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 MaterialsPOTW 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 25POTW 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 ourPOTW 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 thePOTW 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 wellPOTW 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 wouldPOTW 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 canPOTW 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 monitoringPOTW 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 thePOTW 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 receivingPOTW 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 ... thePOTW 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, ifPOTW 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 thePOTW 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 withPOTW 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 assessmentsPOTW 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 naturePOTW 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 somethingPOTW 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 dischargePOTW 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 andPOTW 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 soPOTW 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 bodyPOTW 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 wouldPOTW 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 aPOTW 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 mePOTW 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 impactingPOTW 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 comesPOTW 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 somePOTW 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. AndPOTW 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 wherePOTW 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 thePOTW 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 aPOTW 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 ourPOTW 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 thanPOTW 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 worstPOTW 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 ofPOTW 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 arduousPOTW 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 analysisPOTW 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 thePOTW 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 thePOTW 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 alsoPOTW 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 thatPOTW 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'rePOTW 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 orPOTW 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 otherPOTW 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 termsPOTW 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 againPOTW 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 respectPOTW 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 somethingPOTW 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 thenPOTW 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 thatPOTW 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 inPOTW 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 yourPOTW 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 25POTW 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 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 79

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25POTW 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 2nd72:8 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

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6 6th 73:18 73:20

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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 accompanied70:17 accomplish40:16 accomplished27:2 account21:13 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 acting4:21 action 49:25 50:8 51:16 actions 50:1 activated

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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 agreement4:9 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 airflow63:15 allow18:14 30:1 30:5 57:9 alluded17:24 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 amendment47:3 America 7:22 American 19:15 28:10 ammonia 26:14 among23:16 44:18 45:2 amount17:12 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 anything9:15 18:1 18:14 77:12 anyway 62:22 67:18 appear 60:24 appeared13:21 apportioned32:7 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't17:4 69:20 70:1 arguments 57:9 arrived11:25 articulated44:12 47:19 articulation 56:24 aside 31:1 aspect75:21 assessment8:24 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 28:23POTW 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 assist12:2 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 assuming18:25 assumption 60:17 60:21 61:6 61:11 attempt44:8 attend 5:5 5:6 attributes 9:3 14:23 August72:8 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 bang43:16 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 basically8:18 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 beginning10:13 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 bend38:3 Betsy5:10 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 biggest43:16 bio 61:23 62:22 62:25 biota 75:21 77:2POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 83

biotic 77:2 bit25:9 33:4 35:20 44:2 72:15 blocks 37:4 blow26:19 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 Boyd7:8 Brad7:19 bring19:22 20:14 41:10 49:14 54:23 bringing42:3 brisk 71:14 broad 30:23 broader 27:2 35:23 Browning7:21 7:22 build 8:19 building15:5 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 carefully54:16 Carlton 5:10 carried54:7 carry65:8 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 Cathy4:18 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 centered38:17 central 14:19 60:11 certain 37:15 certainly16:16 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 changed49:13 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 characterizingPOTW 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 checking72:12 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 chemist66:16 chloramine 66:13 chlorination 66:13 Cindy57:17 circulated 17:11 23:3 circumstances 40:10 cities 20:5 20:6 clarification 67:4 69:25 clarify 29:7 clarifying72:20 class 40:24 classes 42:21 classic 42:19 classification 68:16 classifying40:6 clean 19:16 21:14 22:4 24:10 Cleaning19:16 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 collect9:2 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 coming20:11 28:17 29:11 40:3 40:21 58:17 74:21 commendations 47:3 47:6 comment13:19 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 commit73:5 commitment 44:17 44:20 45:8 committed

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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 component75:23 76:23 77:2 components 75:12 76:6POTW 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

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50:21 cooperative 50:5 50:13 core 44:15 Corning7:14 15:2 33:19 correct63:14 cost 44:22 44:24 67:19 costing44:23 council 4:21 6:17 19:10counterproposal 54:21 country 21:25 26:20 38:18 County 63:2 couple 11:20 64:16 69:15 77:10 course 39:7 62:16POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 86

court72:15 cover 19:2 covered17:4 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 dealing14:23 19:25 60:24 75:20 dealt24:11 Debra 5:19 7:15 decent20:6 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 deferred67:18 definition 60:20 degree 32:3 deleo 5:8 5:9 5:11 28:9 28:9 Deleo 56:9 deliverables 74:20 deluding58:17 de-optimal 32:19 de-optimization 30:21 33:13 38:2 depending23:24 59:24 depends 60:18 64:22 described

46:25 description 47:9 deserving76:11 design 19:25 20:3 30:16 32:19 40:10 48:14 designing22:13 28:5 desire 26:10 detailed48:21 69:7 70:22POTW 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 determining12:10 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

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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 Dow5:15 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 draft50:1 51:17 drafted49:25 drain 19:20 drive 65:11 drop 64:17 64:18 64:21 65:2 Duke 48:23 Dumar 7:17 7:17 during9:18 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

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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 21:15POTW MONITORING July 24, 2012 Case Ref # 16859-1 Page 90

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