as all of the models that

7 factor in those type of variables, from predicting what

8 you would see and then use the data stuff that were

9 generated even though it was generated in the past, and

10 what we've proposed here is really just going to

11 further validate that. So, it provides that ability to

12 do that with the modeling stuff that we've already

13 developed. For example, we've even modified a number

14 of wastewater treatment plant types of models to

15 incorporate various ones and look at those variables

16 already.

17 MR. PENBERTHY: Yeah, I mean I guess from your

18 proposal ...

19 MS. PLOTZKE: (Inaudible)

20 MR. PENBERTHY: I guess from ...

21 MS. PLOTZKE: Go ahead. Go ahead.

22 MR. PENBERTHY: I guess from your proposal we

23 couldn't figure out what data you're referring to and

24 are those test methods and sampling procedures going to

25 be the same as that we use in a uniform monitoring
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 16

1 program. So you know, there's no way for us to

2 understand how all that past work would integrate into

3 the five samples that you were going to take.

4 MS. PLOTZKE: And I think ... and it is ...

5 you're right ... it's hard to kind of lay that out in a

6 single proposal and a lot of it is in various stages of

7 being published and written out. But what I can tell

8 you is that the models that we have developed ... and

9 we've been using these models ... it's very similar to

10 what we did really for the D5 Board of Review that we

11 just went through with Canada. There's a whole data

12 set there that's available as well as we ... it's an

13 integrative process where we take that information and

14 recalculate and revalidate the models as we're

15 developing them. So, if that background is there, and

16 we can certainly help you know lay that out and help

17 you see what models we're using, and then the data

18 stuff that's already been generated can be plugged into

19 that, as well as the future data stuff that we're

20 proposing here and to then plug back in and really

21 check against those models.

22 MR. PENBERTHY: Well, I mean clearly we can

23 see agreement at least between what our thinking and

24 your proposal that population is a factor, activated

25 ... sorry ... the treatment type is a factor and the
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 17

1 dilution is a factor. So obviously, we both understand

2 that those are key variables to consider when

3 monitoring. I guess we have additional ones, which

4 aren't covered, we don't think at least in your

5 proposal, so I guess we see a lot of missing parts here

6 and we don't know how to fill them in.

7 MR. THOMAS: Yeah. And, Ward, it might be

8 helpful for me to just kind of walk through the factors

9 that were considered for the development of the

10 proposal, because I think you're right, at least from

11 what I saw in your document that was circulated

12 yesterday, there is a fair amount of agreement on the

13 factors. There may be one or two missing from what you

14 sent around yesterday and what we may have considered.

15 But I think the factors that we have certainly

16 considered include ones that you've eluded to, like the

17 treatment type, also the dilution of the receiving

18 water body, also the, you know, the population that the

19 treatment plant serves is clearly important.

20 Another factor that we were using was whether the POTW

21 received influence from a manufacturer, processor or

22 formulating facility. We thought that was an important

23 factor as well. So I think there may have been one or

24 two that were alluded to in what you sent around, like

25 suspended solids or organic content of the receiving
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 18

1 body. But I don't think there's anything that would

2 preclude, our using those as factors when we actually

3 select the five sites that would be focused on for

4 monitoring. So, I would say there's probably a lot of

5 agreement, between the factors that we previously

6 identified and those that you spoke about, and in fact,

7 the submissions that we provided to the agency at the

8 end of January. In the report from ERM, that was

9 included in that submission, I think on page 17, where

10 it starts talking about Section 5.2, the POTW

11 Potential Treatment Technology: That section

12 starts with a discussion of some of those factors. So,

13 my view is that there's a line of agreement here and I

14 don't think there's anything that would not allow us to

15 consider all of the factors that are laid out in that

16 document in the selection of the five sites in our

17 proposal.

18 MR. PENBERTHY: Yeah, and I mean I guess given

19 the number of independent variables, I don't know if

20 five sites is the right number. Well, clearly it isn't

21 in our point of view. And I guess our approach ...

22 what we're trying to do was focus at least on POTW work

23 that we're talking about now as monitoring that

24 wouldn't include POTWs with an industrial influent, and

25 because we were assuming that the other ... the
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 19

1 monitoring at manufacturing and formulating and

2 processing sites at other SEHSC sites would cover that.

3 So, we're trying to get the background of basically the

4 consumer or domestic contribution from consumer ...

5 from household products to POTWs and then figure out

6 how that source differentiates from the industrial ...

7 the various kinds of industrial sources. So ...

8 MR. DYER: I got a comment on that. This is

9 Scott Dyer with Proctor and Gamble, representing the

10 Personal Care Products Council. I've been involved in

11 a few large prioritization processes with two different

12 trade groups I think would be really helpful as we talk

13 about the differentiate ... you know, the sources of

14 siloxane. One is with the Water Environment Research

15 Foundation and the other one is with the American

16 Cleaning Institute. The clean water needs survey, EPA

17 has a field in it that indicates a percent industry,

18 and we've actually used that as a way of actually

19 trying to actually ... we're interested in trying to

20 understand down the drain consumer product or

21 ingredient discharge is actually a way to select sites.

22 And when you bring in a lot of industry into your

23 discharge, there's ... it doesn't indicate in that

24 particular survey what type of industry you're really

25 dealing with. So I think in the sampling design, if
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 20

1 you really want to understand the consumer use of

2 disposal, you're going to really want to have a play in

3 the sampling design where percent industry is basically

4 zero. And in that case, you're really going to have to

5 steer away from really large cities, but you can

6 actually get to fairly decent size cities with say, up

7 to say, maybe ten percent industry. And I think that

8 in doing that, what you're going to be able to do is

9 then basically bifurcate kind of an analysis, where you

10 can then ask the question again about how much of the

11 siloxanes are coming from consumer use, domestic use

12 versus that of others and then basically use some sort

13 of subtraction methodology.

14 So that ... I bring that to the table because

15 I think that's really, really important, and I think

16 also ... I looked at what was ... as a potential

17 standpoint, a selection process is that looking at the

18 quality of the effluent. As you probably are already

19 aware, the permit compliance system in the ACIs

20 databases, have a lot of other information I think that

21 declare what the water quality is of the effluent, and

22 I think that we probably should think about things

23 beyond total suspended solids in characterizing the

24 effluent. In particular, we would already suspect that

25 you know the siloxanes are going to reach the
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 21

1 environment through the suspended solids route, but

2 we're also going to want to also look at other things

3 like whether or not that wastewater treatment plant is

4 actually operating, as it should. Obviously, we're not

5 going to want to be selecting plants, that you know

6 have violations on a continual basis. And that's one

7 of the nice things about both these databases that

8 permit compliance systems in the ACIs, is that it does

9 have metrics in there, that indicates whether or not

10 there are compliance or violation issues on a

11 consistent basis and/or whether or not they're major

12 issues. So I think that you know if you take into

13 account just those two databases ... and then the other

14 thing is, is that clean water needs survey also has a

15 dilution factor, but that dilution factor does not

16 include upstream contributions, and that's another

17 thing you might want to be thinking about when you are

18 sampling for your siloxane.

19 And so for both the work program as well as

20 the ACI programs, we've used the I-stream data system

21 at the modeling water shed base ... the modeling system

22 for (Inaudible) in the 48 states. And it basically

23 models a consumer down-the-drain use of chemicals

24 through all roughly 10,000 wastewater treatment plants

25 in the country. And what that would enable you to do,
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 22

1 is actually be able to estimate the dilution factors

2 that include upstream contributions at both medium flow

3 and low flow. And so if you take into account, you

4 know the I-stream methodology, the clean water needs

5 survey and the permit compliance system, you're going

6 to basically have I think all the tools at your

7 disposal, that you can actually ask the question ...

8 and not just based on a power analysis, but also be

9 able to have a good understanding about how does a

10 suite of different wastewater treatment plants pertain

11 to an entire national distribution? And I think that

12 these are some of the things that you might want to

13 think about, you know as we start designing really that

14 program for the siloxane.

15 MR. PENBERTHY: Yeah. I mean I think you

16 just put into words a lot of what our intent was with

17 our proposal.

18 MR. THOMAS: Ward, let me ... this is Karluss

19 again. I just want to kind of take a quick step back

20 and, Scott, that was all certainly helpful from the

21 standpoint of you know how you might differentiate the

22 consumer versus the industrial sources. But again, if

23 we go back to the original goal, I think if what we're

24 trying to do is develop a risk assessment, I'm sure

25 there's a way to do that, but I'm not struggling with
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 23

1 how to do it. What I'm struggling with is whether

2 there is a need to do it, because when I read the paper

3 that was circulated yesterday, my view is that it

4 really represented a pretty substantial expansion of

5 the original goal for the program. So I'm not sure you

6 need to differentiate between consumers versus

7 industrial sources to generate empirical data to

8 facilitate a risk assessment. Again, there are data

9 available from other places and there has been risk

10 assessments that have already been done ... pretty

11 comprehensive ones I might also add. Canada has looked

12 at this and has done this, at least for D5, and they

13 found that there is no risk. So if the assessment is

14 done and there's no risk, it's not clear to me why

15 there needs to be substantial, additional data

16 generated to differentiate among consumer versus

17 industrial sources. So it might be helpful for me and

18 some of the other SEHSC members to hear from EPA, the

19 sort of reason for the expansion of the scope and to

20 what extent is that going to better inform the original

21 goal of the program, which was a risk assessment.

22 MR. PENBERTHY: Well, for a risk assessment,

23 you need ... you need data to do a risk assessment, and

24 you know, obviously, depending on the kinds of data you

25 collect, there's different kinds of risk assessments
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 24

1 you can generate and we're very intent on doing a risk

2 assessment that people are going to have a lot of faith

3 in and understand how the data was developed and why,

4 and have a data collection that does help us

5 differentiate from the sources and understand their

6 contributions and understands that various variables

7 ... well, particularly, the POTW phases, the impacts of

8 environmental loading and concentration. So, we're not

9 so much interested in modeling and all that, but we

10 want monitoring that gives a very clean understanding

11 of how risks could be estimated and dealt with. Cathy,

12 do you want to ...

13 MR. THOMAS: And ...

14 MR. PENBERTHY: ... add to that for me? Do

15 you have any ...

16 MS. FEHRENBACHER: I think you summed it up.

17 I think our ... perhaps there were differences in

18 expectations, but I think we've always been clear on

19 what our expectation was for the environmental

20 monitoring.

21 MR. THOMAS: And we certainly appreciate that

22 Cathy, and, Ward, I would absolutely agree that you are

23 going to need some hard empirical data to support a

24 risk assessment and I guess we all just sort of need to

25 be on ... have a good understanding of what the nature
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 25

1 of that data is. And we've always been clear that data

2 generated from this was going to help support a risk

3 assessment. But I guess some of the language in the

4 document from yesterday, in particular, the language

5 that talked about characterizing the ranges of

6 Siloxanes in environmental concentrations and

7 understanding how some of these factors are going to

8 impact or will contribute to the environmental

9 loadings. You know, that sounded a little bit like you

10 know a sensitivity analysis, which again sounded like

11 it might have been a little beyond, at least what we

12 had in mind for what we thought you meant by the

13 original scope. And certainly, our view is that the

14 data that's going to be generated from the five sites

15 ... and I think again, we do have some baseline

16 information for relative comparison like the 50 sites

17 that have already been monitored in Oregon, like the

18 nine sites that have been monitored in Canada. I do

19 think we have a framework for understanding what has

20 been seen in the past. So ... and given the fact that

21 you know what we have seen to date pretty strongly

22 shows at least, again, based on the work that was done

23 in Canada with Board of Review, that there is no risk.

24 We were sort of struggling with the need for all of

25 these additional data.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 26

1 MR. BELANGER: This is Scott Belanger from

2 Proctor and Gamble, and also working this with PCPC.

3 All right. I'm not so sure we're not all saying the

4 same thing and let me suggest why. Wastewater

5 treatment plants are engineered systems and as such

6 they ... if they are well operating, as Scott Dyer

7 alluded to, their performance is usually pretty well

8 founded for any given chemical in a fairly decent range

9 that one can handle from a modeling point of view. So

10 going in, if you desire to have a relatively generic

11 risk assessment, qualifying the treatment facilities by

12 excellent quality, permit compliance information,

13 industrial contribution. That helps you do that with

14 things like BOD and ammonia and some suspended solids

15 should be well within the operating parameters for

16 those plants. And then using modeling framework,

17 again, I'll just echo what Scott was saying. Using

18 modeling frameworks you can take that kind of

19 information, removal and concentration data, and blow

20 it wide open for the rest of the country, as those are

21 generic model inputs, and think about these things in

22 terms of wastewater treatment plant flow, population

23 served, dilution factors at specific sites, and such.

24 So I think the idea that you could do something like

25 that with five well-selected locations is something
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 27

1 that we have done with other compounds and certainly

2 can be accomplished to meet the broader needs I think.

3 MR. DYER: Yeah, this is the other Scott.

4 Just to add on top of that, it's ... it really comes

5 down to developing the framework from all the different

6 data systems that you have that give you the capability

7 to extrapolate back, so you really need to understand

8 the distribution of each one of these factors

9 simultaneously. And it makes me really wonder,

10 particularly after listening to Karluss, has the agency

11 already gone through a modeling exercise that really

12 ... that where there's a particular criteria that

13 you're trying to really look at where perhaps the true

14 goal is really trying to understand the proportion of

15 wastewater treatment that's exceeding a particular

16 criteria or do we have ... has the agency done any of

17 this kind of modeling? Because if it hasn't, maybe

18 that's the next step is to find out where are we at.

19 Give what we already know, and we already know a lot

20 based on the monitoring done in Canada and Oregon, and

21 now we've got these you know just different data

22 systems that are at our disposal. We could probably go

23 through you know a decent modeling exercise and see you

24 know what our chances are of finding siloxanes at

25 various different concentrations ... in discharge
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 28

1 conditions. Excuse me.

2 MR. PENBERTHY: And I think our analysis at

3 EPA is that our next step would be gathering monitoring

4 data and not modeling. And so I think our work and

5 designing how we're going to address D4 and D5 has

6 considered that. And so you know we're not interested

7 in a protracted academic exercise in modeling. What we

8 want is monitoring data.

9 MR. DELEO: Paul, this is Paul DeLeo at

10 American Cleaning Institute. I mean that was the ...

11 the question that was sort of in my head based on the

12 documents that were provided was what kind of

13 methodology is EPA going to be using to conduct these

14 risk assessments? And then what data do you have and

15 where is the data gap? And you know if someone is not

16 privy to the conversations between SEHSC and EPA, those

17 are the kind of questions that have been coming forward

18 and I was hoping maybe that was some of the material

19 you might provide publicly so we could consider those

20 ... that information.

21 MS. FEHRENBACHER: Paul, this is Cathy

22 Fehrenbacher, and we would use the traditional risk

23 assessment approaches. The data that we have available

24 to us, much of that has been provided either by the

25 SEHSC. We've also done our own literature search and
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 29

1 compiled information. So I think at this point, we've

2 evaluated all of the data and have used it to determine

3 the types of monitoring data that we need in order to

4 construct a risk assessment, a national risk

5 assessment, so that's where we are.

6 MR. BELANGER: I ... again, this is Scott

7 Belanger. Cathy, if you could clarify for me, it would

8 help. How is EPA thinking to take the ... what amounts

9 to the site-specific wastewater treatment plant ...

10 type of information to a national level assessment

11 then? I ... and I guess I'm coming back to ... this is

12 where modeling does come in.

13 MS. FEHRENBACHER: We are intending to collect

14 a reasonable amount of monitoring data, as Ward stated,

15 that would enable us to understand the range of

16 siloxane in environmental concentrations associated

17 with POTWs and that information would feed into an

18 exposure assessment that would then feed into a risk

19 assessment.

20 MR. BELANGER: Is that ... so ... Ward and

21 Cathy, I just had one additional question ... I mean

22 question to follow up on with Paul and what others have

23 said. I get the impression that you guys think that

24 there may be some shortcomings in the proposal, so it

25 would probably be helpful to kind of lay out for us so
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 30

1 that we're clear on why the proposal does not allow you

2 to collect the information that you think you're going

3 to need to support your risk assessment. And then

4 maybe more importantly you know help us get a sense for

5 what changes might you suggest that would allow you to

6 be able to get the information you would need.

7 MR. PENBERTHY: All right. Well, maybe we

8 should go through our paper that we sent around.

9 MR. BELANGER: Okay.

10 MS. FEHRENBACHER: Okay. So in terms of the

11 major factors impacting the environmental levels of

12 siloxanes at POTWs, the overall approach that the

13 agency has proposed is the ... first the identification

14 of major factors and then the use of an optimization

15 method, which would provide a scientific basis for a

16 monitoring program design. So the major factors that

17 we've identified include influent sources, and there we

18 believe that the major factor is population size. And

19 in terms of POTW characteristics, the major factor

20 would be treatment types. And I'm sorry; let me go

21 back to population size. For the de-optimization

22 method, we would propose high, medium and low, just

23 fairly broad categories of population size. And that

24 would provide information on how consumer and household

25 use of siloxanes contributes to POTW siloxane loadings,
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 31

1 again, setting aside the manufacture, processing and

2 formulators. Then in terms of POTW characteristics,

3 which is the next group of major factors, there would

4 be treatment types, and here we've looked at activated

5 sludge and then other secondary treatment types, which

6 could include trickling filter, oxidation ditches or

7 lagoons. And we would propose focusing on POTWs that

8 use secondary treatment because that would represent

9 the vast majority of POTWs across the nation.

10 A tertiary treatment is not included in our

11 proposal because it assumes that there would be very

12 low siloxane concentrations in affluent from facilities

13 using tertiary treatment. And then high total suspended

14 solids in the affluent we thought might be another

15 important factor because there are indications of high

16 total suspended solids in affluent from the POTW could

17 be important, as we do know that siloxanes partition to

18 solids. And then the last grouping of major factors

19 are the receiving body characteristics. And the first

20 of those factors is geography, so north and south would

21 be two factors to include, and there geography could be

22 important because colder temperatures would likely

23 decrease the amount of siloxanes that partition to air

24 and increase the amount that remains in the water and

25 reaches the sediment. And then the receiving body
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 32

1 flow; that could be grouped into three parameters;

2 lakes, low-flow streams and high-flow rivers.

3 Receiving body flow directly impacts the degree of

4 dilution and probably the turbulence. And both could

5 impact the partitioning behavior of siloxanes. And

6 then, finally, the organic content of the receiving

7 body and that could be apportioned between high and low

8 organic content, and that could increase the amount of

9 siloxanes that partition to the sediment.

10 So we believe that those are the major

11 factors and Again, as I think we all agree that the

12 most ... that there is agreement between the agency and

13 the SEHSC on the bulk of these factors. And I think

14 Karluss did say that the total suspended solids and the

15 organic content could be variables that could be

16 included as well.

17 MR. BELANGER: So from a process perspective,

18 Cathy, is it the suggestion that we would go back and

19 run this de-optimal design, because I thought I heard

20 Ward mention and I would strongly agree that the

21 academic the exercises may not be as helpful at this

22 point. I mean from my perspective, we have listed

23 experts in this area to help develop the proposal, and

24 I certainly believe we could incorporate all of the

25 factors that you mentioned in the five sites that would
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 33

1 be a part of our proposal. So I'm just trying to

2 understand what the path forward would be. I guess my

3 suggestion would be that we develop a site

4 identification program that's a little bit expanded

5 that includes all of the factors that you've mentioned.

6 Again, there were only one or two that weren't

7 considered in the development of our original proposal,

8 and have those be factors that are going to inform the

9 selection of the five sites that would form the basis

10 for the program.

11 MR. PENBERTHY: Right. You know, we're very

12 confident that five sites won't be enough, and we have

13 run a de-optimization tool on this and so ... and five

14 sites is just not going to be enough to differentiate

15 the various factors from each other. There's just

16 going to be too much multi-varia analysis that we won't

17 be able to tease out the sensitivities on each factor.

18 MS. PLOTZKE: Just one of the questions that I

19 have ... this is Kathleen Plotzke from Dow Corning ...

20 is it sounds like that ... I really actually think all

21 of the variables that you have listed here are

22 incorporated into the proposal that we've put forward

23 to you, as well as what we have the consultant looking

24 at as they're identifying the different sites. And I

25 guess the question is if what we're after is really a
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 34

1 risk assessment and in some of what you have here is

2 looking at the worst case scenario as well as what

3 we've identified, if you do a risk assessment on the

4 worst case scenario and there is no risk, what's the

5 value of understanding the range?

6 MR. PENBERTHY: The value of understanding the

7 range would be the value of understanding what are the

8 variables that contribute most to the higher loadings?

9 So to do that you have to have enough samples to be

10 able to independently evaluate each contributing

11 variable.

12 MS. PLOTZKE: I think a lot of the data that

13 we have generated to date and the knowledge around

14 these materials could probably ... does already tell

15 you how you can identify those worst case scenarios. I

16 mean so we talked about the fact that...

17 MR. PENBERTHY: Yeah. Like I said, we're not

18 interested in the worst case. We're more interested in

19 the distribution.

20 MS. PLOTZKE: But ...

21 MR. THOMAS: And this is the first and we ...

22 MS. PLOTZKE: No, I was just going to say If

23 you're interested in doing a risk assessment, and you

24 do a risk assessment on the worst case, and there is no

25 risk, what's the value of the rest of that information?
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 35

1 MR. PENBERTHY: I think we're talking past

2 each other. I think we've explained this, is we're not

3 really interested in the worst-case analysis. We're

4 interested in understanding the distribution.

5 MR. THOMAS: Ward, can you ...

6 MS. PLOTZKE: Perhaps maybe ... or maybe it

7 will help if you explain; how do you plan to use that

8 information then?

9 MS. FEHRENBACHER: There are different types

10 of exposure assessments and different types of risk

11 assessments. We would tend to use worst case

12 information in a screening level on exposure and risk

13 assessment, and we have determined that we need to do a

14 national risk assessment here, which is not a screening

15 level type of assessment, and that's why we need

16 monitoring data to form a more robust risk assessment.

17 MS. PLOTZKE: So is your intent to do a risk

18 characterization ratio or a probabilistic assessment?

19 MR. PENBERTHY: Could you explain that

20 question a little bit?

21 MS. PLOTZKE: Well, it would be deterministic

22 versus probabilistic, so specific points versus a

23 probabilistic assessment, which would get a broader

24 distribution and uncertainty factored in.

25 MR. PENBERTHY: Well, I mean it seems to me
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 36

1 five sites would have a maximum uncertainly associated

2 with it. So ... and that's just too much uncertainty

3 for us to bear.

4 MS. PLOTZKE: Well, I guess the five sites is

5 really a validation, but the probabilistic assessment

6 will factor in the uncertainty that you would see, and

7 then the five sites would validate that.

8 MR. PENBERTHY: Yeah. We're interested in

9 establishing the rates of environmental concentrations

10 around POTWs and what are the major factors that

11 contribute to the environmental concentrations. To do

12 that you have to have enough samples where you can

13 tease out the inter-relationships between the

14 variables, so that's where we are.

15 MR. DYER: This is Scott Dyer. So have you

16 already done then that power analysis based on the

17 number of influent, effluent and receiving water

18 characteristics to determine the number of sites that

19 you need for your risk assessment?

20 MR. PENBERTHY: Go ahead, Cathy.

21 MS. FEHRENBACHER: We have done some

22 preliminary calculations using the "D" optimization

23 approach, and I know some of you are familiar with that

24 approach. It's a fairly standard statistical approach

25 that's used. But considering all of the major factors,
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 37

1 we come up with 42 sites for monitoring.

2 MR. DYER: And those 42 sites then are ...

3 have already been compartmentalized to the different

4 blocks?

5 MR. PENBERTHY: We haven't ...

6 MS. FEHRENBACHER: Yes.

7 MR. PENBERTHY: Right. But we haven't done

8 any kind of work on site selection along ... or that

9 kind of thing. This is a theoretical analysis at this

10 point.

11 MR. DYER: And what ... and I'm just kind of

12 curious just to continue on there. Now, in that 42

13 sites, what are you exactly trying to determine there?

14 Is it as Cathy was getting to, you know; is it a

15 probability of exceeding a certain concentration? Is

16 it just to determine the mean variance of you know, of

17 different means of the different categories of the

18 different exposure scenarios that you have? I mean

19 what is it?

20 MS. FEHRENBACHER: It is the number that would

21 enable us, as Ward said, based on these major factors

22 to characterize the range of environmental

23 concentrations associated with the POTWs in a national

24 ... on a national basis. So we've identified the

25 factors that we believe are most important in impacting
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 38

1 the environmental concentrations of D4 and D5. And then

2 we've used this de-optimization approach, given the

3 number of municipal POTWs, and sort of bend those POTWs

4 based on these characteristics. And when you use that

5 optimization approach for these variables, for these

6 major factors, you come up with a number of 42 in order

7 to characterize the POTWs with those characteristics on

8 a national basis.

9 MR. BELANGER: Hello? This is Scott Belanger.

10 I'm having a ... to be honest, I'm having a little

11 difficulty wrapping my mind around that kind of

12 approach when we know a number of the variables are

13 more or less self-correlating. For example, population

14 served: We won't find trickling filters associated with

15 much more than a few thousand people, let alone a

16 medium size local. The same with lagoons or oxidation

17 ditches, which are ... tend to be centered around the

18 most rural parts of the country. And then there's this

19 other part of me thinking about the suspended solids

20 angle where we know high-suspended solids are

21 associated with poor treatment. And so if we're going

22 to try and span solids loading that way, we're

23 necessarily including situations where we have

24 inadequate treatment quality to begin with.

25 MR. PENBERTHY: You know I think when it comes
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 39

1 to the different treatment types in our proposal, I

2 think we were trying to you know accommodate as much as

3 we could at the SEHSC proposal, and they've mentioned

4 the treatment ... you know the lagoons and the

5 trickling filter and the oxidation types as treatment

6 types that they thought needed monitoring. So that's

7 why of course we included them.

8 MR. DYER: This is Scott again, Scott Dyer.

9 One of the experiences that we've had, if you think ...

10 I mean it makes sense, obviously, to look at to look at

11 treatment types, but some of the practicalities also

12 are still digging in ... it's not an academic exercise,

13 but you know what ... between the databases that are

14 already available, you can quickly understand you know

15 again whether or not a wastewater treatment plant is in

16 compliance. And then you can also see the treatment

17 trainings. And it is very, very frequent that

18 something that is needed as a particular type of

19 treatment is actually several different types of

20 treatment. And so I don't want to add a lot of

21 complexity, but this is also a piece of the reality

22 too. If we ... if you think about you know the

23 sampling regime is that an activated sludge plant

24 sitting by itself is actually a true rarity, because

25 they've got like sand filters on them you know and some
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 40

1 of them have trickling ... they're updated you know

2 trickling filters. So have ... when you've thought

3 about those things in coming up with the 42 sites ...

4 well, I guess did you think about some of these things

5 in the number of treatment trainings that there really

6 are out there in classifying the different types of

7 treatment?

8 MR. PENBERTHY: Yeah, I don't think we got to

9 that level of analysis and we realize that you know it

10 isn't an ideal design and there may be circumstances

11 where you don't actually have a physical facility that

12 represents the combination of factors that you're

13 looking for, for some of those 42 points.

14 MR. DYER: So that's one reason why ... I'm

15 thinking that you know, again, you're going to ... I

16 think in order to kind of accomplish I mean everybody's

17 goal of what you're trying to come up with, the number

18 of sites that really represent a national distribution,

19 there's this multi-suite you know layered analysis

20 that's going to have to take into account not just

21 what's going in but what's also coming out. So we need

22 to make sure that these plants are in compliance, we

23 need to make sure that the treatment training is

24 representative of something that is within the class of

25 the treatment that we're interested in protecting. And
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 41

1 so a lot of that you know is going to be ... it's

2 actually a lot of work to make sure that you know that

3 we get that national distribution, that we understand

4 you know about these particular sites that might come

5 up you know in our analysis are truly representative.

6 And then, obviously, then when you pack ... you know,

7 all of those have to be overlaid then with the

8 receiving water characteristics as well.

9 So I mentioned at the very, very beginning

10 you know, but I wanted to bring it back again. And I'm

11 not saying this is the only way, but you know with the

12 trace organics research program by the Water

13 Environment Research Foundation, we actually went

14 through this kind of program where we were asking the

15 question, "Where in the United States could trace

16 organics potentially be worthy of ... worthy of

17 increased investigation?" And that's very, very

18 similar to what you're really asking here. And so I

19 would like to submit that we ... if you could ... I

20 mean and I'm sure we can get Laura to send it to you.

21 Well, I'm sure I could send those, I'm the co-author.

22 And (Inaudible) actually was the consultants that

23 actually did the work ... is that this wasn't an

24 academic exercise and it's actually going to set up for

25 a very multi-million dollar suite of studies where
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 42

1 we're going to look at these kinds of things in a very,

2 very similar way in what you're interested in.

3 So I'm just bringing that to bare here

4 because I think that's really kind of the state of the

5 science, really, really where we're at right now in

6 monitoring, because it's really multi-faceted and it's

7 taking into account exactly the same kinds of interests

8 that you have.

9 MS. FEHRENBACHER: And, Scott, have they

10 selected the ... have they determined the number of

11 sites to be sampled?

12 MR. DYER: No, no. In fact ... but it's far

13 fewer than 42.

14 MR. PENBERTHY: Do you know the basis for how

15 they got too far fewer than 42?

16 MR. DYER: Well, it basically comes down to

17 economics to be honest, for that trace organics

18 program. You're looking at not just one chemical or

19 classic chemicals. You're looking at chemicals you know

20 maybe 50 to maybe even 100 different chemicals across

21 different chemical classes. So it's a big, huge

22 analytical exercise, and they're also looking at other

23 end points there in the environment.

24 MR. PENBERTHY: All right. But once you get

25 to the economics then they have to start sorting on the
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 43

1 science, so how did they go ... how did they do that?

2 MR. LEWIS: Let me just add to that in terms

3 of how they take into account the variables that we've

4 been talking about for the past hour.

5 MR. DYER: Well, I ... that's what I was

6 saying is that I think it would probably be more

7 fruitful if we could just send you the ... or have

8 Ward, send you the actual site selection processes that

9 were developed. And then that could be a part of ... a

10 major part of an inclusion for another piece of

11 dialogue that we could have. Again, they're using

12 tools that we've already talked about you know here in

13 McCall, but they're using them in a slightly different

14 way, but with pretty much the same kind of intent.

15 It's really trying to understand where can you get the

16 biggest bang for your dollar?

17 MR. PENBERTHY: And I'm trying to dope out a

18 specific proposal from you, vis-from what we have on

19 the table, so ...

20 MS. FEHRENBACHER: Yeah, and ...

21 MR. DYER: I couldn't hear you. I'm sorry.

22 MR. PENBERTHY: I'm trying to figure out how

23 your suggestions would impact our proposal at all. I

24 mean at this point, I mean, because that's what we're

25 talking about.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 44

1 MS. FEHRENBACHER: And, Scott, this is Cathy

2 Fehrenbacher. We've spent quite a bit of time over the

3 past several months with our Office of Water, and

4 they've done a fair amount of sampling and sampling

5 programs for POTWs. And we've also spoken with our

6 regions and other researchers and so ... and, believe

7 it or not, we are aware of economic considerations and

8 I think the proposal that we've developed is an attempt

9 to meet our need in a reasonable manner.

10 MR. THOMAS: Yeah, this is Karluss, and I'm

11 ... I just want to point out that we really developed

12 this proposal in good faith based on the articulated

13 goals for the program by EPA. And I really don't want

14 to understate that because I think that's really at the

15 core of how this was pulled together. And I really do

16 believe the proposal is really an unprecedented

17 commitment to environmental stewardship by our members.

18 And part of the process for gaining approval among the

19 senior management folks within these companies for this

20 proposal was really trying to balance that commitment

21 with the need for some business certainly associated

22 with the cost because obviously, we've done some

23 costing of this and we have some appreciation for the

24 associated cost and it's well into the seven figure

25 range. So the idea that that would be increased by a
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 45

1 factor of eight is going to be especially difficult to

2 get agreement from among the members. I won't

3 absolutely rule it out, but I just wanted our friends

4 at EPA to be well aware, that's going to be a very

5 challenging proposition in this environment where those

6 managers are also considering other challenges like

7 plant expansions, hiring new workers. So to spend that

8 kind of commitment on a program that other regulators

9 have already determined for material that has no risk

10 is going to be especially challenging.

11 So again, I'll go back to the original goal

12 as stated by EPA for the program in terms of doing a

13 national risk assessment for D4 and D5, the five sites

14 absolutely gives you the ability to do that. I think

15 Kathy Plotzke alluded to this earlier, if you're going

16 to do ... if you're going to identify the worst case,

17 that's certainly a reasonable basis to do a risk

18 assessment. That's certainly well within what EPA has

19 done in the past. If you find from that that there is

20 no risk, it's still not clear what the incremental

21 value is going to be for this data associated with the

22 range of siloxanes in the environment.

23 So I do want to put sort of a ... help us all

24 realize that there is some practical difficulties that

25 we're going to have to get around, and certainly our
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 46

1 interest is in absolutely continuing the good faith

2 negotiation, but we do have to you know sort of temper

3 you know our data needs in terms of what we want with

4 the practical realities of what we're asking for and

5 the incremental value of that additional data.

6 MR. PENBERTHY: Yeah, Karluss. I mean there's

7 a lot that we see good in your proposal. Obviously, we

8 have a lot of agreement on several of the factors. I

9 mean it just ... I think it gets down to the power of

10 the data that's developed. And I guess if you have any

11 particular commentary on our proposal that might get us

12 to a closer ground to what you've put together; I'd be

13 interested in hearing that.

14 MR. THOMAS: Well, would it be reasonable to

15 have you send us your proposal in written format so we

16 can kind of look at it and digest it, because I didn't

17 ... I heard the 42 sites and then I had to ... after I

18 finished picking my lips up off the floor, Cathy had

19 said a whole lot of other things. I want to make sure

20 we have a full understanding of everything that's in

21 the proposal so we can sort of take it back and give

22 full consideration to everything that's in it. Would

23 that be reasonable?

24 MR. PENBERTHY: I mean I think you have the

25 variables described in what we already said here,
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 47

1 right? And then it's ...

2 MR. TOBIAS: We could actually send the

3 commendations from the amendment.

4 MR. PENBERTHY: Go ahead.

5 MR. TOBIAS: We could actually send the

6 commendations that were generated from the run. I'm

7 sorry; this is David Tobias, for the transcriber. And

8 we could you know send ... I guess you're saying that

9 there wasn't sufficient description there. We could

10 you know address any comments that you generate after

11 the meeting to try to make sure you have the

12 information you need to expand ...

13 MR. THOMAS: Well, I mean ...

14 MR. TOBIAS: ... upon what we sent you.

15 MR. THOMAS: Well, and I mean that would be

16 helpful, David. But I think in addition to that, I

17 think linking the run that you did, that sort of

18 methodology, linking that with the goals that were

19 originally articulated in terms of developing the

20 national risk assessment and providing information on

21 the presence and concentration of D4 and D5 in the

22 environment. If you can link that run and the results

23 generated from that run with the original goals and

24 maybe more specifically, how that is going to provide

25 more value from a risk assessment perspective than
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 48

1 what's in our proposal, that would be helpful. Because

2 just having the results and all of the parameters and

3 the number of sites that give ... that you get from

4 that might be helpful, but more helpful is what you're

5 going to do with it, what's the incremental value

6 associated with it is relative to what we've already

7 put on the table. That would be extraordinarily

8 helpful. If other members have other things to add,

9 feel free.

10 MR. PENBERTHY: You know, Karluss, I think

11 we've just already talked about this where our intent

12 is to get the distribution and understand the impact of

13 the various contributing variables. So that's the

14 essence of the design. I don't know much more that we

15 could say beyond that.

16 MS. MIHAICH: Hi. This is Ellen Mahaich with

17 Bluestar Silicones. I am trying to go back to a

18 comment that Cathy had said earlier. If you could help

19 me understand this. So, Cathy Fehrenbacher had

20 commented on your screening level risk assessments, and

21 then there's more detailed risk assessments, and I

22 think that a graduate level of risk assessment versus

23 Duke University, based on EPA methodology and it's

24 generally been my understanding, that you start with a

25 screening level and typically that is based on a worst
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 49

1 case, a somewhat deterministic approach, and if you

2 have a problem then you refine, right? So I guess I go

3 back then to what Kathy Plotzke had asked too, but not

4 ... I'm having a little trouble thinking you know could

5 this not be something more if it's done in steps,

6 because if we were to go out ... and because the range

7 frankly is someplace from zero to that worst case,

8 right? And if we're proposing to look at the worst

9 case, when you would want to have more information is

10 when you have a problem at that worst case. And then

11 that would give ... and then at that point you would

12 use that range and the specific variables to try to

13 understand what could be tweaked or changed or what

14 needs to be modified in order to bring your exposure

15 below a level that would cause a risk.

16 So it might help here with any of the

17 explanation that you provide to us, why we wouldn't

18 start with the normal way that I think EPA usually does

19 this, which is a screening level, understanding worst

20 case, and if you have a problem at that point, then you

21 further refine.

22 MR. PENBERTHY: You know, I think we've done

23 that and we developed, like several of the other

24 chemicals in our existing chemical program, developed a

25 drafted action plan and it calls for a whole host of
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 50

1 things in draft form, risk management actions and

2 information gathering activities. And based on the

3 past positive experience we've had I think with Dow in

4 a product stewardship agreement, we thought it was very

5 likely that we could develop a cooperative effort with

6 SEHSC to develop the data to do a risk assessment

7 without or prior to getting everything activated

8 through an action plan. So we have done ...

9 MS. MIHAICH: And I ...

10 MR. PENBERTHY: Pardon?

11 MS. MIHAICH: And I don't think that there's

12 any ... I'm not asking a question. I mean I think

13 we've been very ... I think we've been very cooperative

14 in trying to do this. My question goes back to a

15 screening level worst case versus a more refined and

16 trying to ... again, as a risk assessor, I mean this is

17 what I do for a living ... in following your guidance,

18 your written guidance, why then we would do it

19 differently here.

20 MR. PENBERTHY: You know, I think we have done

21 that in-house and we are convinced that we could

22 develop a may present risk ... a reasonable risk

23 finding that would generate or would justify a test

24 rule. But we're not doing that because we hope to do

25 it through an ECA without going through that arduous
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 51

1 exercise.

2 MS. MIHAICH: And maybe that's the part Ward,

3 then that would be helpful. If you've done that

4 screening level risk assessment, if you can share that

5 with us, because I think, Well, We've done this a

6 number of times now differently and everything comes up

7 that there is no risk associated with it, and if in

8 fact this was the approach that EPA took back with D4

9 in the early 90s and came to that same conclusion, that

10 there was no risk and didn't go any further. We've

11 done it with EMS as well, working with EPA. So that's

12 all I think we're asking is that if there's something

13 different that you're seeing that we're not seeing,

14 help us understand that.

15 MR. PENBERTHY: Yeah, but what that would

16 involve with us releasing the action plan that we have

17 in draft form now; is that what you really want?

18 MS. MIHAICH: No, no. What I'm asking is if

19 you've done some risk characterization and ... or you

20 have some data that suggests there is a risk associated

21 with it, share that information with us, because we're

22 sharing everything with you and everything that we have

23 is saying there isn't any. If there's something we're

24 not aware of, help us understand that.

25 So I guess maybe just to summarize it is,
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 52

1 what data maybe that you have that already tells you in

2 this conceptual policy, is to help us understand that

3 value part of it that is required to go beyond that

4 screening level risk assessment. What value and what

5 data supports the need for that.

6 MR. PENBERTHY: Yeah, I think we've been

7 around that time and time again today, and maybe we

8 just can't find a way to move forward on this.

9 DR. FINLEY: This is Cynthia Finley at NACWA.

10 This has been an interesting discussion to listen to.

11 I ended up with a lot of the questions that I talked

12 about with some of our members. We were wondering what

13 the purpose of the risk assessment was as well. And I

14 think that I do agree with Karluss with SEHSC at this

15 point. If we're going to weigh in with an opinion of

16 the number of POTWs that should be monitored, it would

17 be really useful to see how EPA has come up with their

18 42 number. SEHSC has looked at the characteristics

19 that they had proposed for five, and so to get you know

20 an informed opinion on the number, I do ... I just need

21 to see a little more information from EPA and not just

22 those factors.

23 MR. PENBERTHY: Okay. I think we've already

24 said that we can share those statistical runs that were

25 generated ...
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 53

1 DR. FINELY: Oh.

2 MR. PENBERTHY: ... to develop the number.

3 DR. FINLEY: Yeah.

4 MR. PENBERTHY: That's not a problem.

5 DR. FINLEY: Yeah. And then ... and I also

6 agree ... I also have a background in risk assessment,

7 and I'm still not clear on ... seeing those runs may

8 help me get to this point, but I'm still not clear on

9 how that monitoring data will inform the risk

10 assessment itself. So, again, if you could provide

11 some more information about that, it would be helpful

12 to me.

13 MS. FEHRENBACHER: I ... this is Cathy

14 Fehrenbacker. I can explain how we would use the

15 information. We would use it to characterize, as I

16 said, environmental concentrations. So we would have

17 the monitoring data for the various POTWs that would

18 span the range that we've been discussing, and we would

19 have those characteristics, and we would use that

20 information to characterize environmental

21 concentrations of D4 and D5 associated with municipal

22 POTWs. That would be one section of the exposure

23 assessment. So we would have the quantitative

24 monitoring data and the characterization and we would

25 be able to say that we believe based on the analysis
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 54

1 that we've conducted that these concentrations span the

2 range of concentrations associated with these types of

3 POTWs in the U.S. So that would be one section of the

4 exposure assessment that would then be used in a

5 national risk assessment. So those of you who

6 understand risk assessments know how it would be

7 carried forward through the risk assessment.

8 MR. THOMAS: So Ward ... this is Karluss ...

9 just so you know everybody is clear on the next steps,

10 once EPA sends us the you know sort of the run and how

11 that feeds into the risk assessment ... and I

12 understand that we've talked about much of that today

13 ... but to the extent that you can you know help by

14 giving us you know some written ... giving that to us

15 in a written way, it gives us a better opportunity to

16 think about it more carefully. What were your thoughts

17 in terms of our getting you feedback and then next

18 steps in terms of the next face-to-face public meeting?

19 How do we move forward? Because, ultimately, I assume

20 we're going to have to provide comments or you know

21 make a counter-proposal based on your proposal. But

22 how do we ... what's the process for moving forward?

23 MR. PENBERTHY: Well, we can certainly bring

24 you know ... send, like I mentioned, send you the

25 statistical analysis that was used to develop the
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 55

1 number of 42. I mean I think you know, obviously,

2 there's two proposals on the table that ... and the

3 real question is, "Is there any way we can find some

4 clear, rational, science-based logic to find somewhere

5 that meets somewhere in between that makes sense?" I

6 don't know if that's possible. I mean I know we didn't

7 give you a whole lot of time to look at the factors

8 that we think are important, so you might have some

9 specific feedback on that. Obviously, if some of those

10 factors are less important than others, then that

11 impacts the statistical analysis.

12 So you know, it's ... and then the other

13 piece of this is we don't know, at least over on this

14 side of the telephone, your constraints on the economic

15 side.

16 So you know, we understand those are

17 practical Realities. So, obviously, there's boundaries

18 for everyone here. We have ... our boundaries are, we

19 have to have a data collection that makes sense where

20 we can do a risk assessment that people will generally

21 respect and thinks is rational. And you know, you have

22 business considerations and also I assume you wanted to

23 defend your product vigorously like you've been doing

24 today.

25 So I don't know, I guess that would be the
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 56

1 next step in my mind. Does anyone else have an idea

2 here?

3 MR. LEWIS: You also mentioned that there's an

4 ... an ERA report ... this is Paul Lewis ... Karluss,

5 that would be available next week.

6 MR. PENBERTHY: I don't think he heard you.

7 MR. BELANGER: I think another follow-up ...

8 now I'm speaking for ... this is Scott Belanger. I'm

9 speaking for Scott Dyer and Paul Deleo who had to go

10 off to another call. But there is this very solid

11 conceptual framework, which I would not characterize as

12 academic because it is used in ... very much in these

13 type situations that was developed under the work

14 torque program. And I think we could, with some of the

15 discussion that Scott Dyer provided, we could probably

16 provide some perspective on how we would typically

17 think about some of these factors like population

18 served and solids loading, dilution, stream flow and

19 such. We do do this very routinely and not only going

20 through the literature with this, but in many

21 situations we've presented similar kinds of information

22 to USCCA, Environment Canada or ECCA on these very same

23 kinds of things. So we would be very happy to you know

24 provide a clear articulation of how we worked through

25 that.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 57

1 MR. PENBERTHY: Would that be in the form of a

2 proposal for this?

3 MR. LEWIS: Well, I think that's something

4 that I certainly I would have to work with Karluss and

5 Cathy, but we certainly can provide some perspective on

6 why we believe the number of sampling sites can be

7 substantially more constrained.

8 MR. PENBERTHY: But if there's you know some

9 valid scientific arguments that allow for that kind of

10 reasoning that we can understand and that's not

11 targeted doing it in a worst case assessment, you know,

12 we'd want to consider that, clearly.

13 MR. BELANGER: Yeah, and that is consistent

14 with how we think about this kind of thing. So I think

15 we can provide some assistance to the discussion for

16 that.

17 DR. FINLEY: This is Cindy Finley at NACWA

18 again. I agree that that type of analysis, thinking

19 back on my work, would be really helpful. As one of

20 the Scotts was saying earlier. I'm sorry; I don't know

21 which one. Lagoons are going to be self-selecting when

22 you're considering population served. Most of them are

23 used for small communities. And you know those type of

24 treatment options are going to be determined by that

25 type of characteristic with the POTW as well. We also
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 58

1 have some comments on those factors in the document

2 that was sent out.

3 MR. PENBERTHY: We're all ears.

4 DR. FINLEY: So ...

5 MR. PENBERTHY: That would be interesting.

6 Could you go through them?

7 DR. FINLEY: We did, yes. And actually,

8 there's been a lot of talk about population served, but

9 we really felt that that is not necessarily one of the

10 most important factors. As somebody mentioned before,

11 if you're looking at the background concentration from

12 consumer products that are used versus from industries,

13 it would be more useful to look at the percentage of

14 the influent that comes from domestic sources versus

15 commercial industrial sources. If you have a lot of

16 commercial flow versus domestic flow, you need to the

17 deluding, what's coming from the domestic sources. So

18 that type of analysis would actually be more

19 informative, I think to population served unless you

20 think that areas with large populations for some reason

21 use more of these products per person. So ...

22 MR. PENBERTHY: So your suggest ...

23 DR. FINLEY: ... I think that would ...

24 MR. PENBERTHY: So your suggestion ... to be

25 clear, your suggestion would be to replace that
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 59

1 population size with percent industrial contribution?

2 DR. FINLEY: Yes.

3 MR. PENBERTHY: Okay. Do you have other

4 comments on our factors?

5 DR. FINLEY: Yeah. I'm wondering about

6 monitoring. There's influent monitoring that was

7 suggested, but, again, if you're looking at ... and I'm

8 still not clear whether you wanted to eliminate any

9 manufacturing facilities from POTWs that would be

10 monitored.

11 MR. PENBERTHY: Well, that was our ...

12 DR. FINLEY: (Inaudible)

13 MR. PENBERTHY: Yeah. Our theory was that the

14 industrial sources would be you know a separate issue

15 monitored separately. This is just to get the

16 background on the POTWs.

17 DR. FINLEY: Right. Okay. If that is done,

18 then perhaps this was not so important that we thought

19 that monitoring was in the collection system to

20 (Inaudible), rather than just influent to the POTW

21 could be useful in differentiating those different

22 types of influences. So again, that could help with

23 just normal commercial sources and not manufacturing as

24 well, depending on the percentage of commercial sources

25 that were contributing.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 60

1 MR. PENBERTHY: Okay.

2 DR. FINLEY: We also wondered (Inaudible),

3 you've got your characteristics here and we've talked a

4 lot about monitoring POTWs, but we were wondering if

5 septic tanks are being considered at all, because those

6 are used for 20 percent of wastewater treatment in the

7 U.S. and that is you know a fairly significant portion.

8 And we were just wondering how that factors into your

9 risk analysis in your consideration.

10 MR. PENBERTHY: Yeah, we didn't include that.

11 MR. GRIFFITH: How would there be a central

12 septic outflow is what I want to know.

13 DR. FINLEY: Looking at the tertiary treatment

14 ...

15 MR. GRIFFITH: I don't know how that ...

16 DR. FINELY: ... we thought that the

17 assumption for tertiary treatment would remove the

18 siloxanes may not be accurate. It really depends on

19 what kind of tertiary treatment is used. There's not

20 you know a single definition for the more advanced

21 treatment, so there may be cases where that assumption

22 is not true.

23 MR. PENBERTHY: Okay. Given the constraints

24 that we appear to be dealing with, is it ... how

25 important is monitoring around tertiary treatment,
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 61

1 relatively speaking?

2 DR. FINLEY: Yeah, I mean I would say if you

3 want to focus on secondary treatment, there is nothing

4 wrong with that, because that would represent the

5 majority of the POTWs. I think if you want to state it

6 like that, rather than stating the assumption that

7 tertiary takes care of it, that would just be a better

8 way to go.

9 MR. PENBERTHY: Okay. That's understood.

10 DR. FINLEY: Other than making that

11 potentially erroneous assumption.

12 MR. PENBERTHY: Okay. Good.

13 DR. FINLEY: And if there was a plan for a

14 tertiary treatment that sort of really fit well with

15 other characteristics you wanted to monitor, it may be

16 useful to do it. So you know I think you just have to

17 make a decision whether or not you want to totally

18 eliminate it or if you want to consider it ... consider

19 the other factors first. Let's see, what else?

20 MR. PENBERTHY: What did you ...

21 DR. FINLEY: I don't think there's been any

22 mention of monitoring the digest with Dow for the

23 treatment plant that used in our adjustment of the bio24 solids.

25 MR. PENBERTHY: Yeah, that was ...
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 62

1 DR. FINLEY: And I really ...

2 MR. PENBERTHY: Go ahead.

3 DR. FINLEY: Pardon?

4 MR. PENBERTHY: We did see that in the

5 original SEHSC proposal, so ...

6 DR. FINLEY: Okay. All right.

7 MR. PENBERTHY: ... that wasn't ...

8 DR. FINLEY: I think in the factors document

9 it wasn't mentioned. So ...

10 MR. PENBERTHY: Yeah, I mean ...

11 MS. FINLEY: ... I was just ...

12 MR. PENBERTHY: ... our concern is mostly with

13 eco-risk and so we didn't know how that related back to

14 that. But we understand there was interest posed on

15 your part and SEHSC in doing some work along those

16 lines, which we of course wouldn't object to.

17 DR. FINLEY: Right. And that's the part that

18 we wondered about too, that we didn't really think it

19 fit in with the environmental risk assessment. But in

20 order to complete a full map balance of what's

21 happening, it ... because we know most of these go to

22 the bio gaps anyway, it would seem important in order

23 to do a complete analysis of what's happening at the

24 POTW and where the siloxanes were going, it would seem

25 important to monitor the bio gaps as well.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 63

1 MR. GRIFFITH: Okay. Cynthia and everyone,

2 this is Patrick Griffith, LA County Sanitation

3 Districts. I think the importance of that may be

4 dictated by how you decide to approach your ultimate

5 risk assessment. I know looking at one of these ... I

6 think it's the site model, it looks like the exposed

7 ... the main exposure pathway is through the air,

8 however, in the sampling plant there was only plant

9 that was ... where the air was going to be sampled, so

10 it ... that kind of looked like to me that maybe ...

11 and I don't know how you envision your exposure

12 assessment to a curve. But a lot of people you know

13 look at influent minus off-flow and then everything

14 goes through the air and maybe you correct that with

15 the one treatment plant where you look at the airflow.

16 But to do a better analysis, I think you really need to

17 look at the ...

18 [OVERTALK]

19 MR. PENBERTHY: Okay. Cynthia, do you have

20 any comment on the suspended solids in the effluent as

21 a factor?

22 DR. FINLEY: Let me see. I'm trying to go

23 through my notes here. Well, again, as somebody

24 mentioned earlier, I think generally, the total of the

25 solids are going to be limited in the fact that you're
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 64

1 monitoring, but I do think that statement is true for

2 D4 and D5. That the siloxanes will partition to the

3 solids. So yeah ... so, I don't have a disagreement

4 there, but again, just wondering based on the utilities

5 that would be selected if they are well-performing

6 utilities that don't have violations, TSS might not be

7 a big factor.

8 MR. GRIFFITH: My guess is ... this is

9 Griffith again. I agree, especially if your focus is

10 secondary treatment facilities. I believe they all

11 have an effluent limitation of 20 milligrams per liter.

12 I don't know if that's really going to make much of an

13 impact.

14 MR. PENBERTHY: So what I'm hearing is that

15 you know if we ran the numbers and the statistics, if

16 we ... well, there's a couple of things here already

17 that ... you could probably drop off lagoons and you

18 probably could drop off the solids in the effluent,

19 right?

20 DR. FINLEY: Yeah. I'm not sure if you want

21 to completely drop off lagoons. Again, it kind of

22 depends on your purpose, but I think my point with the

23 lagoons is those are going to be naturally self24 selecting, small populations if you're just studying

25 populations, you know.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 65

1 But, TSS, yeah, I think that that one may ...

2 you may find that you could just drop back.

3 MR. PENERTHY: Okay. All right. What were

4 your thoughts on geography?

5 DR. FINLEY: Patrick, you had some thoughts

6 about that.

7 MR. GRIFFITH: You know, my thought, which I

8 don't think is going to carry much weight with half the

9 crowd on this phone, but what that may be, just stick

10 with the South, because that would have you know the

11 greatest tendency to drive materials into the air. But

12 it looks like some people want to see a distribution.

13 So ...

14 MR. TOBIAS: Could I ...

15 MR. GRIFFITH: ... that was my comment on that

16 ...

17 MR. PENBERTHY: Hold on, what?

18 MR. TOBIAS: Could I interrupt for just a

19 second? I think there's some confusion. This is a ...

20 we're doing an eco-exposure assessment, and for the air

21 releases returning and affecting water or sediment

22 levels, that's not a pathway we expect to be completed

23 for most sites in the United States. So you're right,

24 I mean there is a large amount of the mass that will go

25 to the air, but in terms of looking at the sediment or
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 66

1 the water, I ... that's why we didn't focus on that

2 compartment.

3 MR. GRIFFITH: Well, I think that ... you

4 know, whatever you decide. I think that has to go back

5 to your other discussions with the industry folks about

6 the scope of this project.

7 So you know I don't really have a comment on

8 the geography.

9 The one thing I thought of after Cynthia and

10 I had spoken earlier, I was wondering about the mode of

11 disinfection, because treatment plants have to

12 chemically disinfect their effluents. And they use

13 chlorination, hypochlorites, chloramine. Some use

14 ozone. Some use ultra-violent disinfection. That may

15 affect the effluent concentrations of siloxanes. I'm

16 not a Ph.D. chemist, I don't know, but it's something

17 to consider.

18 MR. PENBERTHY: Yeah, let us think about that.

19 What did you think about the organic content of the

20 body ... receiving body?

21 DR. FINLEY: We don't really have an opinion

22 on that. I could ... we could research that some more

23 with some other of our members that may have more

24 experience with that.

25 MR. PENBERTHY: Okay. Do you have any other
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 67

1 feedback on any of the ... does anyone else have any

2 feedback on our factors? Okay.

3 MR. FLACK: Yeah, this is Hugh Flack with

4 Wacker. Just a clarification ... [OVERTALK] ... when

5 we identify your site, will that be a single sampling

6 of that public site?

7 MR. PENBERTHY: Can you repeat that again?

8 MR. FLACK: All right. If I go to a POTW to

9 do a monitoring, would that be a single event to

10 monitor?

11 MR. PENBERTHY: You've moved on to a higher,

12 harder issue. We haven't really started to discuss

13 that. We were talking about just the kinds of sites we

14 needed to monitor for. Obviously, that's a question

15 we've had with the SEHSC proposal, "What does a

16 monitoring event really mean?" And I think we

17 mentioned that in our last meeting. I think we've

18 deferred that issue, for the moment anyway.

19 MR. FLACK: I'm just back to cost, because

20 we've all mentioned that money is a factor in our

21 decision-making process, and sampling once or sampling

22 quarterly or whatever might be, would certainly be a

23 major factor in our estimation.

24 MR. PENBERTHY: Yeah, I can understand that.

25 Another variable to optimizer.
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 68

1 DR. FINLEY: This is Cynthia Finley again. I

2 just thought I'd mention that several NACWA members

3 have mentioned that they would be more happy to service

4 the sampling sites. So ...

5 MR. PENBERTHY: Oh, great.

6 DR. FINLEY: ... when you get to the point of

7 looking for willing participants, I can throw a few

8 your way.

9 MR. PENBERTHY: Okay. Great. I know the

10 Office ... our Office of Water has offered to assist us

11 in identifying potential POTWs as well, with

12 (Inaudible).

13 MR. THOMAS: And we only have, well

14 functioning treatment plants, so, sorry.

15 DR. FINLEY: I think all of our members would

16 fall into that classification.

17 MR. PENBERTHY: That's good to know.

18 MR. LEWIS: That's good to know, yeah.

19 DR. FINLEY: Yeah.

20 MR. PENBERTHY: Okay. So where are we on our

21 agenda here?

22 MR. LEWIS: Well, we went through discussion

23 of my proposal. I think in this stage our next step is

24 to decide how we want to proceed. Karluss, you heard

25 in terms of discussion terms of the variables and terms
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 69

1 of what our thoughts are of what the proper number of

2 sites ... you mentioned that you need to get ... talk

3 to your leadership and your membership. Can you get

4 back to us in a week in terms of your response?

5 MR. THOMAS: Well, I can certainly get back to

6 you in a week on the justification for the five sites

7 in terms of the detailed rationale. With respect to

8 whether I can get sufficient feedback to give you some

9 understanding of whether we can agree to what EPA has

10 proposed, I couldn't do that in a week. We would need

11 you know more time for that.

12 MR. LEWIS: How much time are we talking

13 about?

14 MR. THOMAS: Well, I mean I need to ... give

15 me a couple of weeks or so to get back to you on that.

16 I really need to get a whole lot of input ...

17 MR. LEWIS: Sure.

18 MR. THOMAS: ... before I can answer that

19 question, because many of the folks that ultimately

20 make those decisions aren't on the call today because

21 those are sort of senior management folks at some of

22 the companies.

23 MR. PENBERTHY: Okay. So we'll ...

24 MS. MIHAICH: But on that, I'm sorry, can I

25 just get a clarification. This is Ellen Mihaich again
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 70

1 from Bluestar. So, but aren't we expecting some pieces

2 of information from EPA?

3 MR. PENBERTHY: Yes, we moved to send those

4 ...

5 MS. MIHAICH: Because we certainly couldn't go

6 back to our management and ask for permission unless we

7 have a little more information.

8 MR. PENBERTHY: Right. We'll send you

9 something either later today or tomorrow, and ...

10 MS. MIHAICH: Okay.

11 MR. PENBERTHY: And I guess, you know, I guess

12 feedback on you know what we've talked about today,

13 feedback on the optimization analysis, feedback on the

14 various major factors and which ones are the most

15 important. You know there's ways you can get at that

16 number I think. And so your thoughts along those lines

17 that ... and hopefully, accompanied with information

18 that we can take to our management saying, "This makes

19 sense." You know that's really, where we are. We have

20 sort of the same problem you have, you know.

21 MR. THOMAS: Right. And we're going to get

22 you that detailed report that lays out the rationale

23 for our site selection early next week, and if you

24 could get something back to us in that same time

25 period, that would be great. And I guess with respect
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 71

1 to you know feedback on ... feedback from us on your

2 proposal, would that be something that you would expect

3 would be done as part of the next public negotiating

4 meeting where we could kind of formally provide that

5 feedback? I'm just wondering if ... in terms of

6 timing, does that work for you in terms of ...

7 MR. PENBERTHY: Well, we're ...

8 MR. THOMAS: ... getting that feedback?

9 MR. PENBERHTY: You know, we're getting a lot

10 of pressure on the time because you know ... you know,

11 maybe this is the major issue, but I think there's

12 other issues we're going to have to deal with along the

13 way as well. So if we could keep this moving along at

14 a brisk, regular pace and you know how long ... on the

15 feedback on our proposal, is that something that could

16 be developed in you know ... in the period of a week,

17 and maybe have another call like this?

18 MR. THOMAS: I think we can certainly do it in

19 time for another call like this. I certainly ... how

20 about the end of next week, because I'm ... you know, I

21 don't know what folks' travel schedules are. That's

22 the only hesitation I have. We're certainly committed

23 to getting it to you as soon as we can. I just don't

24 want to over-commit and under-deliver.

25 MR. PENBERTHY: So we're talking ...
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 72

1 MR. THOMAS: I think we can get it back to you

2 by the end of next week if that works.

3 MR. PENBERTHY: So could we have a call on

4 Thursday afternoon?

5 MR. THOMAS: Thursday afternoon, what date?

6 MR. PENBERTHY: That would be ... it's the

7 24th today, so that would be ...

8 MR. LEWIS: So that would be like August 2nd.

9 MR. PENBERTHY: August 2nd.

10 MR. THOMAS: Yeah, that would ... that would

11 work for me.

12 MR. PENBERTHY: Okay. We're checking

13 schedules here.

14 MR. AGUILAR: The other thing, it's going to

15 take us a little bit of time to schedule another court

16 reporter if we have to.

17 MR. PENBERTHY: We can do that.

18 MR. AGUILAR: We're not going to do that?

19 MR. PENBERTHY: Okay. So August 2nd.

20 MS. MIHAICH: Just clarifying, Karluss, are

21 you talking about a call or are you talking about just

22 providing feedback by that date and time?

23 MR. PENBERTHY: I think we're talking about a

24 call where we discuss feedback. If we could get the

25 feedback you know in a written email or something
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 73

1 before that, that would help us, but you know we're

2 just trying to keep this moving. I mean you know and

3 if ...

4 MR. MAIT: Karluss, this is Russell Mait from

5 Evonik. I'm a little hesitant to commit to getting

6 feedback at the same time we're having a call. I think

7 it's important to have all the member companies at

8 least on the same page before we have another call.

9 MR. THOMAS: Okay. So would pushing back the

10 call a week make more sense?

11 MR. PENBERTHY: No. See, we're ...

12 MR. MAIT: I mean from my ... hey, Karluss,

13 from my point of view, I'd rather have getting the

14 written feedback to the agency by next week and then

15 have the call subsequent. That way everybody has a

16 chance to read what our response was.

17 MR. PENBERTHY: Okay. So then the call on the

18 6th or the 7th; is that possible?

19 MR. THOMAS: That would work for me. The 7th

20 would be better than the 6th.

21 MR. PENBERTHY: Okay. Well, let's target for

22 that. Okay. So we'll send you ... I guess Marcus will

23 email you all our contacts here, the background on our

24 analysis. Karluss, if you could email Paul and I and

25 Cathy and Marcus, then we're sure to get it and then
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 74

1 we'll send that out to our group as well, the whole

2 group.

3 MR. THOMAS: Okay.

4 MR. PENBERTHY: Then I think what I heard is

5 next week we would get some written feedback from SEHSC

6 on our proposal, and then we'd have a call on the

7 afternoon of August 7th.

8 MR. THOMAS: Yes. Does that work for the

9 SEHSC folks on the call?

10 MR. LEWIS: Good for me, Karluss.

11 MS. FEHRENBACHER: Same here, Cathy.

12 UNIDENTIFIED MALE: Yeah, good for us.

13 UNIDENTIFIED MALE: Afternoon is good.

14 MR. DYER: Same here. This is Scott.

15 DR. FINLEY: Yes, that works.

16 UNIDENTIFIED MALE: Okay for Sinitsu.

17 MR. PENBERTHY: Okay. So I think we've got a

18 quorum for that. So ...

19 MR. LEWIS: Okay. This is Paul Lewis. Any

20 other matters to discuss? We have two deliverables

21 coming up ... two deadlines in this case; August 2nd

22 and August 7th.

23 MR. THOMAS: Right. That works and, Ward, in

24 with respect to the timing, and I'm sensitive to the

25 need to push things forward as well; you mentioned that
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 75

1 there are some other things that you guys ... or you

2 suggested there were some other things that you guys

3 have in mind that we're going to need to discuss. It

4 would be helpful for us to get some sense for what

5 those things are as well.

6 MR. PENBERTHY: Sure.

7 MR. THOMAS: So we can already start thinking

8 about them and getting prepared for those. That would

9 be helpful.

10 MR. PENBERTHY: Right. Three things come

11 quickly to mind, is how to deal with the industrial

12 components, the manufacturing and the formulating and

13 processing facilities, and their associated treatment.

14 Then we had the ... I think there were some differences

15 between your proposal and our proposal on the media,

16 maybe minor differences. The media sampled. We need

17 to come to an agreement on the test guidelines,

18 although I don't think that would be such a difficult

19 issue. And then I think probably the most complex

20 thing is to somehow develop an approach for dealing

21 with the biota aspect of any kind of monitoring plan.

22 MR. THOMAS: Yeah, and I guess in terms of the

23 industrial component, when you say, "How to deal with

24 that," what specifically do you mean?

25 MR. PENBERTHY: Well, like I said you know in
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 76

1 our proposal that we talked today and presented to you,

2 our ... we saw this as two pieces. Monitoring around

3 SEHSC industrial facilities and manufacturers and the

4 formulators and processors as a separate issue from the

5 domestic or consumer contribution in POTWs. And so you

6 know we think they're separable components of a

7 monitoring program, and so that was our intent. We

8 were trying to get sort of the consumer domestic

9 background in our POTW analysis. And we understand

10 that, I think you have what, 13 SEHSC sites, and some

11 of those may be less deserving of monitoring than

12 others. I think one ... at least one doesn't have a

13 water release to it, I think. I'm not sure. But those

14 kind ... and maybe it's two, but things like along

15 those lines. But I mean I think there are manageable

16 issues to discuss along those factors.

17 MR. THOMAS: Okay. It would ... I mean if

18 there are ... if there are specific concerns that you

19 are comfortable sharing those concerns with us, that

20 would be helpful. So if there are you know specific

21 modifications that you think might be appropriate, as

22 is the case that we've been talking about today with

23 the POW ... POTW component of the program you know any

24 guidance or any you know written comments or

25 suggestions or just some you know laying out your
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 77

1 concerns in advance with those elements; the industrial

2 component, the biotic, the biota testing portion, any

3 of the testing guidelines, to the extent that you're

4 willing or comfortable with giving us some of your

5 thoughts on what the specific concerns are. That would

6 be extremely helpful in terms of moving this forward.

7 MR. PENBERTHY: Okay. So why don't I try to

8 organize a proposal around the manufacturing and

9 formulating and processing sites for our call in a

10 couple of weeks and we'll get that to you.

11 MR. THOMAS: Okay.

12 MR. LEWIS: Anything else to discuss?

13 MR. PENBERTHY: Nothing else from me, Paul.

14 MR. LEWIS: Okay. Well, thank you all. Ward,

15 Cathy.

16 MR. PENBERTHY: Thank you.

17 MS. FEHRENBACHER: Thank you.

18 MR. LEWIS: Thank you all.

19 MR. THOMAS: All right. Thanks.

20 MR. PENBERTHY: All right. Bye-bye.

21 (WHEREUPON, the meeting was concluded.)

22

23

24

25
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 78

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

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POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 79

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3

4

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POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 80

1

10,000 21:24

100 42:20

13 76:10

17 18:9

19th 11:6

2

20 60:6 64:11

2011 11:6

2012 4:4

24 4:4

24th 72:7

2nd 72:8 72:9

72:19 74:21

4

42 37:1 37:2

37:12 38:6

40:3 40:13 42:13

42:15 46:17

52:18 55:1

48 21:22

5

5 7:19

5.2 18:10

50 25:16 42:20

6

6th 73:18 73:20

7

7th 73:18 73:19

74:7 74:22

9

90s 51:9

A

ability 15:11

45:14

able 14:21 20:8

22:1 22:9 30:6

33:17 34:10

53:25

absolutely

24:22 45:3 45:14

46:1

academic 28:7

32:21 39:12

41:24 56:12

accommodate 39:2

accompanied 70:17

accomplish 40:16

accomplished 27:2

account 21:13

22:3 40:20

42:7 43:3

accurate 8:6

60:18

ACI 21:20

ACIs 20:19 21:8

across 31:9 42:20

acting 4:21

action 49:25 50:8

51:16

actions 50:1

activated 12:21

16:24 31:4 39:23

50:7

activities 50:2

actual 11:14 13:1

13:9 43:8

actually 18:2

19:18 19:18

19:19 19:21 20:6

21:4 22:1 22:7

33:20 39:19

39:24 40:11 41:2

41:13 41:22

41:23 41:24 47:2

47:5 58:7 58:18

adamant 11:2

add 9:16 23:11

24:14 27:4 39:20

43:2 48:8

addition 47:16

additional

10:19 11:18 17:3

23:15 25:25

29:21 46:5

address 28:5

47:10

adjustment 61:23

advance 77:1

advanced 60:20

affect 66:15

affecting 65:21

affluent 31:12

31:14 31:16

afternoon 4:5

72:4 72:5 74:7

74:13

against 16:21
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 81

agency 7:24 13:13

18:7 27:10 27:16

30:13 32:12

73:14

agenda 8:11 68:21

agreed 8:16

agreement 4:9

16:23 17:12 18:5

18:13 32:12 45:2

46:8 50:4 75:17

Aguilar 5:2 5:2

72:14 72:18

ahead 10:2

15:21 15:21

36:20 47:4 62:2

air 31:23 63:7

63:9 63:14 65:11

65:20 65:25

airflow 63:15

allow 18:14

30:1 30:5 57:9

alluded 17:24

26:7 45:15

alone 38:15

already 15:4

15:12 15:16

16:18 20:18

20:24 23:10

25:17 27:11

27:19 27:19

34:14 36:16 37:3

39:14 43:12 45:9

46:25 48:6 48:11

52:1 52:23 64:16

75:7

am 48:17

amendment 47:3

America 7:22

American 19:15

28:10

ammonia 26:14

among 23:16 44:18

45:2

amount 17:12

29:14 31:23

31:24 32:8

44:4 65:24

amounts 29:8

analysis 20:9

22:8 25:10

28:2 33:16

35:3 36:16

37:9 40:9

40:19 41:5 53:25

54:25 55:11

57:18 58:18 60:9

62:23 63:16

70:13 73:24 76:9

analytical 42:22

and/or 21:11

angle 38:20

answer 69:18

anyone 7:4 7:13

7:25 9:8 56:1

67:1

anything 9:15

18:1 18:14 77:12

anyway 62:22

67:18

appear 60:24

appeared 13:21

apportioned 32:7

appreciate 24:21

appreciation

44:23

approach 13:24

18:21 30:12

36:23 36:24

36:24 38:2

38:5 38:12

49:1 51:8 63:4

75:20

approaches 28:23

appropriate

12:5 76:21

approval 44:18

arduous 50:25

area 32:23

areas 58:20

aren't 17:4 69:20

70:1

arguments 57:9

arrived 11:25

articulated 44:12

47:19

articulation

56:24

aside 31:1

aspect 75:21

assessment 8:24

11:17 11:21 13:2

14:17 14:18

22:24 23:8 23:13

23:21 23:22

23:23 24:2 24:24

25:3 26:11 28:23
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 82

29:4 29:5

29:10 29:18

29:19 30:3

34:1 34:3

34:23 34:24

35:13 35:14

35:15 35:16

35:18 35:23 36:5

36:19 45:13

45:18 47:20

47:25 48:22 50:6

51:4 52:4

52:13 53:6 53:10

53:23 54:4

54:5 54:7

54:11 55:20

57:11 62:19 63:5

63:12 65:20

assessments

13:6 23:10 23:25

28:14 35:10

35:11 48:20

48:21 54:6

assessor 50:16

assist 12:2 68:10

assistance 57:15

associated

29:16 36:1 37:23

38:14 38:21

44:21 44:24

45:21 48:6

51:7 51:20 53:21

54:2 75:13

assume 54:19

55:22

assumes 31:11

assuming 18:25

assumption

60:17 60:21 61:6

61:11

attempt 44:8

attend 5:5 5:6

attributes 9:3

14:23

August 72:8

72:9 72:19

74:7 74:21 74:22

available 8:3 8:4

8:10 13:13 16:12

23:9 28:23 39:14

56:5

aware 12:1

12:10 20:19 44:7

45:4 51:24

away 20:5

B

background 8:9

8:13 16:15

19:3 53:6

58:11 59:16

73:23 76:9

balance 44:20

62:20

bang 43:16

bare 42:3

base 21:21

based 13:21

22:8 25:22 27:20

28:11 36:16

37:21 38:4 44:12

48:23 48:25 50:2

53:25 54:21 64:4

baseline 25:15

basically 8:18

19:3 20:3 20:9

20:12 21:22 22:6

42:16

basis 11:7 21:6

21:11 30:15 33:9

37:24 38:8 42:14

45:17

bear 36:3

begin 4:11 4:17

10:3 38:24

beginning 10:13

41:9

behavior 32:5

Belanger 6:18

6:19 26:1 26:1

29:6 29:7

29:20 30:9 32:17

38:9 38:9 56:7

56:8 57:13

believe 30:18

32:10 32:24

37:25 44:6 44:16

53:25 57:6 64:10

bend 38:3

Betsy 5:10 5:10

better 23:20

54:15 61:7 63:16

73:20

beyond 20:23

25:11 48:15 52:3

bifurcate 20:9

biggest 43:16

bio 61:23 62:22

62:25

biota 75:21 77:2
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 83

biotic 77:2

bit 25:9 33:4

35:20 44:2 72:15

blocks 37:4

blow 26:19

Bluestar 5:12

48:17 70:1

Board 16:10 25:23

BOD 26:14

body 17:18 18:1

31:19 31:25 32:3

32:7 66:20 66:20

boundaries

55:17 55:18

Boyd 7:8

Brad 7:19

bring 19:22 20:14

41:10 49:14

54:23

bringing 42:3

brisk 71:14

broad 30:23

broader 27:2

35:23

Browning 7:21

7:22

build 8:19

building 15:5

bulk 32:13

business 44:21

55:22

Bye-bye 77:20

C

calculations

36:22

Canada 16:11

23:11 25:18

25:23 27:20

56:22

capability 27:6

care 6:17 19:10

61:7

carefully 54:16

Carlton 5:10

carried 54:7

carry 65:8

case 13:23

14:17 20:4

34:2 34:4

34:15 34:18

34:24 35:11

45:16 49:1

49:7 49:9

49:10 49:20

50:15 57:11

74:21 76:22

cases 14:3 60:21

categories

30:23 37:17

Cathy 4:18 10:3

24:11 24:22

28:21 29:7 29:21

32:18 36:20

37:14 44:1 46:18

48:18 48:19

53:13 57:5 73:25

74:11 77:15

cause 49:15

centered 38:17

central 14:19

60:11

certain 37:15

certainly 16:16

17:15 22:20

24:21 25:13 27:1

32:24 44:21

45:17 45:18

45:25 54:23 57:4

57:5 67:22

69:5 70:5

71:18 71:19

71:22

challenges 45:6

challenging

45:5 45:10

chance 73:16

chances 27:24

changed 49:13

changes 30:5

characteristic

57:25

characteristics

30:19 31:2 31:19

36:18 38:4

38:7 41:8

52:18 53:19 60:3

61:15

characterization

35:18 51:19

53:24

characterize

9:4 37:22 38:7

53:15 53:20

56:11

characterizing
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 84

20:23 25:5

charge 4:15 9:1

Charles 7:16

check 16:21

checking 72:12

Chem 7:7

chemical 7:1

7:8 26:8 42:18

42:21 49:24

chemically 66:12

chemicals 21:23

42:19 42:19

42:20 49:24

chemist 66:16

chloramine 66:13

chlorination

66:13

Cindy 57:17

circulated

17:11 23:3

circumstances

40:10

cities 20:5 20:6

clarification

67:4 69:25

clarify 29:7

clarifying 72:20

class 40:24

classes 42:21

classic 42:19

classification

68:16

classifying 40:6

clean 19:16 21:14

22:4 24:10

Cleaning 19:16

28:10

clear 23:14 24:18

25:1 30:1

45:20 53:7

53:8 54:9 55:4

56:24 58:25 59:8

clearly 16:22

17:19 18:20

57:12

closer 46:12

co-author 41:21

colder 31:22

collect 9:2 23:25

29:13 30:2

collection 24:4

55:19 59:19

combination 40:12

comes 27:4

38:25 42:16 51:6

58:14

comfortable 76:19

77:4

coming 20:11

28:17 29:11 40:3

40:21 58:17

74:21

commendations

47:3 47:6

comment 13:19

19:8 48:18 63:20

65:15 66:7

commentary 46:11

commented 48:20

comments 9:17

13:18 47:10

54:20 58:1

59:4 76:24

commercial

58:15 58:16

59:23 59:24

commit 73:5

commitment

44:17 44:20 45:8

committed 71:22

communities 57:23

companies 44:19

69:22 73:7

comparison 25:16

compartment 66:2

compartmentalized

37:3

compiled 29:1

complete 13:11

62:20 62:23

completed 65:22

completely 64:21

complex 75:19

complexity 39:21

compliance

20:19 21:8 21:10

22:5 26:12 39:16

40:22

component 75:23

76:23 77:2

components

75:12 76:6
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 85

compounds 27:1

comprehensive

23:11

concentration

10:20 24:8 26:19

37:15 47:21

58:11

concentrations

8:22 9:5 10:22

14:11 14:15

14:19 14:22 25:6

27:25 29:16

31:12 36:9 36:11

37:23 38:1 53:16

53:21 54:1

54:2 66:15

conceptual

10:23 11:1 11:15

12:3 12:12 12:14

52:2 56:11

concern 62:12

concerns 76:18

76:19 77:1 77:5

concluded 77:21

conclusion 51:9

conditions 28:1

conduct 28:13

conducted 54:1

confident 33:12

configurations

14:11

confusion 65:19

consent 4:9

consider 17:2

18:15 28:19

57:12 61:18

61:18 66:17

consideration

46:22 60:9

considerations

44:7 55:22

considered 17:9

17:14 17:16 28:6

33:7 60:5

considering 36:25

45:6 57:22

consistent

21:11 57:13

constrained 57:7

constraints 55:14

60:23

construct 29:4

consultant 12:4

33:23

consultants 41:22

consumer 19:4

19:4 19:20

20:1 20:11 21:23

22:22 23:16

30:24 58:12 76:5

76:8

consumers 23:6

contacts 73:23

content 17:25

32:6 32:8

32:15 66:19

context 8:25 9:11

continual 21:6

continue 37:12

continuing 46:1

contribute 25:8

34:8 36:11

contributes 30:25

contributing

34:10 48:13

59:25

contribution 19:4

26:13 59:1 76:5

contributions

14:16 21:16 22:2

24:6

convention 12:17

conversations

28:16

convinced 50:21

cooperative

50:5 50:13

core 44:15

Corning 7:14 15:2

33:19

correct 63:14

cost 44:22

44:24 67:19

costing 44:23

council 4:21 6:17

19:10

counterproposal 54:21

country 21:25

26:20 38:18

County 63:2

couple 11:20

64:16 69:15

77:10

course 39:7 62:16
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 86

court 72:15

cover 19:2

covered 17:4

criteria 27:12

27:16

crowd 65:9

curious 37:12

curve 63:12

Cynthia 6:9

52:9 63:1

63:19 66:9 68:1

D

D4 8:17 8:22

10:20 10:22

10:24 11:17

11:22 12:7 12:25

13:6 28:5 38:1

45:13 47:21 51:8

53:21 64:2

D5 8:17 8:22

10:20 10:22

10:24 11:17

11:22 12:7 12:25

13:6 16:10 23:12

28:5 38:1

45:13 47:21

53:21 64:2

data 8:21 9:2

11:10 11:14 13:1

13:4 15:8

15:23 16:11

16:17 16:19

21:20 23:7

23:8 23:15 23:23

23:24 24:3

24:4 24:23

25:1 25:1

25:14 25:25

26:19 27:6 27:21

28:4 28:8

28:14 28:15

28:23 29:2

29:3 29:14 34:12

35:16 45:21 46:3

46:5 46:10

50:6 51:20

52:1 52:5 53:9

53:17 53:24

55:19

database 15:5

databases 20:20

21:7 21:13 39:13

date 11:22

25:21 34:13 72:5

72:22

dated 11:6

David 5:24 6:14

6:14 47:7 47:16

David's 5:25

Davis 4:24

deadlines 74:21

deal 71:12

75:11 75:23

dealing 14:23

19:25 60:24

75:20

dealt 24:11

Debra 5:19 7:15

decent 20:6

26:8 27:23

decide 63:4

66:4 68:24

decision 61:17

decision-making

67:21

decisions 69:20

declare 20:21

decrease 31:23

defend 55:23

deferred 67:18

definition 60:20

degree 32:3

deleo 5:8 5:9

5:11 28:9 28:9

Deleo 56:9

deliverables

74:20

deluding 58:17

de-optimal 32:19

de-optimization

30:21 33:13 38:2

depending 23:24

59:24

depends 60:18

64:22

described 46:25

description 47:9

deserving 76:11

design 19:25 20:3

30:16 32:19

40:10 48:14

designing 22:13

28:5

desire 26:10

detailed 48:21

69:7 70:22
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 87

details 13:10

13:15

determine 12:5

12:13 29:2 36:18

37:13 37:16

determined

35:13 42:10 45:9

57:24

determining 12:10

deterministic

35:21 49:1

develop 11:21

13:5 22:24 32:23

33:3 50:5 50:6

50:22 53:2 54:25

75:20

developed 10:24

11:3 12:4

15:13 16:8

24:3 43:9 44:8

44:11 46:10

49:23 49:24

56:13 71:16

developing 8:19

9:1 13:11

16:15 27:5 47:19

development

11:3 11:8 17:9

33:7

dialogue 43:11

dictated 63:4

differences 24:17

75:14 75:16

different 19:11

22:10 23:25 27:5

27:21 27:25

33:24 35:9 35:10

37:3 37:17 37:17

37:18 39:1 39:19

40:6 42:20 42:21

43:13 51:13

59:21

differentiate

19:13 22:21 23:6

23:16 24:5 33:14

differentiates

19:6

differentiating

59:21

differently 50:19

51:6

difficult 45:1

75:18

difficulties

45:24

difficulty 38:11

digest 46:16

61:22

digging 39:12

dilution 14:13

17:1 17:17 21:15

21:15 22:1 26:23

32:4 56:18

dilutions 14:3

directly 32:3

disagreement 64:3

discharge 19:21

19:23 27:25

discuss 67:12

72:24 74:20 75:3

76:16 77:12

discussing 4:8

53:18

discussion 8:12

8:16 9:9 9:18

10:4 18:12 52:10

56:15 57:15

68:22 68:25

discussions 66:5

disinfect 66:12

disinfection

66:11 66:14

disposal 20:2

22:7 27:22

distribution 12:7

12:25 22:11 27:8

34:19 35:4 35:24

40:18 41:3 48:12

65:12

Districts 63:3

ditch 12:22

ditches 31:6

38:17

docket 8:3 8:11

document 11:18

17:11 18:16 25:4

58:1 62:8

documents 28:12

dollar 41:25

43:16

domestic 19:4

20:11 58:14

58:16 58:17 76:5

76:8

done 15:3 23:10

23:12 23:14

25:22 27:1 27:16

27:20 28:25
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 88

36:16 36:21 37:7

44:4 44:22 45:19

49:5 49:22

50:8 50:20

51:3 51:5

51:11 51:19

59:17 71:3

dope 43:17

Dow 5:15 5:17

7:14 7:14 15:1

33:19 50:3 61:22

down-the-drain

21:23

Doyle 7:23 7:23

DR 6:11 52:9 53:1

53:3 53:5

57:17 58:4

58:7 58:23

59:2 59:5

59:12 59:17 60:2

60:13 60:16 61:2

61:10 61:13

61:21 62:1

62:3 62:6 62:8

62:17 63:22

64:20 65:5 66:21

68:1 68:6

68:15 68:19

74:15

draft 50:1 51:17

drafted 49:25

drain 19:20

drive 65:11

drop 64:17

64:18 64:21 65:2

Duke 48:23

Dumar 7:17 7:17

during 9:18 10:15

Dyer 6:20 6:21

19:8 19:9 26:6

27:3 36:15 36:15

37:2 37:11

39:8 39:8

40:14 42:12

42:16 43:5 43:21

56:9 56:15 74:14

E

earlier 45:15

48:18 57:20

63:24 66:10

early 13:13 13:16

51:9 70:23

ears 58:3

ECA 8:15 50:25

ECCA 56:22

echo 26:17

eco-exposure

65:20

ecological 11:16

economic 44:7

55:14

economics 42:17

42:25

eco-risk 62:13

effluent 20:18

20:21 20:24

36:17 63:20

64:11 64:18

66:15

effluents 66:12

effort 50:5

eight 45:1

Eisenreich 4:22

4:22

either 28:24 70:9

Elaine 7:8

elements 77:1

eliminate 59:8

61:18

Ellen 5:12 5:13

48:16 69:25

else 7:13 7:25

56:1 61:19

67:1 77:12 77:13

eluded 17:16

email 72:25 73:23

73:24

emphasize 15:2

empirical 11:10

23:7 24:23

EMS 51:11

enable 21:25

29:15 37:21

engaged 12:1

engineered 26:5

engineering 12:2

entire 22:11

environment

8:23 10:21 19:14

21:1 41:13 42:23

45:5 45:22 47:22

56:22

environmental

4:10 9:5 10:22

11:14 12:2 12:17

13:1 24:8

24:19 25:6
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 89

25:8 29:16 30:11

36:9 36:11 37:22

38:1 44:17 53:16

53:20 62:19

envision 63:11

EPA 4:6 4:12 4:19

4:20 4:22 4:23

4:24 4:25 5:1

5:2 7:19 9:12

9:14 11:2

11:19 12:17

19:16 23:18 28:3

28:13 28:16 29:8

44:13 45:4 45:12

45:18 48:23

49:18 51:8 51:11

52:17 52:21

54:10 69:9 70:2

ERA 56:4

ERM 12:4 12:12

13:10 18:8

erroneous 61:11

especially 45:1

45:10 64:9

essence 48:14

establishing 36:9

estimate 22:1

estimated 24:11

estimation 67:23

evaluate 34:10

evaluated 29:2

event 67:9 67:16

everybody 54:9

73:15

everybody's 40:16

everyone 4:7

55:18 63:1

everything

46:20 46:22 50:7

51:6 51:22 51:22

63:13

Evonik 6:1 73:5

exactly 37:13

42:7

example 15:13

38:13

exceeding 27:15

37:15

excellent 26:12

Excuse 28:1

exercise 27:11

27:23 28:7 39:12

41:24 42:22 51:1

exercises 32:21

existing 49:24

expand 47:12

expanded 33:4

expansion 23:4

23:19

expansions 45:7

expect 65:22 71:2

expectation 24:19

expectations

24:18

expecting 70:1

experience 50:3

66:24

experiences 39:9

expert 12:2

experts 32:23

explain 35:7

35:19 53:14

explained 35:2

explanation 49:17

exposed 63:6

exposure 11:14

12:6 12:24

13:1 29:18 35:10

35:12 37:18

49:14 53:22 54:4

63:7 63:11

extent 23:20

54:13 77:3

extraordinarily

48:7

extrapolate 27:7

extremely 12:16

77:6

F

face-to-face

54:18

facilitate

11:16 11:23 23:8

facilities

26:11 31:12 59:9

64:10 75:13 76:3

facility 17:22

40:11

fact 12:1 18:6

25:20 34:16

42:12 51:8 63:25

factor 15:7 16:24

16:25 17:1 17:20

17:23 21:15
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 90

21:15 30:18

30:19 31:15

33:17 36:6

45:1 63:21

64:7 67:20 67:23

factored 35:24

factors 4:9

8:17 10:4

13:21 14:12

14:12 17:8 17:13

17:15 18:2

18:5 18:12 18:15

22:1 25:7

26:23 27:8 30:11

30:14 30:16 31:3

31:18 31:20

31:21 32:11

32:13 32:25 33:5

33:8 33:15 36:10

36:25 37:21

37:25 38:6 40:12

46:8 52:22

55:7 55:10 56:17

58:1 58:10

59:4 60:8

61:19 62:8

67:2 70:14 76:16

fair 14:6 17:12

44:4

fairly 20:6

26:8 30:23 36:24

60:7

faith 24:2

44:12 46:1

fall 68:16

familiar 36:23

feed 29:17 29:18

feedback 54:17

55:9 67:1 67:2

69:8 70:12 70:13

70:13 71:1

71:1 71:5 71:8

71:15 72:22

72:24 72:25 73:6

73:14 74:5

feeds 54:11

feel 48:9

Fehrenbacher 4:18

4:18 24:16 28:21

28:22 29:13

30:10 35:9 36:21

37:6 37:20

42:9 43:20

44:1 44:2

48:19 53:13

74:11 77:17

Fehrenbacker

53:14

felt 58:9

FEMALE 7:6

fewer 42:13 42:15

field 19:17

figure 15:23 19:5

43:22 44:24

fill 17:6

filter 12:23 31:6

39:5

filters 38:14

39:25 40:2

finally 32:6

finding 27:24

50:23

FINELY 53:1 60:16

finished 46:18

Finley 6:10

6:11 52:9 52:9

53:3 53:5

57:17 57:17 58:4

58:7 58:23

59:2 59:5

59:12 59:17 60:2

60:13 61:2 61:10

61:13 61:21 62:1

62:3 62:6 62:8

62:11 62:17

63:22 64:20 65:5

66:21 68:1

68:1 68:6

68:15 68:19

74:15

firm 12:2

first 8:15

11:20 30:13

31:19 34:21

61:19

fit 61:14 62:19

five 12:19

12:20 16:3

18:3 18:16 18:20

25:14 26:25

32:25 33:9 33:12

33:13 36:1

36:4 36:7

45:13 52:19 69:6

Flack 7:2 7:3 7:7

67:3 67:3 67:8

67:19

floor 46:18

flow 22:2 22:3

26:22 32:1

32:3 56:18 58:16
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 91

58:16

focus 18:22

61:3 64:9 66:1

focused 18:3

focusing 4:9 8:15

8:17 31:7

folks 10:17 11:25

44:19 66:5 69:19

69:21 71:21 74:9

follow-up 56:7

form 33:9 35:16

50:1 51:17 57:1

formally 71:4

format 46:15

formulating 17:22

19:1 75:12 77:9

formulator 11:13

formulators

31:2 76:4

forward 28:17

33:2 33:22

52:8 54:7

54:19 54:22

74:25 77:6

Foundation

19:15 41:13

founded 26:8

Fowler 4:20 4:20

framework 25:19

26:16 27:5 56:11

frameworks 26:18

frankly 49:7

free 48:9

frequent 39:17

friends 45:3

fruitful 43:7

full 46:20

46:22 62:20

functioning 68:14

future 16:19

G

gaining 44:18

Gamble 19:9 26:2

gap 28:15

gaps 62:22 62:25

Gary 5:17

gathering 28:3

50:2

Gene 7:22

general 4:21

generally 48:24

55:20 63:24

generate 23:7

24:1 47:10 50:23

generated 11:11

11:23 15:9

15:9 16:18 23:16

25:2 25:14 34:13

47:6 47:23 52:25

generic 26:10

26:21

geography 31:20

31:21 65:4 66:8

gets 46:9

getting 13:22

14:17 37:14 50:7

54:17 71:8

71:9 71:23

73:5 73:13 75:8

given 18:18 25:20

26:8 38:2 60:23

gives 24:10 45:14

54:15

giving 54:14

54:14 77:4

goal 10:18

11:20 13:4 22:23

23:5 23:21 27:14

40:17 45:11

goals 10:14

13:7 44:13 47:18

47:23

gone 27:11

graduate 48:22

Grams 7:19 7:19

great 5:3 5:10

5:12 5:14 5:17

5:24 6:1 6:4 6:6

6:9 6:12 6:20

6:24 7:4 68:5

68:9 70:25

greatest 65:11

Griffith 6:12

6:13 6:15

60:11 60:15 63:1

63:2 64:8 64:9

65:7 65:15 66:3

ground 46:12

group 4:1 31:3

74:1 74:2

grouped 32:1

grouping 31:18

groups 19:12
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 92

GUERRERO 6:25

guess 9:15 14:9

15:17 15:20

15:22 17:3

17:5 18:18 18:21

24:24 25:3 29:11

33:2 33:25

36:4 40:4

46:10 47:8

49:2 51:25 55:25

64:8 70:11 70:11

70:25 73:22

75:22

guidance 12:9

50:17 50:18

76:24

guidelines

75:17 77:3

guys 9:19 29:23

75:1 75:2

H

half 65:8

Halya 6:17

Halyna 6:18

handle 26:9

happy 56:23 68:3

hard 16:5 24:23

harder 67:12

haven't 37:5 37:7

67:12

having 8:16 38:10

38:10 48:2

49:4 73:6

head 28:11

hear 23:18 43:21

heard 32:19 46:17

56:6 68:24 74:4

hearing 7:25

9:9 46:13 64:14

Heckman 7:24

Hello 38:9

help 11:23

16:16 16:16 24:4

25:2 29:8 30:4

32:23 35:7 45:23

48:18 49:16

51:14 51:24 52:2

53:8 54:13 59:22

73:1

helpful 17:8

19:12 22:20

23:17 29:25

32:21 47:16 48:1

48:4 48:4 48:8

51:3 53:11 57:19

75:4 75:9

76:20 77:6

helps 26:13

He's 6:15

hesitant 73:5

hesitation 71:22

hey 73:12

Hi 48:16

high 14:2 14:3

14:8 30:22 31:13

31:15 32:7

higher 34:8 67:11

high-flow 32:2

highlighted 10:15

high-suspended

38:20

Hiley 6:4 6:5

hiring 45:7

Hold 65:17

honest 38:10

42:17

hope 50:24

hopefully 70:17

hoping 28:18

host 49:25

hour 43:4

household 19:5

30:24

huge 42:21

Hugh 7:1 67:3

hypochlorites

66:13

I

I'd 5:3 9:13

46:12 68:2 73:13

idea 26:24

44:25 56:1

ideal 40:10

identification

30:13 33:4

identified 4:13

7:5 18:6 30:17

34:3 37:24

identify 5:7

8:7 34:15

45:16 67:5

identifying 33:24

68:11
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 93

I'll 13:8 13:17

26:17 45:11

I'm 5:16 5:20 6:3

6:5 6:23 6:25

13:9 13:13 13:14

22:24 22:25 23:1

23:5 26:3

29:11 30:20 33:1

37:11 38:10

38:10 40:14

41:10 41:20

41:21 41:21 42:3

43:17 43:21

43:22 44:10 47:6

49:4 50:12 51:18

53:7 53:8 56:8

56:8 57:20

59:5 59:7

63:22 64:14

64:20 66:15

67:19 69:24 71:5

71:20 73:5 74:24

76:13

impact 14:14 25:8

32:5 43:23 48:12

64:13

impacting 4:10

30:11 37:25

impacts 24:7 32:3

55:11

importance 63:3

important 12:8

12:16 17:19

17:22 20:15

31:15 31:17

31:22 37:25 55:8

55:10 58:10

59:18 60:25

62:22 62:25

70:15 73:7

importantly 11:16

30:4

impression

13:23 29:23

inadequate 38:24

Inaudible 15:19

21:22 41:22

59:12 59:20 60:2

68:12

include 12:21

17:16 18:24

21:16 22:2 30:17

31:6 31:21 60:10

included 18:9

31:10 32:16 39:7

includes 33:5

including 8:11

38:23

inclusion 43:10

incorporate 15:15

32:24

incorporated

33:22

increase 31:24

32:8

increased 41:17

44:25

incremental 45:20

46:5 48:5

independent 18:19

independently

34:10

indicate 19:23

indicates 19:17

21:9

indications 31:15

individuals 4:12

industrial

18:24 19:6

19:7 22:22

23:7 23:17 26:13

58:15 59:1 59:14

75:11 75:23 76:3

77:1

industries 58:12

industry 15:3

19:17 19:22

19:24 20:3

20:7 66:5

influence 17:21

influences 59:22

influent 18:24

30:17 36:17

58:14 59:6 59:20

63:13

inform 23:20 33:8

53:9

information

8:21 10:19

13:5 16:13 20:20

25:16 26:12

26:19 28:20 29:1

29:10 29:17 30:2

30:6 30:24 34:25

35:8 35:12 47:12

47:20 49:9

50:2 51:21 52:21

53:11 53:15

53:20 56:21 70:2

70:7 70:17

informative 58:19
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 94

informed 4:8

52:20

ingredient 19:21

in-house 50:21

initial 10:14

10:16 12:21

initiate 11:8

input 69:16

inputs 26:21

inspection 8:5

instance 13:24

Institute 19:16

28:10

integrate 16:2

integrative 16:13

intending 29:13

intent 22:16 24:1

35:17 43:14

48:11 76:7

interest 46:1

62:14

interested

19:19 24:9

28:6 34:18 34:18

34:23 35:3

35:4 36:8

40:25 42:2 46:13

interesting 52:10

58:5

interests 42:7

interrelationships

36:13

interrupt 65:18

investigation

41:17

involve 51:16

involved 19:10

isn't 12:9

18:20 40:10

51:23

issue 59:14 67:12

67:18 71:11

75:19 76:4

issues 21:10

21:12 71:12

76:16

I-stream 21:20

22:4

it's 11:22 12:8

12:16 16:5

16:9 16:12 23:14

27:4 36:24 39:12

41:1 41:24

42:6 42:6

42:12 42:21

43:15 44:24

45:20 47:1 48:23

49:5 55:12

63:6 66:16

72:6 72:14

73:7 76:14

I've 19:10

J

Jaeshin 5:14

January 18:8

Jessica 4:20

John 6:17 6:17

joined 7:5

Jones 4:25 4:25

JULY 4:4

justification

69:6

justify 50:23

K

Karen 4:22

Karluss 6:22

9:9 9:25 10:7

13:19 14:25

22:18 27:10

32:14 44:10 46:6

48:10 52:14 54:8

56:4 57:4

68:24 72:20 73:4

73:12 73:24

74:10

Kathleen 5:22

33:19

Kathleen's 5:23

Kathy 14:25

15:1 45:15 49:3

Keller 7:23

Kevin 6:6

key 12:24 17:2

kick 10:1

Kim 5:14 5:16

5:20 5:23 5:25

kinds 14:23

19:7 23:24 23:25

42:1 42:7

56:21 56:23

67:13

knowledge 34:13

KOCH 6:3
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 95

KOZERSKI 5:18

Kristen 6:6

Krowka 6:17

L

LA 63:2

lagoon 12:22

lagoons 31:7

38:16 39:4 57:21

64:17 64:21

64:23

laid 10:14

11:20 18:15

lakes 32:2

language 25:3

25:4

large 19:11

20:5 58:20 65:24

last 7:11 8:14

15:3 31:18 67:17

later 70:9

Laura 41:20

lay 16:5 16:16

29:25

layered 40:19

laying 76:25

lays 70:22

leadership 69:3

least 4:11 8:13

12:10 14:20

16:23 17:4 17:10

18:22 23:12

25:11 25:22

55:13 73:8 76:12

less 38:13

55:10 76:11

let's 61:19 73:21

letter 11:5

level 29:10 35:12

35:15 40:9 48:20

48:22 48:25

49:15 49:19

50:15 51:4 52:4

levels 4:10

8:17 30:11 65:22

Lewis 4:5 4:6 5:3

5:10 5:12 5:14

5:17 5:19 5:21

5:24 6:1 6:4 6:6

6:9 6:12 6:14

6:16 6:20 6:22

6:24 7:1 7:4

7:10 7:13 7:18

7:20 7:25 9:25

10:3 10:7 43:2

56:3 56:4 57:3

68:18 68:22

69:12 69:17 72:8

74:10 74:19

74:19 77:12

77:14 77:18

likely 9:4

31:22 50:5

limitation 64:11

limited 63:25

line 18:13

lines 62:16 70:16

76:15

link 47:22

linking 47:17

47:18

lips 46:18

Lisa 7:8 7:10

7:11 7:17

list 5:4

listed 32:22

33:21

listen 52:10

listening 27:10

liter 64:11

literature

28:25 56:20

little 25:9 25:11

33:4 35:20 38:10

49:4 52:21

70:7 72:15 73:5

living 50:17

loading 24:8

38:22 56:18

loadings 25:9

30:25 34:8

local 38:16

locations 26:25

logic 55:4

long 71:14

lot 16:6 17:5

18:4 19:22 20:20

22:16 24:2 27:19

34:12 39:20 41:1

41:2 46:7 46:8

46:19 52:11 55:7

58:8 58:15

60:4 63:12 69:16

71:9

low 14:3 22:3

30:22 31:12 32:7
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 96

low-flow 32:2

M

Mahaich 48:16

main 63:7

Mait 73:4 73:4

73:12

major 4:9 21:11

30:11 30:14

30:16 30:18

30:19 31:3 31:18

32:10 36:10

36:25 37:21 38:6

43:10 67:23

70:14 71:11

majority 31:9

61:5

MALE 74:12

74:13 74:16

manageable 76:15

management

44:19 50:1 69:21

70:6 70:18

managers 45:6

manner 44:9

manufacture 31:1

manufacturer

11:13 17:21

manufacturers

76:3

manufacturing

19:1 59:9

59:23 75:12 77:8

map 62:20

Marcus 5:2

73:22 73:25

mass 65:24

material 9:18

28:18 45:9

materials 8:10

9:11 9:16 15:6

34:14 65:11

matter 8:1 12:3

matters 4:15

74:20

maximum 36:1

may 8:14 17:13

17:14 17:23

29:24 32:21

40:10 50:22 53:7

60:18 60:21

61:15 63:3

65:1 65:2 65:9

66:14 66:23

76:11

maybe 11:15

20:7 27:17 28:18

30:4 30:7 35:6

35:6 42:20 42:20

47:24 51:2 51:25

52:1 52:7

63:10 63:14

71:11 71:17

75:16 76:14

McCall 43:13

McNett 5:19

7:14 7:15

mean 15:17

16:22 18:18

22:15 28:10

29:21 32:22

34:16 35:25

37:16 37:18

39:10 40:16

41:20 43:24

43:24 46:6

46:9 46:24 47:13

47:15 50:12

50:16 55:1

55:6 61:2

62:10 65:24

67:16 69:14 73:2

73:12 75:24

76:15 76:17

means 37:17

meant 25:12

media 14:22 75:15

75:16

medium 22:2 30:22

38:16

meet 27:2 44:9

meeting 4:3

4:14 4:16 5:5

5:6 6:15 8:3

8:13 8:15

10:17 12:21

47:11 54:18

67:17 71:4 77:21

meets 55:5

member 73:7

members 23:18

44:17 45:2

48:8 52:12 66:23

68:2 68:15

membership 69:3

mention 32:20

61:22 68:2

mentioned 11:7

32:25 33:5

39:3 41:9

54:24 56:3 58:10
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 97

62:9 63:24 67:17

67:20 68:3

69:2 74:25

met 8:14

method 30:15

30:22

methodological

13:9

methodology 20:13

22:4 28:13 47:18

48:23

methods 15:24

metrics 21:9

Mihaich 5:13 5:13

48:16 50:9 50:11

51:2 51:18 69:24

69:25 70:5 70:10

72:20

milligrams 64:11

mind 25:12

38:11 56:1

75:3 75:11

minor 75:16

minus 63:13

missing 17:5

17:13

mode 66:10

model 12:12 26:21

63:6

modeling 15:12

21:21 21:21 24:9

26:9 26:16 26:18

27:11 27:17

27:23 28:4

28:7 29:12

models 10:23 11:1

11:15 12:4 12:15

15:6 15:14

16:8 16:9

16:14 16:17

16:21 21:23

modifications

76:21

modified 15:13

49:14

moment 67:18

Momentive 6:4

7:17

money 67:20

monitor 61:15

62:25 67:10

67:14

monitored 25:17

25:18 52:16

59:10 59:15

monitoring 4:2

8:20 9:2 10:18

11:8 15:5

15:25 17:3

18:4 18:23

19:1 24:10 24:20

27:20 28:3

28:8 29:3

29:14 30:16

35:16 37:1

39:6 42:6 53:9

53:17 53:24 59:6

59:6 59:19

60:4 60:25 61:22

64:1 67:9

67:16 75:21 76:2

76:7 76:11

month 8:14

months 44:3

mostly 62:12

move 52:8 54:19

moved 67:11 70:3

moving 54:22

71:13 73:2 77:6

multi-faceted

42:6

multi-million

41:25

multi-suite 40:19

multi-varia 33:16

municipal 9:23

11:12 38:3 53:21

mute 8:8

N

NACWA 6:9 52:9

57:17 68:2

nation 31:9

national 8:23

11:21 22:11 29:4

29:10 35:14

37:23 37:24 38:8

40:18 41:3 45:13

47:20 54:5

naturally 64:23

nature 24:25

necessarily 38:23

58:9

necessary 12:14

negotiating 71:3

negotiation 10:16

46:2

nice 21:7
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 98

nine 25:18

noise 8:9

none 7:25 9:9

12:10

normal 49:18

59:23

north 31:20

notes 63:23

nothing 61:3

77:13

noticed 13:20

O

object 62:16

objective 8:18

9:1 9:7

objectives 4:15

obviously 17:1

21:4 23:24 39:10

41:6 44:22

46:7 55:1 55:9

55:17 67:14

offered 68:10

off-flow 63:13

Office 4:6 44:3

68:10 68:10

Oh 53:1 68:5

okay 5:12 5:21

6:2 6:16 7:13

7:18 7:20 7:25

9:9 9:13 9:19

9:25 14:9 30:9

30:10 52:23 59:3

59:17 60:1 60:23

61:9 61:12

62:6 63:1

63:19 65:3 66:25

67:2 68:9

68:20 69:23

70:10 72:12

72:19 73:9 73:17

73:21 73:22 74:3

74:16 74:17

74:19 76:17 77:7

77:11 77:14

ones 15:15 17:3

17:16 23:11

70:14

open 26:20

operating 21:4

26:6 26:15

opinion 52:15

52:20 66:21

opportunity

9:10 54:15

optimization

30:14 36:22 38:5

70:13

optimizer 67:25

options 57:24

order 29:3 38:6

40:16 49:14

62:20 62:22

Oregon 25:17

27:20

organic 17:25

32:6 32:8

32:15 66:19

organics 41:12

41:16 42:17

organize 77:8

organizing 9:14

original 13:4

22:23 23:5 23:20

25:13 33:7 45:11

47:23 62:5

originally 47:19

others 4:13 5:6

20:12 29:22

55:10 76:12

outflow 60:12

outset 10:18

overall 30:12

over-commit 71:24

overlaid 41:7

OVERTALK 63:18

67:4

oxidated 12:22

oxidation 31:6

38:16 39:5

ozone 66:14

P

pace 71:14

pack 41:6

page 18:9 73:8

paper 23:2 30:8

parameters

26:15 32:1 48:2

Pardon 6:18 50:10

62:3

participants 68:7

participate 4:14

particular

10:12 11:1 19:24

20:24 25:4 27:12
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 99

27:15 39:18 41:4

46:11

particularly 24:7

27:10

partition 31:17

31:23 32:9 64:2

partitioning 32:5

past 15:9 16:2

25:20 35:1

43:4 44:3

45:19 50:3

path 33:2

pathway 63:7

65:22

pathways 10:21

12:7 12:25

Patrick 6:12 63:2

65:5

Paul 4:5 5:8 9:13

28:9 28:9

28:21 29:22 56:4

56:9 73:24 74:19

77:13

PCPC 26:2

PENBERHTY 71:9

Penberthy 5:1 5:1

10:2 10:5

13:19 13:20 14:2

14:9 15:17 15:20

15:22 16:22

18:18 22:15

23:22 24:14 28:2

30:7 33:11

34:6 34:17

35:1 35:19 35:25

36:8 36:20

37:5 37:7

38:25 40:8 42:14

42:24 43:17

43:22 46:6 46:24

47:4 48:10 49:22

50:10 50:20

51:15 52:6 52:23

53:2 53:4

54:23 56:6

57:1 57:8 58:3

58:5 58:22 58:24

59:3 59:11 59:13

60:1 60:10 60:23

61:9 61:12 61:20

61:25 62:2

62:4 62:7

62:10 62:12

63:19 64:14

65:17 66:18

66:25 67:7 67:11

67:24 68:5

68:9 68:17 68:20

69:23 70:3

70:8 70:11

71:7 71:25

72:3 72:6 72:9

72:12 72:17

72:19 72:23

73:11 73:17

73:21 74:4 74:17

75:6 75:10 75:25

77:7 77:13 77:16

77:20

PENERTHY 65:3

people 5:4 24:2

38:15 55:20

63:12 65:12

per 58:21 64:11

percent 19:17

20:3 20:7 59:1

60:6

percentage

58:13 59:24

performance 26:7

perhaps 24:17

27:13 35:6 59:18

period 70:25

71:16

permission 70:6

permit 20:19 21:8

22:5 26:12

Perricase 7:9

7:12

P-E-R-R-I-C-A-S-E

7:12

person 8:6 58:21

Personal 6:16

19:10

perspective 32:17

32:22 47:25

56:16 57:5

pertain 22:10

PH 7:7

Ph.D 66:16

phases 24:7

phone 8:8 65:9

physical 40:11

pick 13:21

picking 46:18

piece 39:21 43:10

55:13

pieces 70:1 76:2

places 23:9

plan 35:7 49:25

50:8 51:16 61:13
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 100

75:21

plant 11:4

15:14 17:19 21:3

26:22 29:9 39:15

39:23 45:7 61:23

63:8 63:8 63:15

plants 10:25

11:11 21:5 21:24

22:10 26:5 26:16

40:22 66:11

68:14

play 20:2

please 5:7 8:7

Plotzke 14:25

15:1 15:19 15:21

16:4 33:18 33:19

34:12 34:20

34:22 35:6 35:17

35:21 36:4 45:15

49:3

plug 16:20

plugged 16:18

point 9:16 12:8

12:17 13:8 18:21

26:9 29:1

32:22 37:10

43:24 44:11

49:11 49:20

52:15 53:8 64:22

68:6 73:13

points 35:22

40:13 42:23

policy 52:2

pollution 4:6

14:2

poor 38:21

population 14:3

14:13 16:24

17:18 26:22

30:18 30:21

30:23 38:13

56:17 57:22 58:8

58:19 59:1

populations 58:20

64:24 64:25

portion 9:23

10:11 60:7 77:2

posed 62:14

positive 50:3

possible 55:6

73:18

potential 18:11

20:16 68:11

potentially 41:16

61:11

POTW 4:2 8:18

8:20 12:3

14:11 17:20

18:10 18:22 24:7

30:19 30:25 31:2

31:16 57:25

59:20 62:24 67:8

76:9 76:23

POTWs 4:10 8:23

9:3 9:6 14:20

14:23 18:24 19:5

29:17 30:12 31:7

31:9 36:10 37:23

38:3 38:3 38:7

44:5 52:16 53:17

53:22 54:3

59:9 59:16

60:4 61:5

68:11 76:5

POW 76:23

power 22:8

36:16 46:9

POWs 12:5

practical 45:24

46:4 55:17

practicalities

39:11

preclude 18:2

predicting 15:7

preliminary 36:22

preparation 9:21

prepared 8:2

13:14 75:8

presence 8:22

10:20 47:21

present 4:12

5:9 50:22

presentation 9:12

10:16

presented 8:10

56:21 76:1

pressure 71:10

pretty 13:22 23:4

23:10 25:21 26:7

43:14

Prevention 4:6

previously 18:5

prior 11:3 50:7

prioritization

19:11

privy 28:16

probabilistic

35:18 35:22

35:23 36:5
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 101

probability 37:15

probably 9:18

18:4 20:18 20:22

27:22 29:25 32:4

34:14 43:6 56:15

64:17 64:18

75:19

problem 49:2

49:10 49:20 53:4

70:20

procedural 4:15

8:1

procedure 12:5

12:18

procedures

12:13 15:24

proceed 68:24

process 13:11

16:13 20:17

32:17 44:18

54:22 67:21

processes 19:11

43:8

processing 19:2

31:1 75:13 77:9

processor 11:13

17:21

processors 76:4

Proctor 19:9 26:2

produced 15:6

product 19:20

50:4 55:23

products 6:17

19:5 19:10 58:12

58:21

program 10:15

10:18 11:8

13:7 16:1

21:19 22:14 23:5

23:21 30:16 33:4

33:10 41:12

41:14 42:18

44:13 45:8 45:12

49:24 56:14 76:7

76:23

programs 21:20

44:5

project 66:6

prominently 11:7

proper 69:1

proportion 27:14

proposal 8:19

8:20 9:21 9:24

10:11 14:7 15:18

15:22 16:6 16:24

17:5 17:10 18:17

22:17 29:24 30:1

31:11 32:23 33:1

33:7 33:22

39:1 39:3

43:18 43:23 44:8

44:12 44:16

44:20 46:7 46:11

46:15 46:21 48:1

54:21 57:2

62:5 67:15 68:23

71:2 71:15

74:6 75:15 75:15

76:1 77:8

proposals 55:2

propose 30:22

31:7

proposed 15:10

30:13 52:19

69:10

proposing 16:20

49:8

proposition 45:5

protecting 40:25

protracted 28:7

provide 8:13 9:10

10:19 11:14 13:1

13:5 13:16 28:19

30:15 30:24

47:24 49:17

53:10 54:20

56:16 56:24 57:5

57:15 71:4

provided 9:16

18:7 28:12 28:24

56:15

provides 8:21

8:25 15:11

providing 47:20

72:22

public 8:5

54:18 67:6 71:3

publicly 28:19

published 16:7

pulled 44:15

purpose 52:13

64:22

push 74:25

pushing 73:9

Q

qualifying 26:11

quality 20:18

20:21 26:12
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 102

38:24

quantitative

53:23

quarterly 67:22

question 20:10

22:7 28:11 29:21

29:22 33:25

35:20 41:15

50:12 50:14 55:3

67:14 69:19

questions 9:8

9:17 13:18 28:17

33:18 52:11

quick 8:1 22:19

quickly 39:14

75:11

quite 44:2

quorum 74:18

R

ran 64:15

range 9:4 14:10

26:8 29:15

34:5 34:7

37:22 44:25

45:22 49:6 49:12

53:18 54:2

ranges 14:18 25:5

rarity 39:24

rates 36:9

rather 59:20 61:6

73:13

ratio 35:18

rational 8:20

55:4 55:21

rationale 69:7

70:22

Ray 6:4

reach 20:25

reaches 31:25

real 55:3

realities 46:4

55:17

reality 39:21

realize 40:9

45:24

really 10:19 11:7

11:21 12:9 13:14

14:4 15:3 15:4

15:10 16:10

16:20 19:12

19:24 20:1

20:2 20:4 20:5

20:15 20:15

22:13 23:4

27:4 27:7 27:9

27:11 27:13

27:14 33:20

33:25 35:3

36:5 40:5

40:18 41:18 42:4

42:5 42:5 42:6

43:15 44:11

44:13 44:14

44:15 44:16

44:20 51:17

52:17 57:19 58:9

60:18 61:14 62:1

62:18 63:16

64:12 66:7 66:21

67:12 67:16

69:16 70:19

reason 23:19

40:14 58:20

reasonable

29:14 44:9 45:17

46:14 46:23

50:22

reasoning 57:10

recalculate 16:14

recall 8:14

received 17:21

receiving 17:17

17:25 31:19

31:25 32:3

32:6 36:17

41:8 66:20

receptors 12:24

recommendation

12:19

reduce 8:9

referring 15:23

refine 49:2 49:21

refined 50:15

regime 39:23

Region 7:19

regions 44:6

registered 5:4

regular 71:14

regulators 45:8

related 62:13

relative 14:16

25:16 48:6

relatively

26:10 61:1

release 76:13

releases 10:24
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 103

14:8 65:21

releasing 51:16

remains 31:24

remarks 9:10

remind 10:17

removal 26:19

remove 60:17

repeat 67:7

replace 58:25

report 13:11

13:13 13:15 18:8

56:4 70:22

reporter 72:16

represent 31:8

40:18 61:4

representative

11:2 40:24 41:5

represented 23:4

representing 19:9

represents 40:12

required 52:3

research 19:14

41:12 41:13

66:22

researchers 44:6

respect 55:21

69:7 70:25 74:24

respond 15:1

response 69:4

73:16

rest 26:20 34:25

results 47:22

48:2

returning 65:21

revalidate 16:14

Review 16:10

25:23

risk 8:23 11:16

11:21 13:2

13:5 14:17 14:18

22:24 23:8

23:9 23:13 23:14

23:21 23:22

23:23 23:25 24:1

24:24 25:2 25:23

26:11 28:14

28:22 29:4

29:4 29:18

30:3 34:1 34:3

34:4 34:23 34:24

34:25 35:10

35:12 35:14

35:16 35:17

36:19 45:9 45:13

45:17 45:20

47:20 47:25

48:20 48:21

48:22 49:15 50:1

50:6 50:16 50:22

50:22 51:4

51:7 51:10 51:19

51:20 52:4 52:13

53:6 53:9 54:5

54:6 54:7

54:11 55:20 60:9

62:19 63:5

risks 24:11

rivers 32:2

Robert 4:25

robust 35:16

role 4:13

Rothbart 6:14

roughly 21:24

route 21:1

routinely 56:19

rule 45:3 50:24

run 32:19 33:13

47:6 47:17 47:22

47:23 54:10

runs 52:24 53:7

rural 38:18

Russell 6:1 6:2

73:4

S

sampled 12:6

42:11 63:9 75:16

samples 16:3 34:9

36:12

sampling 9:1 11:4

11:10 12:18

15:24 19:25 20:3

21:18 39:23 44:4

44:4 57:6 63:8

67:5 67:21 67:21

68:4

sand 39:25

Sanitation 63:2

saw 11:18 17:11

76:2

scans 9:3

scenario 13:24

34:2 34:4

scenarios 34:15

37:18

schedule 72:15
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 104

schedules 71:21

72:13

science 42:5 43:1

science-based

8:19 55:4

scientific

30:15 57:9

scope 23:19 25:13

66:6

Scott 6:18 6:20

19:9 22:20

26:1 26:6

26:17 27:3

29:6 36:15

38:9 39:8 39:8

42:9 44:1 56:8

56:9 56:15 74:14

Scotts 57:20

screening 35:12

35:14 48:20

48:25 49:19

50:15 51:4 52:4

search 28:25

second 65:19

secondary 31:5

31:8 61:3 64:10

section 18:10

18:11 53:22 54:3

sediment 31:25

32:9 65:21 65:25

seeing 51:13

51:13 53:7

seem 62:22 62:24

seems 35:25

seen 25:20 25:21

SEHSC 6:22 7:16

8:19 19:2

23:18 28:16

28:25 32:13 39:3

50:6 52:14 52:18

62:5 62:15 67:15

74:5 74:9 76:3

76:10

select 18:3 19:21

selected 10:12

14:6 42:10 64:5

selecting 21:5

64:24

selection 18:16

20:17 33:9

37:8 43:8 70:23

self 64:23

selfcorrelating

38:13

self-selecting

57:21

send 41:20

41:21 43:7

43:8 46:15

47:2 47:5 47:8

54:24 54:24 70:3

70:8 73:22 74:1

sends 54:10

senior 44:19

69:21

sense 14:10 14:20

30:4 39:10

55:5 55:19 70:19

73:10 75:4

sensitive 74:24

sensitivities

33:17

sensitivity 25:10

sent 9:11 11:19

17:14 17:24 30:8

47:14 58:2

sentences 11:20

separable 76:6

separate 59:14

76:4

separately 59:15

September 11:6

septic 60:5 60:12

served 26:23

38:14 56:18

57:22 58:8 58:19

serves 17:19

service 68:3

services 12:1

setting 31:1

seven 44:24

several 15:3

39:19 44:3

46:8 49:23 68:2

share 51:4

51:21 52:24

sharing 51:22

76:19

shed 21:21

she's 5:20

Shin-Etsu 7:21

shortcomings

29:24

shows 25:22
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 105

significant 60:7

Silicones 7:21

48:17

siloxane 4:1

4:8 4:10 9:5

14:14 19:14

21:18 22:14

29:16 30:25

31:12

siloxanes 8:15

20:11 20:25 25:6

27:24 30:12

30:25 31:17

31:23 32:5

32:9 45:22 60:18

62:24 64:2 66:15

similar 16:9

41:18 42:2 56:21

simulate 10:24

simultaneously

27:9

single 16:6 60:20

67:5 67:9

Sinitsu 74:16

site 10:23 11:1

11:15 12:4 12:12

12:15 12:23 14:6

33:3 37:8 43:8

63:6 67:5 67:6

70:23

sites 8:18 8:20

9:22 10:12 11:12

11:13 11:25

12:11 12:13

12:20 12:20

13:21 18:3 18:16

18:20 19:2

19:2 19:21 25:14

25:16 25:18

26:23 32:25 33:9

33:12 33:14

33:24 36:1

36:4 36:7

36:18 37:1

37:2 37:13

40:3 40:18

41:4 42:11 45:13

46:17 48:3

57:6 65:23 67:13

68:4 69:2 69:6

76:10 77:9

site-specific

29:9

sitting 39:24

situations

38:23 56:13

56:21

size 20:6 30:18

30:21 30:23

38:16 59:1

slightly 43:13

sludge 12:22 31:5

39:23

small 57:23 64:24

Smith 6:6

solid 56:10

solids 17:25

20:23 21:1 26:14

31:14 31:16

31:18 32:14

38:19 38:20

38:22 56:18

61:24 63:20

63:25 64:3 64:18

somebody 58:10

63:23

somehow 14:21

75:20

someone 28:15

someplace 49:7

somewhat 49:1

somewhere 55:4

55:5

sorry 14:2

16:25 30:20

43:21 47:7 57:20

68:14 69:24

sort 11:24

14:15 20:12

23:19 24:24

25:24 28:11 38:3

45:23 46:2 46:21

47:17 54:10

61:14 69:21

70:20 76:8

sorting 42:25

sounded 25:9

25:10

sounds 33:20

source 19:6

sources 10:21

12:24 19:7 19:13

22:22 23:7 23:17

24:5 30:17 58:14

58:15 58:17

59:14 59:23

59:24

south 31:20 65:10

span 38:22

53:18 54:1

spans 14:18
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 106

speak 5:5 13:14

speaking 8:6

8:8 56:8 56:9

61:1

specific 26:23

35:22 43:18

49:12 55:9 76:18

76:20 77:5

specifically 9:22

11:24 47:24

75:24

spell 7:10

spend 45:7

spent 44:2

spoke 18:6

spoken 44:5 66:10

Stable 7:16 7:16

stage 68:23

stages 16:6

standard 12:9

12:12 36:24

standpoint

20:17 22:21

start 9:14

10:10 10:13

22:13 42:25

48:24 49:18 75:7

started 11:9

67:12

starts 18:10

18:12

state 42:4 61:5

stated 10:18

29:14 45:12

statement 64:1

states 21:22

41:15 65:23

stating 61:6

statistical

12:9 12:13 12:18

36:24 52:24

54:25 55:11

statistician

13:14

statistics 64:15

Stedeford 4:23

4:23

steer 20:5

step 22:19

27:18 28:3

56:1 68:23

steps 49:5 54:9

54:18

stewardship 44:17

50:4

stick 65:9

stop 13:8 13:17

strategy 9:2

stream 56:18

streams 32:2

strongly 25:21

32:20

struggling

22:25 23:1 25:24

studies 41:25

studying 64:24

stuff 15:8

15:12 16:18

16:19

submission 18:9

submissions 18:7

submit 41:19

subsequent 8:16

73:15

substantial

23:4 23:15

substantially

57:7

substantive 9:15

subtraction 20:13

sufficient 8:21

13:5 47:9 69:8

suggest 26:4 30:5

58:22

suggested 59:7

75:2

suggestion

32:18 33:3 58:24

58:25

suggestions 43:23

76:25

suggests 51:20

suite 22:10 41:25

summarize 51:25

summed 24:16

support 8:23 13:2

24:23 25:2 30:3

supports 52:5

sure 5:20 8:5

22:24 23:5

26:3 40:22 40:23

41:2 41:20 41:21
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 107

46:19 47:11

64:20 69:17

73:25 75:6 76:13

survey 19:16

19:24 21:14 22:5

suspect 20:24

suspended 17:25

20:23 21:1 26:14

31:13 31:16

32:14 38:19

63:20

system 20:19

21:20 21:21 22:5

59:19

systems 21:8 26:5

27:6 27:22

T

table 4:12

20:14 43:19 48:7

55:2

taking 42:7

talk 19:12 58:8

69:2

talked 12:20 25:5

34:16 43:12

48:11 52:11

54:12 60:3 70:12

76:1

talking 18:10

18:23 35:1

43:4 43:25 67:13

69:12 71:25

72:21 72:21

72:23 76:22

tanks 60:5

target 14:7

14:7 73:21

targeted 57:11

tease 33:17 36:13

TECHNICAL 4:1

Technology 18:11

teleconference

4:8

telephone 55:14

temper 46:2

temperatures

31:22

ten 20:7

tend 35:11 38:17

tendency 14:19

65:11

terms 8:5 8:13

8:14 8:16 8:17

8:25 9:7 9:21

10:4 10:14 14:16

26:22 30:10

30:19 31:2

43:2 45:12

46:3 47:19 54:17

54:18 65:25

68:25 68:25

68:25 69:4

69:7 71:5 71:6

75:22 77:6

tertiary 31:10

31:13 60:13

60:17 60:19

60:25 61:7 61:14

test 15:24

50:23 75:17

testing 77:2 77:3

thank 5:3 5:14

6:16 9:25

77:14 77:16

77:17 77:18

thanking 9:14

Thanks 9:13 77:19

that's 9:7 11:9

11:11 11:13

11:17 11:22

13:11 14:5 16:12

16:18 20:15 21:6

21:16 25:14

27:15 27:18 29:5

33:4 35:15

36:2 36:14 36:25

39:6 40:14 40:20

41:17 42:4

43:5 43:24 44:14

45:4 45:17 45:18

46:10 46:20

46:22 48:13 51:2

51:11 53:4

55:6 57:3

57:10 61:9 62:17

64:12 65:22 66:1

67:14 68:17

68:18 70:19

71:21

themselves 4:13

7:5

theoretical 37:9

theory 59:13

there's 16:1

16:11 18:1

18:4 18:13 18:14

19:23 22:25

23:14 23:25

27:12 33:15

38:18 40:19 46:6

48:21 50:11
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 108

51:12 51:23 55:2

55:17 56:3

57:8 58:8 59:6

60:19 61:21

64:16 65:19

70:15 71:11

they're 14:23

21:11 33:24 40:1

42:22 43:11

43:13 76:6

they've 39:3

39:25 44:4

THOMAS 6:23

9:13 10:9 14:1

14:5 17:7

22:18 24:13

24:21 34:21 35:5

44:10 46:14

47:13 47:15 54:8

68:13 69:5 69:14

69:18 70:21 71:8

71:18 72:1

72:5 72:10

73:9 73:19

74:3 74:8

74:23 75:7 75:22

76:17 77:11

77:19

thoughts 54:16

65:4 65:5 69:1

70:16 77:5

thousand 38:15

throw 68:7

Thursday 72:4

72:5

Tobias 4:24

4:24 47:2 47:5

47:7 47:14 65:14

65:18

today 4:8 8:10

8:18 9:7 52:7

54:12 55:24

69:20 70:9 70:12

72:7 76:1 76:22

Todd 4:23

tomorrow 70:9

tool 33:13

tools 22:6 43:12

top 27:4

torque 56:14

total 20:23 31:13

31:16 32:14

63:24

totally 61:17

Toxics 4:7

trace 41:12 41:15

42:17

Tracy 6:24

trade 19:12

traditional 28:22

training 40:23

trainings 39:17

40:5

transcriber 47:7

transcript 8:2

8:4 8:6

travel 71:21

treatment 9:23

10:11 10:25

11:12 14:13

15:14 16:25

17:17 17:19

18:11 21:3 21:24

22:10 26:5 26:11

26:22 27:15 29:9

30:20 31:4

31:5 31:8

31:10 31:13

38:21 38:24 39:1

39:4 39:5

39:11 39:15

39:16 39:19

39:20 40:5

40:7 40:23 40:25

57:24 60:6 60:13

60:17 60:19

60:21 60:25 61:3

61:14 61:23

63:15 64:10

66:11 68:14

75:13

Trent 7:23

trickling 12:23

31:6 38:14

39:5 40:1 40:2

trouble 49:4

true 27:13

39:24 60:22 64:1

truly 41:5

try 38:22 47:11

49:12 77:7

trying 13:23

14:10 18:22 19:3

19:19 19:19

22:24 27:13

27:14 33:1 37:13

39:2 40:17 43:15

43:17 43:22

44:20 48:17

50:14 50:16

63:22 73:2 76:8
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 109

TSS 64:6 65:1

TUESDAY 4:4

turbulence 32:4

tweaked 49:13

type 15:7 16:25

17:17 19:24

29:10 35:15

39:18 56:13

57:18 57:23

57:25 58:18

types 14:13 15:14

29:3 30:20

31:4 31:5 35:9

35:10 39:1

39:5 39:6

39:11 39:19 40:6

54:2 59:22

typically 48:25

56:16

U

U.S 54:3 60:7

ultimate 63:4

ultimately

54:19 69:19

ultra-violent

66:14

uncertainly 36:1

uncertainty 35:24

36:2 36:6

under-deliver

71:24

understand

14:21 16:2

17:1 19:20

20:1 24:3 24:5

27:7 27:14 29:15

33:2 39:14

41:3 43:15 48:12

48:19 49:13

51:14 51:24 52:2

54:6 54:12 55:16

57:10 62:14

67:24 76:9

understanding

22:9 24:10 24:25

25:7 25:19

34:5 34:6 34:7

35:4 46:20 48:24

49:19 69:9

understands 24:6

understate 44:14

understood 61:9

UNIDENTIFIED

7:6 74:12

74:13 74:16

uniform 15:25

United 41:15

65:23

University 48:23

unless 58:19 70:6

unprecedented

44:16

updated 40:1

upon 47:14

upstream 21:16

22:2

USCCA 56:22

useful 52:17

58:13 59:21

61:16

usually 26:7

49:18

utilities 64:4

64:6

V

valid 57:9

validate 11:15

12:3 12:6

12:11 15:11 36:7

validating 12:14

validation 36:5

value 34:5 34:6

34:7 34:25 45:21

46:5 47:25

48:5 52:3 52:4

variability 14:21

variable 34:11

67:25

variables 14:14

15:7 15:15

17:2 18:19

24:6 32:15 33:21

34:8 36:14

38:5 38:12

43:3 46:25 48:13

49:12 68:25

variance 37:16

variety 9:3

various 14:11

14:12 14:22

14:22 15:15 16:6

19:7 24:6

27:25 33:15

48:13 53:17

70:14

vast 31:9
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 110

verify 12:24

versus 20:12

22:22 23:6 23:16

35:22 35:22

48:22 50:15

58:12 58:14

58:16

view 11:10

11:22 13:4 18:13

18:21 23:3 25:13

26:9 73:13

vigorously 55:23

violation 21:10

violations 21:6

64:6

Visar 7:7 7:8

vis-from 43:18

W

Wacker 7:1 67:4

wait 5:21

walk 17:8

Ward 5:1 9:25

13:20 15:2

17:7 22:18 24:22

29:14 29:20

32:20 35:5 37:21

43:8 51:2 54:8

74:23 77:14

wasn't 41:23 47:9

62:7 62:9

wastewater 9:23

10:11 10:25

11:12 15:14 21:3

21:24 22:10 26:4

26:22 27:15 29:9

39:15 60:6

water 17:18 19:14

19:16 20:21

21:14 21:21 22:4

31:24 36:17 41:8

41:12 44:3 65:21

66:1 68:10 76:13

ways 70:15

we'd 57:12 74:6

week 13:13

13:16 56:5

69:4 69:6

69:10 70:23

71:16 71:20 72:2

73:10 73:14 74:5

weeks 69:15 77:10

weigh 52:15

weight 65:8

welcome 4:7

we'll 4:14 8:3

9:12 69:23

70:8 73:22

74:1 77:10

well-performing

64:5

well-selected

26:25

Wendy 6:2

we're 12:10 13:12

16:14 16:17

16:19 18:22

18:23 19:3 19:19

21:2 21:4

22:23 24:1

24:8 26:3 28:5

28:6 30:1

33:11 33:25

34:17 34:18 35:1

35:2 35:3 36:8

38:21 38:22

40:25 42:1

42:5 43:24 45:25

46:4 49:8

50:24 51:12

51:13 51:21

51:23 52:15

54:20 58:3 65:20

70:21 71:7

71:9 71:12 71:22

71:25 72:12

72:18 72:23 73:1

73:6 73:11 73:25

75:3

West 6:7 6:8

we've 15:3 15:4

15:10 15:12

15:13 16:9 19:18

21:20 24:18 25:1

27:21 28:25 29:1

30:17 31:4 33:22

34:3 35:2

37:24 38:2

39:9 43:3

43:12 44:2

44:5 44:8

44:22 48:6 48:11

49:22 50:3 50:13

50:13 51:5 51:10

52:6 52:23 53:18

54:1 54:12 56:21

60:3 67:15 67:17

67:20 70:12

74:17 76:22

whatever 66:4

67:22

WHEREUPON 77:21

whether 17:20

21:3 21:9
POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 111

21:11 23:1 39:15

59:8 61:17

69:8 69:9

whole 16:11 46:19

49:25 55:7 69:16

74:1

wide 26:20

willing 68:7 77:4

wonder 27:9

wondered 60:2

62:18

wondering 52:12

59:5 60:4 60:8

64:4 66:10 71:5

work 16:2 18:22

21:19 25:22 28:4

37:8 41:2

41:23 56:13 57:4

57:19 62:15 71:6

72:11 73:19 74:8

worked 56:24

workers 45:7

working 4:1

26:2 51:11

works 72:2

74:15 74:23

worst 13:23 14:17

34:2 34:4

34:15 34:18

34:24 35:11

45:16 48:25 49:7

49:8 49:10 49:19

50:15 57:11

worst-case 35:3

worthy 41:16

41:16

wrapping 38:11

written 16:7

46:15 50:18

54:14 54:15

72:25 73:14 74:5

76:24

wrong 61:4

Y

yesterday 11:19

17:12 17:14 23:3

25:4

yet 5:20

yourself 5:7 8:7

you've 17:16 33:5

40:2 46:12

51:3 51:19 55:23

60:3 67:11

Z

zero 20:4 49:7