EPA Siloxanes (D4) ECA

Environmental Monitoring 

Program Update

SEHSC/EPA Meeting

July 15, 2014
Meeting Goals

• Update on SEHSC Progress 

• Overview of Program Challenges

• EPA’s Engagement with Resolving 

Program Challenges
Key Milestones

• Effective Date of ECA 4 Apr 2014

• Submission of the Study Plan 2 Aug 2014

• Submission of QAPP 1 Oct 2014

• EPA Approval of Study Plan 1 Oct 2014*

• Go-Live By Date for Monitoring 30 Nov 2014*

• Field Sampling & Analytical Complete 25 Nov 2015*

• Interim Reports due every 180 days

• Final Report 23 April 2016*

(* - estimate)
Progress

• SEHSC Funding Agreement signed 13 Jan 2014

• Contractor Selected: ERM & ALS Lab 7 Feb 2014 

• Lab Certification @ 2 Sites completion 22 Aug 2014

• Field Sampling Certification completion Sep 2014 

• Site Selection underway

• EPA Approval underway

• Site Access Agreements underway

 4 Direct Discharge Committed

 1 Industrial Committed

 3 Residential Committed

• Study Plan (4 Direct Discharge Sites) 2 Aug 2014

• QAPP (applicable to all 14 sites) 1 Oct 2014

Positive progress made so far, but there are challenges . . . .

1 year to select and secure access agreements with current 4 POTW sites
Round 1: Larger Facilities with Populations >60,000

POTW Sampling Candidate Site Selection

Start: 

May 2013

Jan 2014

Continued on next slide

ISTREAM POTWs - 10,422

Activated Sludge POTWs - 4,871 

Sites Serving a Population > 60,000 - 342

POTWs with a Dilution Factor <3 - 228

NEEDS 2004 POTWs - 16,583

Lowest Dilution Factor and Population by State - 64

+ 17 supplemental sites, some with D.F. <10 (total 81 sites called).

POTWs Contacted - 48

Qualified POTWs (No Combined Sewers, Receiving 

Water Type, Authorization, etc.) - 26

Residential

POTWs with <15% 

Industrial Influent 8

Industrial

POTWs with >15% Industrial 

Influent 9

33 backup 

sites 

remain
Residential

POTWs with <15% 

Industrial Influent 8

Industrial

POTWs with >15% Industrial 

Influent 9

Round 1: Larger Facilities with Populations >60,000

POTW Sampling Candidate Site Selection

Site Accepted 3+2 

tentative Sites Accepted- 2

Eliminated Due to 

Tertiary Treatment 1

Eliminated Due to 

Tertiary Treatment 4

Site Remaining -1 

(access agreement 

signed)

Site Remaining -1 

(access agreement 

signed)

Jan 2014

May 2014

Sites Declined- 3 Sites Declined- 7

Round 1 Results: 

2 signed access agreements 
Round 1: Status of Candidate POTWs

• Agreed to participate; signed the access 

agreement 

 Gresham, OR (Industrial)

 Lexington, KY (Residential)
ISTREAM POTWs - 10,422

Activated Sludge POTWs - 4,871 (~41% with tertiary treatment*)

Sites Serving a Population > 10,000 with a dilution factor <10- 1,070 

NEEDS 2004 POTWs - 16,583

POTWs serving >10,000 – 140 without identified issues **

Sites 

Initial contact 

made, but key 

contact still to 

be identified 

14

Response to Challenges – Increase No. of POTWs to Consider

Round 2: Smaller Facilities with Population >10,000

POTW Sampling Candidate Site Selection 

Start: 

April, 2014

Ongoing

*US EPA Clean Watersheds Needs Survey , 2008: Report to Congress 

**issues: 334 tertiary treatment, 167 sign. violations, 411 no ECHO data, 18 other eliminating conditions

Sites 

Contact Still 

Being Pursued 

98

Sites 

Signed 

Agreements 

2 

Sites 

Declined 

2 

Eliminated 

2 

Sites 

Further 

Information 

Requested 

22
Current Status of Candidate POTWs

• Round 1; agreed to participate and signed the access 

agreement 

 Gresham, OR (Industrial)

 Lexington, KY (Residential)

• Round 2; agreed to participate and signed access 

agreement

 Lafayette (Boulder), CO (Residential)

 Genesee, MI (Residential)
Remaining Pool of Candidate 

POTWs

• POTWs Needed

 4 Industrial

 2 Residential

• Remaining Pool of Potential POTWs From 

Rounds 1 and 2 

 167 POTWs 

 33 sites – need to be evaluated for the presence of tertiary treatment

 98 sites – no successful contact made

 14 sites – viable; only initial contact made

 22 sites – require additional information
Feedback on POTW’s Declining 

Participation

1. No derived value from participation

2. Increased burden from participation 

3. No resources to support participation

4. May trigger additional regulatory reporting from 

participation
What is the Projected Timing from 

POTW Agreement to Submission of Final 

Study Plan to EPA?

POTW Agrees to Participate

Site Visit

Development of Draft Study Plan

Member Comments Addressed

Final Study Plan for EPA Review

Signed Access Agreement

4 Months 

Total 

(projected)

8 weeks (typical)

2 weeks (typical)

2 weeks (typical)

2 weeks (projected)

2 weeks (projected)
Challenges

1. Completion of Site Selection/Access 

Agreements

 Securing signed Access Agreement with 

POTW’s

 Length of time needed against current timeline

2. Submission of “complete” Study Plan by

August 2, 2014

 Study Plan section for 4 Direct Discharge sites to 

be submitted by August 2, 2014
“Suggested” Options

• EPA assistance to encourage POTWs to participate

 Discuss options

• Study Plan extension - August 2, 2014 to April 2, 2015

• Other Options?
Next Steps