UNITED STATES

 ENVIRONMENTAL PROTECTION AGENCY

 SILOXANE TECHNICAL WORKING

 GROUP/POTW MONITORING

 U.S. ENVIRONMENTAL PROTECTION AGENCY

 1201 CONSTITUTION AVENUE, N.W.

 WASHINGTON, D.C. 20460

 AUGUST 7, 2012

 2:03 P.M.
MEETING Case Ref # 16194-6 Page 2

1 ATTENDEES:

2

3 ON BEHALF OF THE EPA:

4 MARCUS AGUILAR

5 BOB JONES

6 BRADLEY GRAMS

7 CATHY FEHRENBACHER

8 DAVID TOBIAS

9 JESSICA BARKAS

10 JESSICA BELL

11 JOE AVCIN

12 MARCUS AGUILAR

13 NHAN NGUYEN

14 PAUL LEWIS

15 TODD STEDEFORD

16 WARD PENBERTHY

17

18

19

20

21

22

23

24

25
MEETING Case Ref # 16194-6 Page 3

1 INTERESTED PARTIES:

2 BETSY CARLTON, BLUESTAR SILICONES

3 CYNTHIA A FINLEY, (NACWA)

4 DAVID POWELL, DOW CORNING

5 DEBRA MCNETT, DOW CORNING

6 ELLEN MIHAICH, BLUESTAR SILICONES

7 GARY KOZERSKI, DOW CORNING

8 HUGH FLACK, WACKER CHEMICAL CORP.

9 JAESHIN KIM, DOW CORNING

10 KARLUSS THOMAS, (SEHSC)

11 KATHLEEN P. PLOTZKE, DOW CORNING

12 KEVIN WEST, MOMENTIVE PERFORMANCE MATERIALS

13 LISA DUMAR, MOMENTIVE PERFORMANCE MATERIALS

14 LISA PERRICASE, WACKER CHEMICAL CORP.

15 PATRICK GRIFFITH, LOS ANGELES COUNTY SANITATION

16 PAUL DELEO, AMERICAN CLEANING INSTITUTE

17 RAY HILEY, MOMENTIVE PERFORMANCE MATERIALS

18 SCOTT DYER, PERSONAL CARE PRODUCTS COUNCIL

19 TRACY GUERRERO, (SEHSC)

20 TRENT DOYLE, (SEHSC)

21 WENDY KOCH, CONSULTANT TO EVONIK

22

23

24

25
MEETING Case Ref # 16194-6 Page 4

1 OTHER INTERESTED PARTIES PRESENT WITHOUT COMPLETE

2 NAMES/COMPANIES RECORDED:

3 KEN WOODBURN

4 DAVE ROBISON, PROCTOR AND GAMBLE

5 GEORGE LISCOE

6 JOHN KROGER

7 REBECCA GRAY

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
MEETING Case Ref # 16194-6 Page 5

1 U.S. EPA

2 SILOXANE TECHNICAL WORKING GROUP/POTW MONITORING

3 AUGUST 7, 2012

4 MR. PENBERTHY: I'll let you know who's on

5 the other end of the line. This is Ward Penberthy.

6 MR. JONES: I'm Bob Jones.

7 MR. NGUYEN: Nhan Nguyen.

8 MR. AVCIN: Joe Avcin.

9 MR. TOBIAS: David Tobias.

10 MS. FEHRENBACHER: Cathy Fehrenbacher.

11 MR. AGUILAR: Marcus Aguilar.

12 MS. BELL: Jessica Bell.

13 MR. PENBERTHY: I guess could we start, I

14 guess Marcus, why don't you call off the the names off

15 the list and if you're here, please respond with here.

16 MR. AGUILAR: Okay. All right, so I have

17 these are in no particular order, so if you can just

18 speak up when you hear your name. Betsy Carlton from

19 Bluestar?

20 MS. CARLTON: Yep.

21 MR. AGUILAR: Cynthia Finley from NACWA?

22 MS. FINLEY: Yes.

23 MR. AGUILAR: David Powell from Dow?

24 MR. POWELL: Yes.

25 MR. AGUILAR: Debra McNett from Dow?
MEETING Case Ref # 16194-6 Page 6

1 MS. MCNETT: Yeah.

2 MR. AGUILAR: Ellen Mihaich from Bluestar?

3 MS. MIHAICH: Mihaich, yes.

4 MR. AGUILAR: Okay, sorry.

5 MS. MIHAICH: That's okay.

6 MR. AGUILAR: Gary Kozerski from Dow?

7 MR. KOZERSKI: Here.

8 MR. AGUILAR: Hugh Flack?

9 MR. FLACK: Here.

10 MR. AGUILAR: Okay. Jaeshin Kim from Dow?

11 MR. KIM: Here.

12 MR. AGUILAR: Karluss Thomas?

13 MR. THOMAS: I I'm here.

14 MR. AGUILAR: Okay. Kathleen Plotzke?

15 MS. PLOTZKE: Here.

16 MR. AGUILAR: Okay. Kevin West?

17 MR. WEST: Here.

18 MR. AGUILAR: Patrick Griffith?

19 MR. GRIFFITH: Here.

20 MR. AGUILAR: Paul DeLeo?

21 MR. DeLEO: Right.

22 MR. AGUILAR: Ray Hiley?

23 MR. HILEY: Here.

24 MR. AGUILAR: Scott Belanger?

25 MR. BELANGER: Here.
MEETING Case Ref # 16194-6 Page 7

1 MR. AGUILAR: Scott Dyer?

2 MALE SPEAKER: He is not here.

3 MR. AGUILAR: Okay. Tracy Guerrero?

4 MS. GUERRERO: Here.

5 MR. AGUILAR: Wendy Koch?

6 MS. KOCH: Here.

7 MR. AGUILAR: All right. If you if I haven't

8 said your name, if you could please just go off one at

9 a time and state your name and, the party that you're

10 representing?

11 MR. ROBISON: Dave Robison. Proctor and

12 Gamble.

13 MR. GOLDSMITH: Mike Goldsmith.

14 MR. LEWIS: Paul Lewis, EPA.

15 MR. GRAMS: Brad Grams, EPA.

16 MS. DUMAR: Lisa Dumar, Momentive.

17 MR. STEDEFORD: Todd Stedeford, EPA.

18 MS. PERRICASE: Lisa Perricase, Walker.

19 MR. STAPLES: Carl Staples, MDHSC.

20 MR. LISCOE: George Liscoe at Trent Doyle

21 Keller & Heckman.

22 MR. KROGER: John Kroger, Personal Care

23 Product counsel.

24 MS. GRAY: Rebecca Gray, Dirst & Dunn

25 (phonetic).
MEETING Case Ref # 16194-6 Page 8

1 MS. BARKAS: Jessica Barkas, EPA.

2 MR. AGUILAR: All right. Is there anyone

3 else that hasn't said their name? Okay.

4 MR. PENBERTHY: Okay, you all should have

5 received a an agenda from Marcus as well as some copies

6 of, several documents, the SEHSC communication, from

7 last week. Also, you should have gotten a testing

8 proposal from EPA on ma- on the manufacturing

9 processing and formulation component of this. I guess

10 on the agenda, our first, portion of the meeting would

11 be trying to, discuss further the POTW monitoring

12 issues, specifically going through the SEHSC

13 communication, and also their feedback on our ideas

14 about testing around POTWs and then we'd follow that up

15 with the discussion of SEHSC's ideas around the

16 manufacturing and processing of formulating sites and

17 then, then our, perspectives on that from the EPA. As

18 I understand it, this working group is supposed to, try

19 to work together to, bring back, some kind of

20 recommendation or proposal to the formal negotiating

21 group, to consider, so ultimately, that's, the

22 intended, outcome of this meeting. So, we'll be

23 testing for that at the end of the meeting or at the

24 end of the different, discussions, agenda items, so,

25 before we go on to talking about the POTWs, is there
MEETING Case Ref # 16194-6 Page 9

1 any questions about the agenda or any or anything else

2 of that, nature?

3 MR. BELANGER: Yes, this is Scott, Scott

4 Belanger. There should have been an additional

5 document that was distributed a bit late, but coming

6 from PCPC regarding it it it's basically a build to the

7 SEHSC, responses.

8 MR. PENBERTHY: I'm not sure that we have

9 received that.

10 MR. BELANGER: All right. We sent it over

11 there today.

12 MR. PENBERTHY: Okay.

13 MR. BELANGER: So, our apologies if it was it

14 was late.

15 MR. PENBERTHY: Who did you send it to at

16 EPA?

17 MR. BELANGER: Itlucky COP Chubbs, II

18 (phonetic), it it went to oh, yeah, it was my mistake.

19 I I thought I had it on Marcus on here but I didn't.

20 So, I it's something that you did not receive.

21 Apologies for that.

22 MR. PENBERTHY: Yeah, because of that, we

23 won't be able to discuss it today.

24 MR. BELANGER: Yeah.

25 MR. PENBERTHY: Sorry about that.
MEETING Case Ref # 16194-6 Page 10

1 MR. BELANGER: Understand.

2 MR. PENBERTHY: Okay, anything else besides

3 that or should we proceed to, SEHC, document and, their

4 justification and rationale for the choices they've

5 proposed for POTW monitoring. Okay, Carlos, I guess,

6 the floor is yours for now. Or the line anyway.

7 MR. THOMAS: Okay. Thank you. Thank you,

8 Ward. thanks again to the EPA for organizing this

9 call. I, hopefully you guys did get the, the

10 officer's submission from SEHSC in that we provide a

11 pretty detailed summary and a technical review of the

12 rationale for the number of sites that we're selecting

13 for the POTW portion of the proposal. We also provided

14 some some feedback on the agency's what I'm calling the

15 factors document, but that's the document that was

16 circulated last week that was called Major Factors

17 Relevant to the Environmental Presence of Siloxanes,

18 and in addition to that, we provided some additional

19 perspectives on the on the EPA process so far, I'll

20 invite Kathy and her team to kind of walk through the

21 whole document sort of starting with the ERM Report and

22 then also the feedback on, the factors document. So,

23 sorry to put you on the, spot, Kathy. I think we can

24 do that quickly and then following that, we're we're

25 very eager to hear EPA's feedback on the on the
MEETING Case Ref # 16194-6 Page 11

1 submission.

2 MR. PENBERTHY: Yeah, Karluss, we did get

3 your document and we did spread it around. We've done

4 our best to evaluate it as quickly as we can in the, in

5 the three or two or three working days we've had, uh.

6 There's some aspects of it we've been able to, plunge

7 into more detail than others, but, I guess given the

8 extent of the the detail you provided, we haven't been

9 able to do what I would call a complete assessment of

10 what you sent, but we're going to do our best today.

11 MR. THOMAS: Okay. Fair enough.

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

13 I don't believe I've received that document.

14 MR. PENBERTHY: Okay, we can go ahead and

15 forward that to you, Cynthia.

16 MS. FINLEY: That would be great. Thank you.

17 MR. PENBERTHY: Do you want me to do it right

18 now?

19 MALE SPEAKER: Yeah, go ahead.

20 MR. PENBERTHY: I can do it now.

21 MS. PLOTZKE: Okay. Well, and what I was

22 gonna do is just kind of walk through so each one of

23 the attachments and maybe, give an overview of it and

24 then see if there are questions. I realize you maybe

25 haven't gotten into, great detail in looking at them,
MEETING Case Ref # 16194-6 Page 12

1 but then really kind of open it up for discussion. So,

2 the first document as Karluss indicated was a report

3 from ERN (phonetic) the consultant that have been

4 working with and really, their rationale and

5 justification for the selection of five wastewater

6 treatment sites. Thereagain, not identifying the

7 specific sites, but really just doing a power analysis

8 to assess what type of the reality as far as the number

9 of sites needed to really further validate the

10 conceptual site models that ERN had had done for us.

11 So, their their explanation they have walked through

12 that as far as how they've done their power analysis,

13 so I'll stop and pause here and see if there were any

14 specific questions around that and then build on the

15 rest of the pieces.

16 MR. PENBERTHY: This is comments on what

17 portion of the document? The the first the first

18 document?

19 MS. PLOTZKE: Yes, the yes, the report from

20 ERN was ERN, which is Recommendation of Number of Sites

21 to Sample for Validation of Z45 POTW Conceptual Site

22 Model.

23 MR. PENBERTHY: Okay, I guess, just to

24 start, you know, obviously, the conceptual site models

25 were an important component to develop for establishing
MEETING Case Ref # 16194-6 Page 13

1 what media need to be sampled in in in the monitoring

2 program. It's I don't think, and this is a theme that

3 runs through the document, I don't think the intended

4 effort of the monitoring program is to necessarily

5 validate the conceptual site model, but for our

6 purposes, it's the monitoring is meant to us to provide

7 information from which we could develop a risk

8 assessment. So, I think, the document sort of

9 basically, identifies a conceptual difference in the

10 goals between SEHSC and EPA and so, we'd initially want

11 to point that out right away.

12 MR. THOMAS: Ward, I think that the document,

13 in addition to noting that one of the goals was to

14 validate the conceptual site models, I think it's also

15 clear that the document points out that in addition to

16 that, the point is to also, provide additional

17 information on sources and pathways of D4 and D5 to the

18 environment, which could be used to support the risk

19 assessment. So, I don't think the agency's goals for

20 this effort are lost.

21 MR. PENBERTHY. I guess in that sense, not

22 completely lost, but, I guess it doesn't what, clearly,

23 and we've said this before several times, is that it

24 would be very ha- difficult for us to base a risk

25 assessment on such a limited sample size and, I mean,
MEETING Case Ref # 16194-6 Page 14

1 that's just an ongoing, difference that we have, and I

2 you know, you'll have to admit the statistical anal3 analysis is somewhat, is interesting but, you know, I'm

4 not sure that it would stand the test of, you know, are

5 we is this an appropriate design for a, a risk

6 assessment that's trying to give a national perspective

7 on siloxane environmental concentrations.

8 Cathy, you might do you have anything to add

9 to that?

10 MS. FEHRENBACHER: No.

11 MR. PENBERTHY: Okay, no. Okay.

12 MR. THOMAS: Ward, just to Ward, just to help

13 us out a little bit, are you are you able to provide a

14 little bit more detail with respect to specifically

15 what elements of the rationale don't allow you to

16 accomplish your goal of a risk assessment? What is

17 there something missing? Is there something I mean

18 beyond just not being able to use the number of sites.

19 Are there specific elements of the rationale that lead

20 you to the conclusion that something different might be

21 needed, because that's sort of what I'm struggling

22 with.

23 MR. PENBERTHY: Right. Well, in page eight

24 on the conclusions, it clearly states that that design

25 is, trying to establish a worst-case scenario and
MEETING Case Ref # 16194-6 Page 15

1 that's not our objective.

2 MS. PLOTZKE: I guess just one of the

3 questions that that I had concerning obviously, that

4 that is one of the the questions that that are

5 different than they should say that we have in from an

6 approach standpoint is the worst case scenario and they

7 way we look at it is, if you do a worst case scenario,

8 in particular with the data set, that's one of the

9 things we tried to demonstrate in the other attachment

10 on the benthic risk assessment, looking at this where

11 we have monitoring data data from around the globe, so

12 global monitoring data that was already done basically

13 looking at, a risk assessment approach in the data and

14 actual real data that you have which shows there is no

15 risk associated with the concentrations that we're

16 finding in the multiple places around the globe,

17 including some here in the United States or others that

18 will be similar to the United States, that the usable

19 worst case approach, then may be appropriate to

20 identify and verify here within the United States that

21 you're not going to have any situation that's really

22 different than what we've already done.

23 MR. PENBERTHY: Well, you do mention that

24 the monitoring data that you presented, specifically in

25 Table One of, let me see, that's Attachment, is that
MEETING Case Ref # 16194-6 Page 16

1 Attachment Three?

2 MR. AGUILAR: Yeah, Attachment Three.

3 MR. PENBERTHY: you know, many of these data

4 are from different countries. A great or a majority of

5 them are from, sea water samples. I think the Lake

6 Pepin data is, well, we don't fully understand the

7 circumstances of the monitoring, but, from what we

8 understand are very remote from any source of

9 siloxanes. I mean, the only data that looks like it

10 might, have some relevance to this exercise would be,

11 and I might maybe I'm over-sighting. Maybe it's not

12 the only data. All of the data is relevant, I suppose,

13 but the most interesting data would be from what's the

14 Wang, et al. data and that's eleven different sites,

15 but So, I don't think the data that's been presented is

16 is, sufficient for us to develop the kind of

17 conclusions that you you suggest.

18 MS. PLOTSKE: I I think that I I think, you

19 know, we can talk a little bit more if you'd like to

20 understand the specifics around some of the sites.

21 Dave Powell is here, as well, to talk about that,

22 particularly Lake Pepin, but I guess one one aspect of

23 it, and I understand that this is not this is not data

24 that is going to replaceor is in, you know, basically

25 we're suggesting that you look at not any other
MEETING Case Ref # 16194-6 Page 17

1 monitoring data, but what we are suggesting is that

2 when you take a look at this data set and you apply

3 certain factors. Yes, some of it is sea water, but not

4 all of it. Some of it is fresh water. Some of it is

5 area by park, if not exactly in the United States but

6 similar to the United States and that combined with our

7 extensive knowledge around these materials and how they

8 behave, we really feel confident you can go out and

9 predict this kind of behavior with these materials and

10 so by having these five additional worst case sites in

11 the United States, it really verifies and validates

12 that approach.

13 MR. PENBERTHY: Yeah, I'm sorry. We just

14 can't agree with that.

15 MS. PLOTSKE: So, I guess, can you help us

16 understand why you don't agree with that?

17 MR. PENBERTHY: Well, I think I just said

18 that they don't they're from different countries.

19 They're from mostly or many of the majority of the data

20 is from sea water, you know, would it how close is the

21 nearest source to Lake Pepin is? I think it's over

22 sixty miles, I mean, so, you know,

23 MR. THOMAS: Eight kilometers. That's

24 straight.

25 MR. PENBERTHY: Well, whatever. It's still,
MEETING Case Ref # 16194-6 Page 18

1 we don't believe it's representative data for us to

2 develop any kind of conclusions along the lines you

3 suggest.

4 MR. THOMAS: Well, if if I may just add here,

5 I think what you're touching upon is the whole issue

6 with concentrations in sediments are going to be a

7 function of distance away from the waste water

8 treatment plant. Is that correct?

9 MR. PENBERTHY: I think that's a logical

10 connection that most people would come to, don't you

11 think?

12 MR. THOMAS: I would hope so, yes. So, from

13 that perspective alone, why could they why could you

14 not go to a well-selected worst case area and sample

15 the sediments in that area confined study area such as

16 was done for Tokyo Bay, and that way you you will find

17 a bracket the range of concentrations that will exist

18 in sediments across the nation?

19 MR. PENBERTHY: Well, we're just not

20 interested in a worst-case assessment. We'd rather

21 have

22 MR. THOMAS: That's not what I'm saying.

23 I'm not saying a worst-case assessment, but you can go

24 to a worst-case area and sample that area and you will

25 get concentrations that range from the low detection,
MEETING Case Ref # 16194-6 Page 19

1 up to the highest concentrations possible. That by

2 definition will bracket every concentration you can

3 find across the U.S.

4 MR. PENBERTHY: I just don't see the data in

5 that table as representative of U.S. situation.

6 MR. THOMAS: Well, would you would you say

7 that Tokyo Bay is similar to, San Francisco Bay?

8 MR. PENBERTHY: Okay, I think on that

9 MR. THOMAS: On that isthey both have salt

10 wedges.

11 MR. PENBERTHY: on the

12 MR. THOMAS: They both get significant

13 amounts of treatment.

14 MR. PENBERTHY: Okay, I think on your sites

15 that have been proposed for monitoring, I don't think I

16 saw a single site that was to sea well, there's one

17 site to sea waters, I believe. So, the sea water

18 sites, you know, while they're I mean, it it's

19 interesting data but it's not the circumstances that

20 we, seem to be trying to obtain monitoring data for.

21 MR. THOMAS: So, your only focus is on fresh

22 water environment.

23 MR. PENBERTHY: Well, that's our primary

24 focus because that's the primary location of your

25 facilities, the primary location of most, the great
MEETING Case Ref # 16194-6 Page 20

1 fraction of the POTWs in the United States, and if

2 we're trying to establish a range of concentrations in

3 the environment in the United States, that would be,

4 you know, a logical thought, I would think.

5 MR. WEST: Ward, this is, Kevin West from

6 Momentive. I'll readily admit I'm not as

7 scientifically inclined as some of my colleagues, and I

8 don't want to beat a dead horse here, but we're

9 mentioned a couple of times worst-case scenario on

10 range of, distribution, etc. and I have to try to

11 explain to my management who's less scientifically

12 inclined than I am why have if the risk is zero in a

13 worst-case scenario, why would we want to go out and

14 spend, you know, 10x number of dollars to show that the

15 risk is somewhat less than zero.

16 So, maybe if we could at some point in

17 today's conversation try to put that in three syllable

18 words or less so I can explain it to my management why

19 we would want to quantify a risk less than zero and why

20 a worst-case scenario wouldn't be the screening

21 assessment that we would do first, before we do a deep

22 dive and what value a range of, concentration, gives to

23 you what what, what value does it give to you and

24 whatever use it is up for you because I guess I could

25 have a hard time trying to explain that to my
MEETING Case Ref # 16194-6 Page 21

1 management, so if you could help me out there, I could

2 apprec I would appreciate it.

3 MR. PENBERTHY: Right. Well, I guess the

4 major concern that we would have is how would we know

5 beyond a theoretical basis that in fact the sites

6 selected are the worst case, so there's no guarantee,

7 despite the fact that I think the factors that we think

8 are important to use to select, facilities or sites to

9 monitor would would probably encompass worst cases.

10 There's there's no guarantee until you do take the data

11 and in fact what you've done is is actually captures

12 it. So, so, basically, you know, designing a program

13 about what people intuitively think would be the worst

14 case, you know, doesn't necessarily give us enough

15 confidence that the data is representative or, even,

16 relevant to, a risk assessment.

17 MR. THOMAS: Ward, this is Karluss, and just

18 to kind of continue with that with that point, you

19 mentioned that the Wang, et al. data was probably the

20 most interesting, and I'm just wondering if the Wang,

21 et al. data coupled with the Oregon data, which I think

22 there you had fifty plus sites. I realize all of them

23 were non-detects but I'm just wondering with the fifty

24 plus sites from Oregon, coupled with the eleven sites

25 from the Wang, et al. study in Canada, that gives you
MEETING Case Ref # 16194-6 Page 22

1 greater than sixty sites.

2 MR. PENBERTHY: Do we have the

3 MR. THOMAS: So, is it your view that sixty

4 sites wouldn't be sufficient to allow you to determine

5 what the worst case scenarios might be?

6 MR. PENBERTHY: It's only the (parties

7 speaking over each other)

8 MR. THOMAS: That's certainly more than the

9 forty-two that you just

10 MALE SPEAKER: levels and the detection level

11 was higher than we would like it to be. I explained

12 that.

13 MR. PENBERTHY: Yeah, I don't I don't well,

14 first of all, I don't know that or I don't know if we

15 certainly don't know enough about the details of the

16 circumstances in which the Canadian data were were

17 gathered. For instance, what the POTW configuration,

18 what were the flow rates, what were the conditions of

19 sampling the the standard stuff that you would have in

20 a in a rigorous monitoring program, and there are

21 certain problems with the the Oregon data and David,

22 maybe you can further explain.

23 MR. TOBIAS: Well, for the Oregon data, the

24 only the F1 level is given, I think, from the paper

25 and, the limit of detection for that paper is over what
MEETING Case Ref # 16194-6 Page 23

1 the agency's concern level is, and there are no

2 sediment levels given for that paper, which I think

3 SEHSC has also verified as being the media where it's

4 persistent. So, of one sample grab, I think, at fifty5 two sites, where the purpose of the monitoring program

6 was definitely not to go out and evaluate siloxane.

7 The the program started from a different direction than

8 that, and that seems a big jump to take when the the

9 data that even you, agree is the is persistent in the

10 sediment.

11 MR. THOMAS: Right, no, agreed, but I I

12 thought we were talking about determining what the

13 worst case scenarios were.

14 MR. PENBERTHY: Yeah, we're not interested in

15

16 MR. THOMAS: and I wasn't

17 MR. PENBERTHY: determining the worst case.

18 We want to establish what the range is and and what the

19 variability is and what the relative contributions are

20 of different factors to Siloxane's coming out of POTWs.

21 MR. TOBIAS: The the other point is that in

22 the Oregon paper, they they point out that Oregon has

23 no history of the chemical industry present in their

24 state, which is is another point against that data

25 being too heavily weighed. So, that is not a factor
MEETING Case Ref # 16194-6 Page 24

1 that would be true across the rest of the country, and

2 our our problem with the Canadian data, as Ward started

3 to indicate, is that they had to grant confident- or

4 anonymity to all of the sites, so to some degree, you

5 can learn some about how to connect these to what what

6 would create risk and how to select worst case, but but

7 it's not clear because they had to grant con- anonymity

8 or confidentiality to these sites.

9 MS. PLOTSKE: But I guess the other question

10 that I have about getting looking at the getting a

11 range and understanding that range, is how how do you

12 plan how why you think it's the right way to get that

13 range, even with forty-two sites? How do you define a

14 sampling program to really understand that range?

15 MR. PENBERTHY: Well, I think what we tried

16 to do is, develop a sampling program that would logic

17 that tries to base on a scientific logic, what would be

18 the likely biggest contributors to Siloxane releases in

19 at from various POTWs, and then test each of those

20 factors using that design tool in in which is tries to

21 make it as efficient as possible, you know, obviously

22 we've asked for feedback, and I I would like to get to

23 your feedback on some of our factors, which I think is

24 very helpful, and some of your comments tend to,

25 resonate with the proposal that we make, quite frankly.
MEETING Case Ref # 16194-6 Page 25

1 So, but, you know, that was our approach, so.

2 MS. PLOTSKE: I, so I guess, I mean, I think

3 the biggest the question and from our experience and

4 knowledge and it it really looking at the how you do it

5 sampling program, and understanding the range of

6 materials, the the towns you're going to pick, so if

7 we're in agreement that the farther you get away from

8 the source, the impact it's going to have an impact on

9 the condensation, but you could look across that whole

10 range for one site. That range won't be different for

11 one site across the whole nation. So, you you could

12 spend time monitoring forty-two sites and you will

13 encompass the range with one site.

14 MR. PENBERTHY: I I don't think I understand.

15 MS. PLOTSKE: Well, I just want what I'm

16 trying to understand is, what more information does

17 that really give you to do a risk assessment if you

18 don't understand that range overall by just giving one

19 site.

20 MR. PENBERTHY: Well, clearly the more sites,

21 the less uncertainty in your analysis. Would you agree

22 to that?

23 MALE SPEAKER: It depends on the number of

24 samples taken at each site.

25 MR. PENBERTHY: Well, I mean, if you
MEETING Case Ref # 16194-6 Page 26

1 MALE SPEAKER: If you if you were to monitor

2 just sediment, would you monitor in the zone of initial

3 dilution? Would you monitor a hundred meters

4 downstream from that zone? Two hundred meters? A

5 kilometer?

6 MR. PENBERTHY: I don't think we've even

7 begun to talk about this issues. We're just trying to

8 MALE SPEAKER: Well

9 MR. PENBERTHY: talk about how many sites.

10 MALE SPEAKER: That's a consideration,

11 though.

12 MR. PENBERTHY: Well, I definitely agree.

13 MALE SPEAKER: I could tell you I can tell

14 you based on how you've expressed concerns about Lake

15 Pepin. I understand that. I can also tell you that if

16 you go look at published monitoring data on other

17 materials, PCBs, metals, organic chlorines, what you

18 find is that in the Mississippi River, the greater

19 concentrations of those materials are current in Lake

20 Pipin, which is eighty kilometers downstream from the

21 source. That's a function of deposition. It's a

22 function of the rate of flow from, the Mississippi

23 River. Basically what you have in the upper part of

24 the river is along the scour, not much in the way of

25 deposition zones, and Lake Pepin is serving as a trap.
MEETING Case Ref # 16194-6 Page 27

1 MALE SPEAKER: Okay, directly, go ahead.

2 MR. PENBERTHY: David has a point.

3 MR. TOBIAS: Well, I'd I'd just like to make

4 a I I I don't actually have detailed knowledge of the

5 the range of contaminants along the Mississippi River,

6 but the Mississippi River is a very large river,

7 obviously, with many, many inputs, but we're concerned

8 about all kinds of different watersheds in the United

9 States at the EPA, not just the largest one in the

10 country. So, I don't I don't understand just comparing

11 it to the Mississippi River.

12 MALE SPEAKER: I I understand that. My point

13 is, if you go to a site, where you going to where where

14 you going to sample? If you go to biggest Minneapolis,

15 St. Paul happens to be one of the recommended areas to

16 go to, where would you sample?

17 MR. PENBERTHY: Adjacent to a POTW

18 (MULTIPLE PERSONS SPEAKING OVER EACH OTHER)

19 MR. TOBIAS: You you'd want to you'd want to

20 sample near the outfall.

21 MR. PENBERTHY: Near the outfall.

22 MALE SPEAKER: Why?

23 MR. PENBERTHY: Because

24 MALE SPEAKER: The highest concentrations are

25 eight tall or seven straight.
MEETING Case Ref # 16194-6 Page 28

1 MR. TOBIAS: You you're

2 MALE SPEAKER: and sevens.

3 MR. TOBIAS: You you're saying you also have

4 monitoring data in Minneapolis, St. Paul for these

5 chemicals? Is that what I thought there wasn't

6 monitoring data. You're just saying in general.

7 MALE SPEAKER: Not for the Siloxane but for

8 classes of other materials.

9 MR. PENBERTHY: Well, I mean, but you propose

10 a hypothetical and there's no way that we can argue

11 that because you don't have data. We don't have data.

12 So,

13 MR. TOBIAS: But just initially from the

14 Canadian data, they found higher levels than at Lake

15 Pepin, so that means higher levels are possible for

16 sure and there's where the monitoring was done at the

17 outfall.

18 MALE SPEAKER: I'm not disputing that.

19 MR. TOBIAS: Okay.

20 MALE SPEAKER: I'm not disputing that aspect

21 of it. What I'm saying is, Lake Pepin does not

22 represent a worst case scenario. You said you're not

23 interested in the worst case scenario, and Lake Pepin

24 appears not a worst case scenario.

25 MR. TOBIAS: Yeah, it
MEETING Case Ref # 16194-6 Page 29

1 MALE SPEAKER: What it does represent is it

2 shows you the variability associated with the sediment

3 and the function of the the flow regime of the

4 receiving waters and the distance, and I can tell you

5 that based on other sediment or contaminants, the

6 higher concentrations occur at Lake Pepin. They do not

7 occur at the point of discharge.

8 MR. PENBERTHY: Okay, well

9 MALE SPEAKER: Those are too high.

10 MR. PENBERTHY: Maybe your dat- maybe the

11 Lake Pepin data deserved to be included in evaluating

12 within a risk assessment, but clearly, we need data, as

13 we said, near the outfall of the POTWs.

14 MR. THOMAS: Well, Ward, would it be

15 worthwhile now to just kind of go into the feedback on

16 your factors documents. You mentioned you guys were

17 interested in hearing that feedback. You thought it,

18 helped with some of your considerations. Would it be

19 worthwhile now to kind of start to walk through that?

20 MR. PENBERTHY: Yeah, please, go ahead.

21 Attachment two.

22 MR. THOMAS: Okay.

23 MR. AGUILAR: I think I'd pick up many

24 places, actually, that were (Inaudible).

25 MR. THOMAS: Kathy, I'll let you walk
MEETING Case Ref # 16194-6 Page 30

1 through that one, as well.

2 MS. PLOTZKE: Okay, I'm going to turn that

3 over to Jaeshin Kim.

4 MR. KIM: Would you give out the section

5 five. Hi, this is Jaeshin Kim. Okay, so I would like

6 to I discuss the major factors that might be used for

7 the, the optimal approach for the D-optimal design

8 [Inaudible] and well, obviously we all agree that we

9 need to way to find a a very good reason to select why

10 we are focused important criteria, and so I select

11 three criteria to select the major factors and then I

12 give you the six factors proposed by Jay and then I

13 really consider or look at factor and then I propose

14 the right ones again.

15 The first criteria is the detector should be

16 influence the output, obviously, and then second one is

17 selective detector should be independent of each other

18 and then the third criterion would be the quantitative

19 detector should be long and prior to the monitoring

20 program.

21 MR. TOBIAS: Excuse me, Jaeshin, sorry. Just

22 a, a point of procedure here. I think you're actually

23 talking about Attachment Five, right? What is it?

24 MR. PENBERTHY: Yeah, that is Attachment

25 Five.
MEETING Case Ref # 16194-6 Page 31

1 MR. TOBIAS: Yeah.

2 MR. KIM: [Inaudible].

3 MR. TOBIAS: No, that's fine. He can go

4 ahead.

5 MR. KIM: I sent you a text with the

6 Attachment, Attachment Five.

7 MR. TOBIAS: Yeah, I just so everyone knows

8 where

9 MR. KIM: Okay.

10 MR. PENBERTHY: So, can can just to summarize

11 the three criteria that you're looking at is the the

12 input of siloxanes to the POTW, the treatment method

13 and then the the dilution factor into the receiving

14 stream?

15 MR. KIM: Right, right, so, you know, well

16 overall the population is, does not influence the,

17 concentration of the D4 and D5 in the effluent and the

18 temperature does not dictate that much, and also the

19 receiving water flow does not correlate the contents

20 used in but, instead of these factors, we propose to

21 use the dilution factor, okay, and then and then we

22 found that based on the physical properties, that the

23 the efficiency of the Siloxane removal and and those

24 the different concentration is very related to the

25 treatment type, so every every load that siloxanes is
MEETING Case Ref # 16194-6 Page 32

1 very volatile and is very absorptive to the suspended

2 particles and when at the time the wastewater enter the

3 the POTW, it's already equlibrated thoroughly, and

4 thenso the additional removal will be done by the

5 aeration or volatization during the treatment, and we

6 also know that the activated sludge system used a lot

7 of aeration so it, remove the siloxanes from the third

8 phase eventually to the air compartment and also the,

9 the concentration, compared to the lagoons or the

10 activated sludge system produce less total solids

11 concentration, compared to the lagoons or the pond, so

12 overall, the different concentration is very related to

13 the treatment type. So, we better suggest that the

14 three levels of treatment type might be a better one.

15 Each represent the older treatment and and then, okay,

16 this additional factor with two lagoons, which

17 represents the receiving environment, and and then, I

18 also know database about the organic contents of the

19 receiving body nationwide, so it's very hard to include

20 the [Inaudible] data in the input, so I think overall

21 treatment type with the three levels and dillution

22 factor with three levels might be better important

23 factor to accept the D4, D5 siloxanes monitoring.

24 So, overall, I think that this combination

25 might be a proper way for the monitoring plan. Any
MEETING Case Ref # 16194-6 Page 33

1 questions?

2 MR. PENBERTHY: Yes, just a just a few.

3 Obviously, we agree that the a logical way to,

4 understand that the the amount of input of siloxanes to

5 the POTW's important. That was the intent of our

6 population size, so I guess, you're in your concept,

7 again, you're going at it a little bit from the worst

8 case again where you're trying to pick, as I understand

9 it, you know, pick pick only POTWs with high siloxane

10 concentrations in their feed to test in that six

11 component matrix. Is that correct?

12 MR. KIM: Yes.

13 MR. PENBERTHY: Now, how would you determine

14 which POTW is a high concentration in the feed? I

15 mean, we we, thought that, and this was on the advice

16 of people in our office of water who deal with POTWs

17 that population was a big factor in that. How would

18 you est- identify, the high input POTWs?

19 MR. KIM: I think from the NPDS database, we

20 know population served to each POTW and also we know

21 the incoming flow rate. So, I would consider the low

22 in incoming flow rate for the population. It takes

23 would be the logical high load important thing to POTW.

24 MR. PENBERTHY: So, let let me just

25 understand it. You would basically pick POTWs, serving
MEETING Case Ref # 16194-6 Page 34

1 high populations that receive a low flow to establish

2 your high input POTW?

3 MR. KIM: Yes.

4 MR. PENBERTHY: Okay.

5 MR. BELANGER: This is Scott Belanger. I I'm

6 gonna add a point in here that it is it is not trivial

7 and this is actually a a substantial well-known

8 analysis and factor in in how consumer product

9 chemicals are evaluated for their environmental risk,

10 and this goes directly to historical pre-manufacturing

11 notification assessments, or, existing assessments of

12 typical, typical consumer product chemicals, whether

13 they be triclosan or or surfactants or telators, D4, D5

14 falls in here, but the fact is with population size,

15 that it's relatively independent of the influent

16 concentration, and and the reason is quite simple.

17 With increasing population size, one has, an increased,

18 ingoing dilution volume from people using water in

19 their homes.

20 So, as a result, influent concentrations, to,

21 a particular treatment facility, are are very simply

22 scaled by those off-site factors that are they you may

23 have now differences of, you know, a factor of twenty24 five or thirty percent here or there, but that is more

25 likely, associated with other things like overflows or
MEETING Case Ref # 16194-6 Page 35

1 or other factors. So, these are typically handled as

2 pretty easily, scalable and predicted influent

3 measurement,

4 (Multiple people talking)

5 MR. BELANGER: that's why population served

6 MR. PENBERTHY: And then you [Inaudible] the

7 low population. I thought we had

8 (Multiple people talking)

9 MR. BELANGER: doesn't necessarily translate.

10 Our largest concentrations aren't necessarily in the

11 largest city.

12 FEMALE SPEAKER: How do you know [Inaudible].

13 MR. KIM: I agree. It's my bottom point, but

14

15 (Multiple people talking).

16 MR. PENBERTHY: Okay, well, as I understand

17 your proposal. I guess we had population just by

18 itself and you're saying that the combination of

19 population and flow rate might be a better way to

20 establish the input of siloxanes.

21 MR. KIM: Yes.

22 MR. PENBERTHY: Okay. So, I understand that

23 that, you know, we're going to need to discuss that. I

24 think if we were trying to establish the range of

25 concentrations, then logically speaking, if we follow
MEETING Case Ref # 16194-6 Page 36

1 your proposal here, a low population high flow would

2 get the low low number, right?

3 MR. KIM: Right.

4 MR. PENBERTHY: Okay. Let's keep going.

5 MR. KIM: Okay, then. So, from the

6 monitoring results, we assume that the removal is

7 relatively the same then, we can predict the lower

8 effluent concentration from the lower input.

9 MR. PENBERTHY: The one thing question I had

10 was I know your comment is all organized around

11 concentration, but you know, if you have a a very high

12 flow at a low concentration, you still get a high

13 loading in terms of pounds, in terms of mass, and and

14 and then there's as larger mass goes through say the

15 POTW is so you know, ninety-five percent efficient in

16 extraction, you know, the five percent of the large

17 number could be still be a large number. So, the

18 concentration's not really the only factor you have to

19 consider.

20 MR. KIM: Could you please elaborate again?

21 I couldn't hear the last part.

22 MR. PENBERTHY: Well, I mean, the commentary

23 that you make is very focused on concentration

24 discussions, saying that, you know, the concentration

25 in is an important factor in the feed, but you know, I
MEETING Case Ref # 16194-6 Page 37

1 think also the total mass going to the POTW is

2 important, too, because say you have a very large flow

3 rate and a relatively small concentration in terms of

4 mass going through the POTW, of Siloxane. It still

5 could be a very, very large number that that eventually

6 doesn't get treated and goes out the effluent.

7 MR. KIM: But I I don't think the total mass

8 is not our primary concern, although it it we are we

9 are aware of that factor, but the environmental level

10 is our primary concern, is my understanding.

11 MR. PENBERTHY: What's our primary concern?

12 MR. TOBIAS: Concentration that the parts per

13 million and parts per billion.

14 FEMALE SPEAKER: That that's that's what

15 we've been focusing on where you've indicated the

16 concentration of these materials.

17 MR. PENBERTHY: Okay, but how do you but what

18 happens if you get, you know, a large mass going out

19 the effluent, large mass gets absorbed to the sediment

20 and concentration builds?

21 FEMALE SPEAKER: You're not going to be able

22 to build, I mean, from a I mean, you've got some other

23 factors that play into the the fate and distribution of

24 these materials that you're not going to get like this

25 level of concentration greater than what you can
MEETING Case Ref # 16194-6 Page 38

1 achieve from a solubility standpoint.

2 MR. PENBERTHY: Okay, well, I think maybe we

3 should move on to discussing the treatment types. I

4 guess from what I understand in your commentary, you

5 like the activated sludge, the trickling filter, and

6 the lagoons as the treatment types that you would need

7 to monitor.

8 MR. KIM: Yes.

9 MR. PENBERTHY: Okay. I guess I need to

10 understand your concept of the dilution which is, well,

11 that's the ratio of the F1 flow rate to the flow rate

12 of the receiving river?

13 MR. KIM: Yes, that's correct.

14 MALE SPEAKER: It's not rate if well, I I

15 guess it it's it's it's rated if you're considering

16 that in terms of volume per minute, yeah. Probably

17 should digress away from changing it.

18 MR. PENBERTHY: How is that different than -

19 hold on a second. We need to discuss here for a

20 second. How is that different than is that a better

21 (Multiple people talking).

22 MR. KIM: that the siloxane concentration in

23 the receiving water body will be higher than the other

24 case, and and then also based on the NPDS data, and

25 there are very wide range of distribution and my
MEETING Case Ref # 16194-6 Page 39

1 understanding is the median value is around two with a

2 dilution factor of 200. So, then I assume for the

3 stream water environment, it should factor in terms of

4 the dilution factor. So, I think this factor is very

5 important to represent the environment of the receiving

6 water body.

7 MR. PENBERTHY: Okay, so I understand then as

8 a result of that analysis, then you would have a

9 assuming that you would pick monitoring only for a high

10 input POTWs, you would test activated sludge trickling

11 filter at lagoons both at high dilution rates and low

12 dilution rates. Well, that would basically be a raft

13 of six POTWs monitored.

14 MR. KIM: Yes.

15 MR. PENBERTHY: Okay, well, I understand your

16 comment, and do you all have any anybody else have any

17 EPA have questions about that?

18 MR. TOBIAS: I, yes, I'll make a couple

19 comments. This is David Tobias. The point about

20 population that that is I think something we need to

21 look at a bit more, because I think when they look at

22 sludge levels, they do see a difference connected to

23 population for commandment levels. So, that would

24 indicate that there is a component that's determined by

25 the total mass input. So, we'll have to do some more
MEETING Case Ref # 16194-6 Page 40

1 looking into that, so so to completely see how to

2 evaluate what the relative merit of these different

3 parameters is.

4 But for the second point when on geography on

5 Jaeshin's here, is that by the time you get to the end

6 of your criteria, you've you've removed any impact you

7 think from the local environment at all whether that be

8 geography, temperature, the organic content of the

9 receiving body, what watershed it is, whatever that

10 that seems to be difficult to assume that you can wipe

11 all of that away and still say that you could, either

12 understand the range or the worst case independent upon

13 which one you think you're going out to to measure when

14 you've as Dave Powell just pointed out, there are local

15 affects that come into play when you when you get rid

16 of all of those factors, you've got no back up to think

17 about how any local local variability will go on.

18 It so it it it seems it seems like it's it's

19 it's making the environment seem a lot more near than

20 than the reality, how messy the environment is, and the

21 so I I I see the points for the the total suspended

22 solids and the organic content you've made, but I I

23 think you you wipe away the organic content because you

24 say that they're not a good database for it but the I

25 it it seems hard to me to accept that there there
MEETING Case Ref # 16194-6 Page 41

1 should be no no no information about the local

2 environment in terms of determining how many sites or

3 what kind of sites you're going to measure.

4 MS. FEHRENBACHER: I I think that the

5 challenge is that there's no there's no information in

6 databases that allow you to pull that information out.

7 It's like on organic carbon content in the sediment of

8 the receiving body, you would measure that, and factor

9 that into the results that you have, but there's no way

10 to go in and say what that organic carbon content is

11 and the water, the surface water area in the United

12 States and then use that as a parameters, so it's not

13 that it won't factor into your end result. You can't

14 use it as a parameter for selecting a site.

15 MR. TOBIAS: I think that there might not be

16 exact information for what organic content would be,

17 but I think that if you wanted to think about a range

18 of organic content would be, as you pointed out, I

19 mean, the Hudson River would be very different than a

20 water body in the southwest. You can't know exactly

21 for sure before you design the program what that

22 measured value would be. I agree, but to say that you

23 have no ability to even put it into different scales

24 for different rivers, that sounds extreme.

25 MALE SPEAKER: Well, in my sense of this and
MEETING Case Ref # 16194-6 Page 42

1 this kind of unfortunately circles back to some of the

2 earlier discussion about what it takes, then, to really

3 factor that in properly. Of course, we know that

4 organic carbon has a high seasonal dependence. Water

5 bodies that are large, may have different levels of

6 variability than water bodies that are smaller and have

7 a more like variance zone associated with them, and it

8 gets into very much this idea that what the goal of,

9 of, of a monitoring effort would be and in the end,

10 those annual or local variations are so large, our

11 experience is exactly what Kathy just indicated that

12 you factor it in by understanding what organic carbon

13 is like in the site or sites that you eventually choose

14 so that you can appropriately account for it in the

15 evaluation of the physical chemical properties and

16 measurements in biota.

17 So, I think it's not that the fact that the

18 we think it's unimportant. It is important. It's that

19 there are other ways to factor that in.

20 MR. PENBERTHY: Exactly what would those

21 other ways be, do you think? How would be the best

22 way?

23 MR. TOBIAS: It would be a parameters just

24 like any other that you would need to monitor,

25 especially in SITU that would allow you to have a
MEETING Case Ref # 16194-6 Page 43

1 sense for what variability actually is at a given site.

2 To do that top priority, you know, perhaps

3 you might, you might try, but the fact is that the

4 information simply is not out there to allow you to do

5 that well.

6 MR. PENBERTHY: Now if that's the case and I

7 sort of understand your comment, does that mean if

8 that's not a factor for selecting a specific site, does

9 that mean you would have to monitor more sites to make

10 sure that you had data points that covered that

11 variability?

12 MR. TOBIAS: I think this probably goes back

13 to that concept, my understanding, you'd add a site

14 that you do choose to monitor allows you to address it

15 and it is a ... because this is a physical property

16 driven thing, our sense has always been that you could

17 always adequately account for it that way.

18 MR. PENBERTHY: But the straight-up ...

19 MR. TOBIAS: Knowing that a discharge is in a

20 region of high organic carbon is useful in

21 understanding the context at that site, but it's going

22 to be very difficult to extrapolate beyond that.

23 MR. PENBERTHY: Okay, so to get a straight-up

24 comparison, you would need, say, say you were taking a

25 high population, low flow POTW on activated sludge at a
MEETING Case Ref # 16194-6 Page 44

1 specific effluent rate as our dilution ratio, then

2 you'd want data with roughly the same values for those

3 factors, but different only how much suspended solids

4 in the receiving stream? Is that how you would do

5 that?

6 MR. TOBIAS: I'm not sure I exactly follow,

7 except I return to the big, big factor here, factors,

8 will always turn out to be treatment type and local

9 dilution.

10 Another thing to consider in this is whether

11 we really believe that competitive interactions between

12 effluent solids because the compounds are not going to

13 be in the aqueous phase, so for organic carbon to

14 become a very important factor, important enough to

15 raise up to the level of designing a study around, we

16 would have to have, we would be adopting the view that

17 organic carbon is going to be more competitive for D4

18 D5, than effluent solids would and I would actually,

19 would have a hard time believing that.

20 Equivalent, yes. If there was more D4 D5 in

21 the aqueous phase, I could imagine that if we go that

22 way, but this would be ignoring a lot of the physical

23 property information that exists.

24 (WHEREUPON, there is background discussion

25 while phone is muted. The following segment is spoken
MEETING Case Ref # 16194-6 Page 45

1 over the phone discussion.)

2 MR. PENBERTHY: No, I understand what they're

3 saying, it's just ...

4 MALE SPEAKER: There's more to it than just

5 (Inaudible).

6 MR. PENBERTHY: There's a competition between

7 sludge and suspended solids. Lined-up as the sludge, I

8 guess.

9 MALE SPEAKER: We've determined that that

10 wasn't a killer, killer factor for us, right?

11 MR. PENBERTHY: I was just pointing out that

12 they've gotten rid of the nickname that, that's a site.

13 I mean, like the total suspended solids that are in the

14 carbon geography, those, they talked about where, and

15 they just like blowed us off.

16 MALE SPEAKER: Yeah, but I think the way you

17 handle the solids is that you get enough samples that

18 you have a facility that has high solids.

19 I can understand why they can't figure that

20 out.

21 MR. PENBERTHY: But they want to do whatever

22 they can to point to five, so.

23 MALE SPEAKER: One.

24 MR. PENBERTHY: Okay.

25 FEMALE SPEAKER: Yeah, I mean they just had
MEETING Case Ref # 16194-6 Page 46

1 this long discussion about all the variables and they,

2 as he said, they just dismissed all that because that

3 ...

4 MR. PENBERTHY: Well, I mean they agreed with

5 three of them.

6 (WHEREUPON, the background discussion ceased

7 and the phone discussion was heard.)

8 MS. FEHRENBACHER: The other thing that's

9 important is when you allow your monitoring and

10 concentrations of sediment, you can normalize as to

11 your, too, your carbon content which is what really

12 causes the problem anyway.

13 That's the important thing. When you're

14 doing that and you're understanding at the site that

15 you're monitoring and you're looking at that and

16 normalizing for that.

17 MR. KIM: And also there is one component

18 that we need to consider is, is that the siloxane is

19 not biodegradable, so if you, when you consider these

20 normal organic compounds, then the temperature, the

21 other factors are important because the biodegradation

22 rate depends on many parameters, but for siloxane, for

23 siloxane, we don't consider biodegradation, so local

24 tests are not the most important other than the

25 sorption and aeration.
MEETING Case Ref # 16194-6 Page 47

1 MR. PENBERTHY: Okay. Thank you.

2 Does our EPA folks have any other questions

3 about the comments that were made? Any clarifications

4 needed?

5 Okay. I mean, I think, I think what we're

6 going to need to do here at EPA, obviously we really

7 didn't have enough time to fully digest your

8 commentary, but understanding the comments you've made

9 on our proposal, I think we need to go back and

10 consider them in more depth and to see how many of the

11 proposed changes in focus that you make in your

12 comments we can accommodate in a, possibly an updated

13 proposal and so we're going to have to get back to you

14 on that.

15 Is that all right with you all?

16 MR. THOMAS: That's fine, Ward.

17 MR. PENBERTHY: Okay.

18 MS. FEHRENBACHER: And one other thing on

19 that, Ward, too, because I didn't add Kent Woodburn,

20 but obviously you have a document in your hands that is

21 from Kent Woodburn and he has stepped into the room. I

22 just wanted to document that he is here as well because

23 he did provide that copy of the risk assessment.

24 MR. PENBERTHY: Oh, yeah, I do, we do have

25 that. Unfortunately, our risk assessors haven't been
MEETING Case Ref # 16194-6 Page 48

1 available for us to look at that yet, so we're going to

2 need to apologize about that. Summertime is sometimes

3 tough.

4 MR. TOBIAS: Can I ask Cathy a question?

5 MS. FEHRENBACHER: Kent, do you want to just

6 add something about the sediment concentrations?

7 MR. TOBIAS: Cathy? Cathy? Are you there?

8 Can I ask you a question, actually about the

9 ...

10 MR. WOODBURN: I heard the comments about the

11 sediment concentrations and just wanted to give you the

12 perspective of how the data were collected and shown in

13 the document.

14 In any sort of probabilistic assessment, you

15 want to get a range of concentrations and the nice

16 thing about the APRA style approach is that you can

17 then examine worst-case scenarios, you can examine

18 median scenarios, you can examine low-case scenarios,

19 low-risk scenarios, and so it gives you a range of

20 concentrations.

21 And if you look at the data for both D4 and

22 D5, the settlement data in the diagram, you can see

23 that we have a range of concentrations that went from

24 three orders of magnitude to four orders of magnitude.

25 Now, admittedly, that we did sway to fit, in that we
MEETING Case Ref # 16194-6 Page 49

1 did not include the non-detectable concentrations. We

2 can certainly go back and put those in. We can say

3 that they're 50 percent of the detection limit or

4 something like that, but that would just further expand

5 the range of concentrations that we have. It would

6 take it four, even five orders of magnitude.

7 So if we were to throw on the proposed 42

8 more sites, I dare say that they're going to likely

9 fall on the same distribution lines that are shown here

10 from D4 and D5 and if we go back and look at the Wang,

11 et. al. data, there's a couple of caveats that you

12 should be aware of for that. And that is that these

13 data were collected by Environ in Canada. They were

14 using a megaflush model, they're model, for waste water

15 treatment plant discharge to try to find locations that

16 would have a high concentration of siloxane. And so

17 they identified nine municipal waste water treatment

18 plants and one industrial waste water treatment plant

19 and they collected data from those locations. If you

20 put those data with regard to the distribution lines,

21 you'll find that they span the entire spectrum of the

22 concentrations on the distribution lines both from low

23 concentrations to the highest concentrations from the

24 industrial side.

25 So I think that this is a really useful tool
MEETING Case Ref # 16194-6 Page 50

1 because it allows us to look at the data. We have some

2 60 some odd data for D4 and 90 some odd data for D5

3 because it's the full spectrum of what the likely

4 concentrations are for sediment to be really the big

5 kahuna with regard to the exposure for these materials

6 given their lipoglycopeptide and so it's really the

7 impact on densest organisms, so I think it's really

8 pertinent data with regard to this whole scenario

9 because we need to look at some. We have a range of

10 concentrations shown here for both materials and we put

11 it in the context of how does that compare to benthic

12 invertebrate species which could potentially be

13 impacted.

14 MR. PENBERTHY: Okay. Thank you.

15 To be honest, we just haven't had time to get

16 our feedback together on what was prepared, but David

17 has a question.

18 MR. TOBIAS: A question for Kent.

19 MR. WOODBURN: I hope you are going to

20 comment just on the concentrations because I heard some

21 of the discussion with regard to the concentrations and

22 again, they were not collected with any sort of

23 censoring with regard to worst-case, best-case

24 scenarios. It's really to try and gather all of the

25 data that we have on siloxane, what's the distribution,
MEETING Case Ref # 16194-6 Page 51

1 because once you gather, roughly, over 30 data points,

2 the distributions are not going to change likely in a

3 dramatic effect when you're trying to collect a variety

4 of different conditions and so that's what we've done

5 here.

6 And so again, we did not include the non7 detectable concentrations in sediment. That would just

8 further extend the distribution, obviously on the low

9 end, for both D4 and D5. So we certainly could do

10 that, but we did not so that. So this is, again, just

11 to ... all the scenarios for D4 and D5 are likely to,

12 whatever 42 sites you select in your proposal, are

13 likely to fall on these distribution lines with regard

14 to sediment concentrations for both compounds.

15 MR. TOBIAS: Just a couple of questions,

16 Kent.

17 Have you submitted this for publication

18 anywhere? Is this in the literature?

19 MR. WOODBURN: No, but we're preparing to

20 submit it. We discussed it at some of the CTAC

21 meetings, just, in fact, the most recent CTAC meetings,

22 well, the year before in Milan over in Italy, and then

23 we also presented here at CTAC in North America.

24 MR. TOBIAS: Okay.

25 MS. FEHRENBACHER: And also this one was
MEETING Case Ref # 16194-6 Page 52

1 done, the Tokyo Bay data is new information that's just

2 hot off the presses, but this approach was also used

3 for the D5 Board of Review and accepted by the D5 Board

4 of Review experts. And they probably concluded that

5 there was no risk associated with D5.

6 MR. WOODBURN: Right. This was a key part of

7 that, too, because obviously that makes these species

8 are the organisms of high concern with these materials.

9 MR. TOBIAS: The second question ... I heard

10 something confusing, you said, about how Canada

11 selected their sites. When I talked to Mayron, he said

12 their sites, they basically, they had already been

13 participating in monitoring programs and they just used

14 the ones that had already been participating for their

15 programs and then they added two more sites or

16 something like that. And when you described their

17 program, you confused me there. You sounded like you

18 think they did it a different way?

19 MR. WOODBURN: It was our understanding that

20 they were using megaflush to try to identify the high21 end concentrations and site locations.

22 MS. FEHRENBACHER: Yeah, I think the current

23 monitoring, because we've been in touch with Mayron as

24 well, the current monitoring now that they're

25 continuing, is based on their previous site selections.
MEETING Case Ref # 16194-6 Page 53

1 MR. TOBIAS: So this is in addition to what

2 they've done before?

3 MS. FEHRENBACHER: Yeah. So if their initial

4 select site selections was done based using the

5 megaflush model.

6 MR. TOBIAS: Their initial? I'll have to

7 talk to Mayron again because that's different than what

8 I got from him. Okay.

9 MS. FEHRENBACHER: That's our understanding

10 from the Board of Review. That was what was reported

11 during the Board of Review.

12 MR. WOODBURN: That's why there was the

13 inclusion of an industrial site which, obviously, is

14 the highest concentration.

15 MR. TOBIAS: Well, I think they did more

16 industrial sites than just one, actually, but they had

17 to claim all of that data CDI, so ... from the other

18 study done on industrial sites, but yeah, I mean I, I

19 talked him more. You know, I talked to him since we

20 were all at the meeting in Canada, so I'll talk to him

21 again about how site selection was done.

22 MR. PENBERTHY: So on the plot, is there ...

23 for say D4, figure one, where do those Wang, et. al.

24 data points end up on that plot?

25 MR. WOODBURN: Pretty much the full spectrum.
MEETING Case Ref # 16194-6 Page 54

1 You can go back to table one and pull whatever data

2 points you want off of there and compare, but they go

3 all the way from the lowest end of the plot to the

4 highest end of the plot.

5 That's the whole thing about gathering data

6 for, I mean, once you have enough data points for a

7 distribution, that's how, obviously, once you have a

8 bell ... if they behave as a bell shaped curve, that's

9 how they, that's how they're going to act and that's

10 pretty much the case for the Wang, et. al. data.

11 MALE SPEAKER: If I could also point out one

12 thing on those plots, is that those were not based on

13 random sampling. They're based on sampling at

14 locations where it was expected. That CMBS

15 concentrations would be detected, therefore they are

16 biased high and if you do a random selection, that will

17 lower the percentile concentrations.

18 MR. WOODBURN: Oh, yeah. Absolutely.

19 MR. TOBIAS: So on the D4, the conclusion is

20 that 94th percentile exposure is at 70 nanograms per

21 gram dry weight? Is that right?

22 MR. WOODBURN: Right.

23 MR. TOBIAS: So that means you can spend 95

24 percent of the samples that are going to be at

25 concentrations and some that are less than that, right?
MEETING Case Ref # 16194-6 Page 55

1 Is that how that works?

2 MR. WOODBURN: Right. Exactly.

3 And that's my thing about doing a PRA. You

4 can use whatever sort of target numbers you want to and

5 calculate what is the collective risk. I mean, you

6 combine the exposure percentile and combine that with

7 the toxicity percentile that you want to examine and

8 then the intersection of the two probabilities is the

9 product of those two, so by using ... and this is

10 fairly common, this has been done in ecofram and other

11 types of work groups. A 90 percentile concentration

12 compared to a 5th centile toxicity distribution, the

13 probability of those two events simultaneously

14 occurring is .25 percent or looked at with glass half15 full, that's 99.75 percent probability that the events

16 will not occur and for both D4 and D5, we never had an

17 intersection of the 90th percentile and the 5th centile

18 toxicity.

19 MALE SPEAKER: I encourage you to keep in

20 mind that that is biased high because of the way the

21 sampling was done.

22 MR. WOODBURN: And then the last thing that

23 we did was that we took the data for some of the

24 organism that Dave collected, both in Lake Pepin and in

25 Oslo fjord, and we basically estimated the
MEETING Case Ref # 16194-6 Page 56

1 concentrations on a lipid normalized basis using some

2 of the worst-case BFAF values that Dave was able to

3 collect from Lake Pepin for benthic invertebrates. So

4 that was D4, we used a value of 20 and for D5 we used a

5 value of five and we were able to estimate biota

6 concentrations that, for the tox-triggers that would

7 correspond. So then we could compare the toxicity

8 distribution on a lipid normalized basis to the

9 organisms that had been collected in the field and

10 compare those two. And again, asking the basic

11 question, is there an overlap and those are the last

12 two figures in the document and you can see the results

13 are the same.

14 So we tried to use different techniques to

15 compare the exposure to the toxicity NOEC distribution,

16 but for each one of the scenarios, we found basically

17 the same conclusion.

18 And we mentioned in the document, there's a

19 paper out there that may be informative to, to the EPA,

20 and that is there's a paper by Redman, et. al., Aaron

21 Redman, Dave and I were fortunate enough to be co22 authors on it, comparing, looking at tissue-based

23 issues with respect to the siloxanes and looking at

24 motive action, presumptive motive action of siloxanes,

25 comparing them. We used the target lipid model,
MEETING Case Ref # 16194-6 Page 57

1 Domenic Di Toro's target lipid model, for our scenario

2 and so we compared the findings with the siloxanes we

3 used, D4, D5, and D6 as a matter of fact, and compared

4 those to data collected on lots of other materials,

5 most of which are actually the target motive action.

6 We also (Inaudible) which are obviously, you know,

7 specific modes of action and the siloxanes were

8 consisted with the target motive action issue

9 concentration and so it was just published. It's

10 online in the Environmental (Inaudible) and Chemistry

11 Journal, The CTAC Journal. So the citation is

12 mentioned in the documents and I can send you guys a

13 PDF. I don't think I'm breaking too many copyright

14 laws. We're co-authors.

15 MR. PENBERTHY: Okay. I'm anxious to see

16 what our ecotoxicologists will think of the data. I

17 just haven't had the chance to talk with them.

18 Todd Stedeford, are you on the line?

19 MR. TOBIAS: He's not there.

20 MR. PENBERTHY: Okay.

21 MR. GRIFFITH: Ward? Ward?

22 MR. PENBERTHY: Yes?

23 MR. GRIFFITH: This is Patrick Griffith from

24 LA County Sanitary District, NACWA, I guess. I have to

25 step out for another meeting, so I just wanted to weigh
MEETING Case Ref # 16194-6 Page 58

1 in on the factors to consider discussion.

2 MR. PENBERTHY: Okay. That's good.

3 MR. GRIFFITH: Before you guys move on, I

4 think we're just, I guess we're just covering the same

5 comments we had before. We didn't really feel that

6 lagoons were going to be very critical, but you may

7 want to look at septic tanks, considering that the

8 population weighting, that there's more population

9 shared by big tanks, than lagoons and lagoons may be on

10 the way out because I think from the last discussion,

11 they may be self-selecting for some of the other

12 factors you're considering.

13 And another concern that you may have and I'm

14 not sure how EPA was going to approach this, but was it

15 your intent to have the various PHWs volunteer to

16 participate in this program?

17 MR. PENBERTHY: I guess that would ultimately

18 be the case. Right.

19 MR. GRIFFITH: Yeah, because, I mean just in

20 terms of the sampling efforts that I'm aware of which

21 are not very many, but there are a few, it can be kind

22 of difficult to get, to corral 42 treatment plants,

23 especially, you know, having the 42 be ones that will

24 fit all of your factors. So that may be kind of a

25 hurdle for you. So that's something to consider.
MEETING Case Ref # 16194-6 Page 59

1 And I think some of these factors may be

2 dropping off, so maybe you might want to review that

3 analysis.

4 And my one final thing was and I think

5 Cynthia mentioned this at the very beginning, if we can

6 be included on some of these emails where some of these

7 reports are being sent around, that would be very

8 helpful.

9 MR. PENBERTHY: Yeah, that was an unfortunate

10 oversight and our problem and it shouldn't have

11 happened.

12 MR. GRIFFITH: That's fine. That happens.

13 MR. PENBERTHY: I'm interested in your

14 thoughts on the high population, low flow scenario.

15 MR. GRIFFITH: Right. Yeah, our initial

16 comment was that perhaps instead of population size,

17 period, to look at the percent domestic contribution

18 because you might have certain communities that are

19 served or certain PHWs that are serving a domestic

20 community, but they also have industrial non-siloxane

21 dischargers and that could affect it.

22 I think that, I can't remember, was it Jason

23 who was commenting? He brought in that some of the

24 sewer systems are combine systems where you might have

25 storm water being brought in as well, so I think that
MEETING Case Ref # 16194-6 Page 60

1 was very useful contribution there. Then I would do

2 population weighted against the total flow and not just

3 total population. I think that's very useful to look

4 at.

5 MR. PENBERTHY: Okay. Great.

6 MR. GRIFFITH: All right. Thank you, guys.

7 MS. FINLEY: This is Cynthia, NACWA.

8 I think when you have a chance to look

9 through the document that was sent out this morning and

10 the one that we just received as well during the call,

11 we can put together some written comments, you know, to

12 expand a little bit on what Patrick said here on the

13 phone and comment on some of the other factors as well,

14 if that would be helpful.

15 MR. PENBERTHY: That would be extremely

16 helpful. Obviously, that would be ...

17 MS. FINLEY: Okay. Yeah. We need a little

18 time to do it, of course. You know, I have to get

19 through what I review today, but we'll need some time.

20 MR. PENBERTHY: Again, I apologize for not

21 getting that document to you.

22 MS. FINLEY: Yeah, that's okay.

23 MR. PENBERTHY: Okay. So maybe we should

24 move on to the manufacturing, processing, and

25 formulating sites unless anyone else on the call has
MEETING Case Ref # 16194-6 Page 61

1 some additional commentary?

2 Okay.

3 So Karluss, on the agenda it has, had time

4 for you to outline the rationale for your proposal on

5 manufacturing and processing and formulating sites, so

6 please go ahead.

7 MR. THOMAS: Sure and I can make this

8 relatively quick and I'll invite other members to add

9 on, but I think the primary rationale for our proposal

10 with respect to the manufacturer and processor and

11 formulator site is that the indirect dischargers

12 presumably or at least facilities that are likely to be

13 very similar are going to be picked-up by the POTW

14 portion of the proposal. So our thought was that we

15 would focus the SEHSD manufacturer, processor,

16 formulator sites who would have those focused only on

17 those sites that would have direct discharges and we've

18 essentially proposed that all four of the SEHSD sites

19 that are under our members' control be included in the

20 monitoring program. So that's essentially the

21 rationale.

22 Cathy, I'll invite you and others to add in

23 as needed.

24 MS. FEHRENBACHER: No, that's pretty good.

25 That's the basics, really, rationale.
MEETING Case Ref # 16194-6 Page 62

1 MR. PERBERTHY: Okay, I think I understand

2 that rationale.

3 I guess what was unclear to us in your

4 proposal was whether so much indirect discharge sites

5 were also going to be captured in the POTW monitoring,

6 site selected or not. In your ...

7 MR. THOMAS: They certainly could be or it

8 could be other MPF facilities that might be similar. I

9 mean, based on your comment as well during that initial

10 negotiating meeting, I think the thought was that, you

11 know, our MPF facilities aren't necessarily any

12 different from other facilities that use materials, so

13 I guess the thought is that as long as some of the

14 POTWs that are selected do have some MPF input, that

15 would be sufficient to make whatever conclusions that

16 you would need from that kind of a sample set.

17 MR. PENBERTHY: And I think our thinking in

18 this is definitely want the four facilities that are

19 the direct discharge and then we also wanted,

20 separately, to do the POTW with less sites with less of

21 an industrial, well, siloxane component. And then our

22 interest in an indirect discharge site was to help us

23 understand the relative contribution of the formulating

24 and processing sites versus the manufacturing sites to

25 environmental concentrations. So, I guess, based on
MEETING Case Ref # 16194-6 Page 63

1 when you look at what we sent around is, you know, how

2 would we pick ... we don't have really enough

3 information based on what you provided on the indirect

4 discharge to be able to figure out which ones would

5 make sense to monitor from.

6 MR. THOMAS: And on what basis do you

7 determine which ones would make sense? What

8 information would you need to make that determination?

9 MR. PENBERTHY: Well, I mean it would be

10 along the ... well, obviously there's a differentiation

11 between the sites that have on-site pre-treatment

12 before they go to a POTW. Then there could be

13 differences on the POTW configuration. For instance,

14 what is their treatment technique and what is their

15 receiving water body?

16 So if we knew those, we might be able to

17 select from all of those indirect discharge sites, the

18 most relevant ones that could help us with that

19 understanding of the relative contributions to the

20 various kinds of industrial sites.

21 MR. MAY: Hey, Ward, this is Russell May from

22 Avonics.

23 I took the liberty of sort of evaluating all

24 the different types of processors and formulators out

25 there outside the membership of SEHSD and I identified
MEETING Case Ref # 16194-6 Page 64

1 at least 12 different other industrial categories. So

2 I guess that's sort of Karluss' question.

3 So which of those industries are you planning

4 to evaluate?

5 MR. PENBERTHY: Well, maybe we need to know

6 more, then, about what kind of processing is actually

7 going on. Is it processing to make a ...

8 MR. MAY: Well, that's my problem. We can

9 only speak to what our silicone industry does. We

10 cannot speak to the other industries that get, that are

11 part of the value chain.

12 MR. PENBERTHY: Okay, but maybe we need to

13 know what's going on at your facilities to figure out

14 which ones are most relevant.

15 MR. MAY: Why does that make that

16 representative? I'm having difficulty with that.

17 If you want to be informed about all

18 processing and formulating, do you not need to consider

19 the full range of the universe?

20 How do you know which is high and which is

21 low?

22 MR. TOBIAS: I guess what you're suggesting

23 is ...

24 MR. PENBERTHY: I think what you're saying,

25 it would seem to me then, since I think all of the
MEETING Case Ref # 16194-6 Page 65

1 large manufacturers in SEHSD, you would have to tell us

2 about your value chain, then, and where your material

3 is going so that we could know how to answer that

4 question you're asking us.

5 MR. MAY: Well, actually we did that back

6 when we filed our CDR just a couple weeks ago.

7 MR. PENBERTHY: But that only included the

8 ... I thought that only included the members in SEHSD?

9 MR. TOBIAS: That's CDR.

10 MR. PENBERTHY: Oh, CDR is what you're

11 talking about.

12 MR. MAY: Right, but that part of the value

13 chain that expresses where the materials go.

14 MR. PENBERTHY: Well, we do understand, for

15 instance, on D4 that, you know, a significant portion

16 goes to, as a reactant to make other polymers, so to

17 the extent that those facilities would be identified

18 from your indirect discharge sites, maybe we could at

19 least get better insights into those, how those kind of

20 facilities differentiate themselves from facilities

21 that just ...

22 MR. MAY: I don't understand why are you only

23 looking at, I mean, we just spent the last hour and a

24 half talking about you need to know the range with

25 respect to POTWs. I don't understand the point here
MEETING Case Ref # 16194-6 Page 66

1 where we're only looking at a very narrow window.

2 You're looking at seven facilities, potentially, out of

3 tens of thousands.

4 MR. NGUYEN: You know, I stated ... this is

5 Nahn Nguyen.

6 I stated in your charge, part of the charge

7 is to understand the sources on the pathways of

8 environmental concentrations and ...

9 MR. MAY: I couldn't hear what you were

10 saying.

11 MR. NGUYEN: Sorry.

12 Part of the charge is to have an

13 understanding of the sources on the pathways to

14 environmental concentrations on D4, D5. We don't have

15 any information on the configuration of the on-site

16 treatment system, no information on concentrations

17 loading, so there's no way you could really develop

18 that understanding.

19 MR. THOMAS: I think part of the difficulty

20 is, you know, our members, our seven companies, their

21 sites only represent a very small fraction of the total

22 universe of facilities that are using D4, D5. It's not

23 clear that all of those would necessarily be

24 representative of the thousands of facilities that use

25 D4, D5. So if you're truly interested in the range,
MEETING Case Ref # 16194-6 Page 67

1 then our membership is only going to give you an

2 extremely narrow portion of that range.

3 MR. NGUYEN: It seems the advocates for, for

4 sampling of the additional sites, the more information

5 you have, the better.

6 MR. TOBIAS: The other question, I wanted a

7 quick question for Karluss, in his opening statement

8 there, since you said that the indirect would be

9 similar to what was in the POTW, that seems to assume

10 that all that indirect sites are releasing POTWs. Is

11 that correct or is some of them going to industry,

12 industrial waste water treatment plants? You would

13 have to know that to make that comparison. The two

14 processes would be different.

15 MR. THOMAS: I'm not sure I understand the

16 question. Could you say it one more time?

17 MR. TOBIAS: Well, it seemed to me like you

18 were implying that the indirect dischargers all send

19 their waste to a POTW, a municipal POTW that's

20 receiving waste also from residential and the spectrum,

21 but ...

22 MR. THOMAS: Correct.

23 MR. TOBIAS: ... if some of these indirect

24 sites are sending their waste to their, I don't know,

25 to an industrial facility, then that would be a
MEETING Case Ref # 16194-6 Page 68

1 different set-up, an industrial waste water treatment

2 plant. So it ...

3 MR. MAY: So we're already offering you the

4 four direct sites already.

5 MR. TOBIAS: That is true, but the ... just

6 from looking at the list here, there are three Dow

7 sites very close to each other in Michigan. If their

8 waste flows are combined, it's all sent to the same

9 treatment plant, then that becomes a new scenario, I

10 think, and we can't tell one way or the other.

11 MR. THOMAS: It becomes a new scenario for

12 what? Because they're all, they're send it to the

13 POTWs, so they're indirect dischargers, right?

14 MR. TOBIAS: Are you sure they're sending it

15 to a POTW? Is that what you're saying? That's a ...

16 MR. PENBERTHY: That's what they mean by

17 indirect discharge.

18 MR. TOBIAS: Well, yeah.

19 MR. MAY: That's what an indirect discharger

20 is.

21 MR. PENBERTHY: But is it the same POTW is

22 the question.

23 MR. TOBIAS: Yeah. I mean ...

24 MR. BROWNING: Well, first (Inaudible),

25 Michigan is pretty far away from Midland, I think.
MEETING Case Ref # 16194-6 Page 69

1 MR. MAY: But they are sending it to a POTW.

2 MR. TOBIAS: They all send it to a POTW?

3 MR. BROWNING: Right.

4 MR. THOMAS: Correct.

5 MR. PENBERTHY: Are all the POTWs activated

6 sludge facilities?

7 MS. PLOTZKE: This is Kathy Plotzke from Dow

8 Corning.

9 They all don't go to the same POTWs. They

10 all go to a waste water treatment plant.

11 MR. MAY: But Kathy, they're POTWs, though.

12 You don't own them. The indirect discharge types won't

13 discharge to a publically owned treatment works.

14 MS. PLOTZKE: No, that's not correct,

15 Russell.

16 MR. PENBERTHY: So then what do they go to

17 then?

18 MR. MAY: What do they go to? I guess that's

19 my confusion.

20 MS. PLOTZKE: A private. One goes to a

21 private. One goes to a private.

22 MR. TOBIAS: A private.

23 MR. PENBERTHY: Also on the list, there's two

24 sites with no discharge? What does that mean?

25 MR. TOBIAS: Does that mean they have ... I
MEETING Case Ref # 16194-6 Page 70

1 guess the question for the no discharge one is they

2 have no solid waste at all from their plants?

3 MR. MAY: I think they're warehouses.

4 MR. BROWNING: No, this is Gene Browning with

5 Shin-Etsu Silicone Group of America.

6 Those two sites are ours. We collect all of

7 our waste by processes within the plant here. They're

8 made of, they're processing plants and manufacturing

9 plants and, for instance, where many of the other

10 plants use outside sources of coolant water, we have an

11 internal cooling system that uses ... that doesn't,

12 it's non-content for cooling processes.

13 If we have any waste, we collect the waste,

14 we put them in drums, and then go to a treatment

15 facility where I think they go to an incinerator. So

16 we essentially have no waste water flows out of these

17 plants except for rain water.

18 MR. PENBERTHY: Okay, so there's no waste

19 water from the Shin-Etsu plants, okay.

20 MR. BROWNING: Right.

21 MR. PENBERTHY: Okay, the other plant that's

22 not a POTW, what's the treatment, what kind of

23 treatment facility is that?

24 MR. TOBIAS: It's a private industrial,

25 whatever, a private waste water plant that's ... all of
MEETING Case Ref # 16194-6 Page 71

1 them are municipally owned.

2 MR. PENBERTHY: How does that work? Is the

3 waste water trucked to a private plant?

4 MS. PLOTZKE: I'm sorry, I'm not sure I know

5 which one. Are you referring to one of ours?

6 MR. PENBERTHY: Well, you said there was one

7 site, one facility that didn't go to a POTW and I'm

8 trying to ... well, if it didn't go to a POTW, where

9 does it go and how does it get there?

10 MR. BROWNING: The two sites that are listed

11 under Shin-Etsu Silicone of America are the same

12 scenario. We have no waste water leaving the plant.

13 MR. PENBERTHY: Right, but I understood

14 there's another facility that doesn't go to a POTW

15 besides those two sites.

16 MR. TOBIAS: That was Dow Corning, she was

17 talking about that.

18 MS. PLOTZKE: That is correct. There is one

19 that goes to a private waste water treatment plant.

20 MR. PENBERTHY: Do we know which one that is?

21 MS. PLOTZKE: Tertiary.

22 MR. PENBERTHY: Do we know which one that is?

23 MS. PLOTZKE: Yes, the Tertiary Plant.

24 MR. TOBIAS: Not interested in tertiary.

25 MR. PENBERTHY: Okay, we're not interested,
MEETING Case Ref # 16194-6 Page 72

1 you know, our focus is on secondary treatment, not

2 tertiary. I think we'd be less interested in

3 monitoring at that facility, so if that was identified,

4 that might help us.

5 Do you see how the logic works? We're trying

6 to figure out which of these sites would make sense to

7 monitor at?

8 MR. THOMAS: So, Ward, are you agreeing that

9 those that do discharge to a POTW don't warrant

10 monitoring as we believe?

11 MR. PENBERTHY: No, I don't think that's the

12 case. I mean, we're still very much interested in

13 understanding how the source of, potential source, of

14 siloxane into the environment being either a processor

15 or formulator differs from the potential of a

16 manufacturer to be a source to the environment, so a

17 selection of the ... well, since there's not, well, I

18 guess on the direct discharge there's, well, they say

19 there's two processors-only sites, but we don't have

20 any formulation-only sites in the mix.

21 I do have a question about the Wacker Site,

22 though, on the direct discharge site, because on that

23 2006 IUR they were reported as manufacturing before, so

24 I was, I was trying to understand is our information

25 correct.
MEETING Case Ref # 16194-6 Page 73

1 MR. BROWNING: No, we do processing.

2 MR. PENBERTHY: No manufacturing?

3 MR. BROWNING: No.

4 MR. PENBERTHY: Okay.

5 MR. BROWNING: So I guess with the, the IUR

6 would be capturing importers, too, you know, not just

7 ...

8 MR. PENBERTHY: I fully understand that, but

9 they, Wacker, did report being a manufacturer before in

10 2005, 2006.

11 MR. BROWNING: Right, because we import.

12 MR. PENBERTHY: Well, that's not how it was

13 recorded in our database. Maybe our input was wrong or

14 maybe the form was filled out wrong, but anyway, that's

15 not ... just as long as I know what the circumstances

16 are.

17 You're currently just a processor?

18 MR. BROWNING: Yep.

19 MR. PENBERTHY: Okay.

20 MR. TOBIAS: So is our request to maybe ask

21 them to fill-in some of this to be determined

22 information with that, then, guiding?

23 MR. PENBERTHY: Right. I mean, if we

24 understood some of the information, that would help us

25 understand whether, I mean clearly, we're interested in
MEETING Case Ref # 16194-6 Page 74

1 monitoring a sampling of these indirect discharge

2 sites.

3 MR. THOMAS: Well I guess, Ward, in terms of

4 a goal that you mentioned in terms of being able to

5 differentiate relative contributions between processors

6 and manufacturers and formulators, again, I'll go back

7 to the original point that, you know, the SEHSC

8 initiative does not provide sufficient data sets to do

9 that. The universal processors and formulators, in

10 particular, is far greater than the number of

11 facilities. I mean thousands, tens of thousands,

12 probably greater than the seven companies that are on

13 today and, I guess, in addition to that, it's not clear

14 to me why that would be needed to do a risk assessment.

15 MR. PENBERTHY: Well, I mean I guess on a

16 risk assessment, if we do monitoring around the four

17 direct discharge sites, we certainly have a sense of

18 what is the manufacturing contribution to environment

19 load, so we can probably get a sense of what processing

20 does because there's at least two processing sites

21 solely.

22 MR. MAY: But Ward, I'd be careful about

23 that. It only represents processing that is focused on

24 our industry. There are many other different types of

25 technologies that processes this material.
MEETING Case Ref # 16194-6 Page 75

1 MR. PENBERTHY: Yes, I understand that. So

2 that introduces a ...

3 MR. MAY: What I'm getting at, what my

4 problem is, I don't understand how the idea that you're

5 going to be more informed on your objective identifying

6 seven sites.

7 MR. PENBERTHY: I guess if we have very few

8 sites, there's a tremendous amount of uncertainty in

9 our risk assessment. If we have more sites, there

10 would be less uncertainty about, say for instance, how

11 relatively speaking, should we be more concerned about

12 the releases from a formulator or a processor?

13 MR. MAY: I think it would depend on what

14 industry you're in.

15 MR. PENBERTHY: Well, clearly.

16 MR. MAY: Again, I'm trying to understand,

17 just like Karluss, how this is going to help you be

18 more informed from a risk assessment, particularly when

19 you're already monitoring the POTWs anyway?

20 More than likely, when you evaluate the POTW,

21 you will know the SIC codes of the industries that are

22 discharging to that facility.

23 MR. PENBERTHY: Well, the beauty of doing

24 monitoring around the indirect discharge sites is we

25 have more information, potentially, about the actual
MEETING Case Ref # 16194-6 Page 76

1 industrial activities going on.

2 MR. MAY: Well, how is that germane to your

3 risk assessment?

4 MR. PENBERTHY: Because it will give us an

5 indication whether, on a relative basis, formulators

6 are a greater contributor to environment loading than

7 manufacturers or not. Generally speaking. And there

8 would be uncertainty around that evaluation.

9 MR. THOMAS: And Ward, just to back up one

10 second because you kind of hit on this button a couple

11 of times even though we were talking about the POTW

12 portion of the monitoring proposal.

13 I think, at least my impression is that EPA

14 seems to be operating under the assumption that there

15 is a risk associated with D4 and D5 to the environment

16 and that you're trying to focus the data collection to

17 insure that you can have some relative portion of

18 exposure among the sources to inform your risk

19 management and I guess from our standpoint, we're

20 operating under the assumption that there are not any

21 sufficient risks to warrant restrictive risk

22 management.

23 As a corollary, I would say you colleagues,

24 Environ in Canada, share that view for D5 now and in

25 the future, and even for D4, they've only required the
MEETING Case Ref # 16194-6 Page 77

1 preparation of a solution prevention plan which is in

2 no way restrictive.

3 And I'll add to that, the concentration of

4 the D4 that you find relative to D5 are generally a lot

5 lower.

6 So I guess I'll just say on that, just say

7 that we've been totally transparent with the agency in

8 sharing all of the data that we believe confirms the

9 safety of D4 and D5. All of the analysis we've done,

10 all of the assessments, all of the monitoring

11 activities, and it's not clear that we have, you know,

12 gotten that same level of cooperation.

13 I just kind of harken back to earlier in the

14 call, I heard a comment that the Oregon data, the

15 trigger levels that EPA have are lower than the levels

16 that, you know, Oregon would have.

17 So I'm just curious what the scientific basis

18 is for EPA's determination that a lower level needs to

19 be looked at? So if there aren't data that EPA has

20 that confirms, at least in your mind, that there's a

21 risk associated with those materials, with the

22 materials, then I think EPA really has an obligation to

23 share those and subject them to peer review as your

24 colleagues in Canada did.

25 MR. PENBERTHY: Yeah, I'm sure we'll get down
MEETING Case Ref # 16194-6 Page 78

1 the level of detection if we can actually get to the

2 point where we can agree on what sites to monitor. So

3 yeah, we'll get to that I'm sure.

4 Okay, is there any other input on this topic

5 from the other participants?

6 Okay, I'm hearing none. I guess, I guess,

7 Karluss, can we expect more direct feedback on our

8 monitoring proposal from you from what we sent you from

9 SEHSC?

10 MR. THOMAS: On the MPF sites?

11 MR. PENBERTHY: Yes.

12 MR. THOMAS: I guess we can certainly do

13 that, Ward, but I guess it would be instructive to hear

14 a little bit more specifically from the agency why what

15 was proposed does not allow you to do a risk

16 assessment, because again, I know we keep going back to

17 the point that you're going to pick-up the indirect

18 dischargers or certainly facilities that are similar to

19 those MPFs when you do the POTW portion, so we've

20 essentially offered all of the, our member sites, that

21 have direct dischargers. So from a risk standpoint,

22 it's unclear what more we can do.

23 MR. PENBERTHY: Okay. I mean, I think what

24 we're going to have to do is, you know, formulate our

25 proposal based on the feedback we've gotten so far,
MEETING Case Ref # 16194-6 Page 79

1 both on the POTWs and on the MPF sites, and then get

2 back to you with some modifications based on the

3 feedback you've given and then I think what we would do

4 is need to, we'll probably need a couple weeks to put

5 that together.

6 We also need to review the risk assessment

7 that you all provided us.

8 I think at that point we would send out a

9 revised proposal in, I'd say, a couple weeks and then

10 we want to meet on a formal basis with the full

11 negotiating group and then we would hopefully present

12 our proposal, our modified proposal and then basically

13 at that meeting understand is it worth proceeding

14 further in the discussions.

15 I think there's been some good progress, good

16 feedback, and I appreciate all of the work that you've

17 put in. I think the document explaining the logic that

18 you had used to pick sites and develop your monitoring

19 program was, you know, it really helped us understand

20 your perspectives better.

21 I'm still pretty sure there's differences,

22 however, so we'll see if we can bridge those in the

23 next couple weeks, and to the extent that we can.

24 So I guess looking at the calendar, I mean, I

25 would think that we would want to organize the more
MEETING Case Ref # 16194-6 Page 80

1 formal meeting, maybe an in-person meeting, either the

2 last week in August or the first week in September.

3 Do you all have a preference for that?

4 MS. PLOTZKE: This is Kathy Plotzke. I am

5 out of the country the first week in September. So my

6 preference would be the last week in August.

7 MR. PENBERTHY: Okay. So Tuesday has worked

8 fairly well, so is the 28th a good day?

9 We'll have to confirm this with all of our

10 folks, but let's ...

11 MS. CARLTON: Ward, this is Betsy Carlton.

12 Can I just ask a question?

13 Just to be clear, is this to schedule another

14 technical working group but a face-to-face?

15 MR. PENBERTHY: No, this wouldn't be a

16 technical working group meeting. It's pretty clear we

17 have different perspectives here, so I don't know if

18 we're going to be able to use the working group to

19 actually develop a proposal for consideration of the

20 group, but I think we would, at EPA, like to take

21 another look at our previous proposals, maybe try and

22 clarify some of the points in them and are some of the

23 rationales for some of the pieces and then offer that

24 to a negotiating session, not a working group session,

25 in the last week of August.
MEETING Case Ref # 16194-6 Page 81

1 MS. CARLTON: So another telephone

2 conference?

3 MR. PENBERTHY: Well, we could arrange for

4 both. It could either be in-person or by phone.

5 Either way.

6 MR. MAY: Ward, but for clarity, you're

7 proposing the last week in August, the 28th ...

8 MR. PENBERTHY: Correct.

9 MR. MAY: ... for negotiating meeting?

10 MR. PENBERTHY: Right. Correct.

11 MR. THOMAS: And, and I think in terms of the

12 timing of you guys getting us some additional feedback,

13 we talked about two weeks. That would be sometime the

14 week of the 20th, so that's essentially a week before

15 the face-to-face negotiating sessions. I'm just

16 wondering, I know we do want to give ourselves enough

17 time to review all of the information. There's always

18 challenges for us as well for getting things circulated

19 and allowing enough time for folks to review materials.

20 Do we think a week is going to be enough time

21 for you to give us the feedback and for us to

22 sufficiently digest it and have that face-to-fact

23 meeting or do we want to give ourselves a little bit

24 more time to take everything in and potentially give

25 the agency more time to pull its thoughts together on a
MEETING Case Ref # 16194-6 Page 82

1 revised proposal?

2 MR. PENBERTHY: Well, what are your thoughts

3 on that? Obviously, you think that we might need more

4 time?

5 MR. THOMAS: Well, I just, I just know we all

6 have, you know, challenges for time and particularly in

7 the summer in getting everybody to look at things we

8 need to have on it.

9 I know a lot of things we talked about you

10 wanted your eco folks to kind of provide feedback on.

11 I don't believe so any of them are on-call, so like,

12 I'll leave it to you to let me know what you think is

13 enough time, but I just want to make sure we consider

14 giving enough time for folks to pull things together

15 and giving us enough time to take a look at it.

16 MR. PENBERTHY: Well, why don't we do it this

17 way. Let's tentatively schedule for the 28th and if

18 things aren't ... timing is breaking down, maybe we'll

19 have to postpone it, but we'll try to stick with our

20 schedule the best we can.

21 MS. CARLTON: So then it would have to be by

22 phone? Because these days, they won't let you cancel

23 your reservation for a plane. They charge you anyway.

24 MR. PENBERTHY: Yeah, we'll keep that in

25 mind.
MEETING Case Ref # 16194-6 Page 83

1 MS. CARLTON: It's a short time frame and

2 then if we get that close and say no, we can't, and

3 reschedule, it makes things really hard.

4 MR. PENBERTHY: Okay. So maybe it will have

5 to be by phone if ... I think we'll have some better

6 idea of the timing here in the next week or so.

7 MR. THOMAS: And you think you'll be able to

8 give us the feedback you talked about, Ward, on the ...

9 on an updated version of your POTW proposal based on

10 our comments and also potentially a revised version of

11 the MPF proposal based on the discussion today? You

12 still think all of that is possible the week of the

13 20th? So in two weeks?

14 MR. PENBERTHY: Correct.

15 MR. THOMAS: Okay.

16 MR. PENBERTHY: Is that fair enough?

17 MR. THOMAS: Fair enough.

18 MR. PENBERTHY: Okay. Are there any other

19 points?

20 I should have mentioned this at the front, at

21 the front of the meeting, but we have, we'll have a

22 transcript. We'll have the agenda and all of the

23 documents that we've discussed in the docket just so

24 you're aware of that.

25 MR. BROWNING: Are we proposing a specific
MEETING Case Ref # 16194-6 Page 84

1 time for the 28th?

2 MR. PENBERTHY: I think the afternoon if

3 that's okay. Probably one or two.

4 MR. THOMAS: Okay. Either works for me.

5 MR. PENBERTHY: Okay.

6 All right. Anything else to discuss?

7 MR. THOMAS: Nothing from me.

8 MR. PENBERTHY: All right. Well thanks again

9 for all your help, all your input, all your

10 explanations on the science that sometimes we don't

11 have a full grasp of like you all do, but thanks again.

12 GROUP: Thank you. Good-bye.

13 (WHEREUPON, the meeting concluded.)

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MEETING Case Ref # 16194-6 Page 85

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19:2 20:22 31:17

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37:16 37:20

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concentrations

14:7 15:15

18:6 18:17 18:25
MEETING Case Ref # 16194-6 Page 92

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MEETING Case Ref # 16194-6 Page 94

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MEETING Case Ref # 16194-6 Page 95

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MEETING Case Ref # 16194-6 Page 96

eight 14:23 17:23

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explanation 12:11
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explanations

84:10

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59:12

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5:22 11:12 11:12

11:16 60:7 60:17

60:22

first 8:10 12:2

12:17 12:17
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20:21 22:14

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77:12 78:25

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MEETING Case Ref # 16194-6 Page 99

gram 54:21

Grams 7:15 7:15

grant 24:3 24:7

grasp 84:11

Gray 7:24 7:24

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16:4 19:25 60:5

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MEETING Case Ref # 16194-6 Page 100

honest 50:15

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63:3 63:17 65:18

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industrial

49:18 49:24

53:13 53:16

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62:21 63:20 64:1

67:12 67:25 68:1
MEETING Case Ref # 16194-6 Page 101

70:24 76:1

industries 64:3

64:10 75:21

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64:9 67:11 74:24

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13:7 13:17 25:16

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33:4 33:18

34:2 35:20

36:8 39:10 39:25

62:14 73:13 78:4

84:9

inputs 27:7

insights 65:19

instance 22:17

63:13 65:15 70:9

75:10

instead 31:20

59:16

instructive 78:13

insure 76:17

intended 8:22

13:3

intent 33:5 58:15

interactions

44:11

interest 62:22

interested

18:20 23:14

28:23 29:17

59:13 66:25

71:24 71:25 72:2

72:12 73:25

interesting

14:3 16:13 19:19

21:20

internal 70:11

intersection 55:8

55:17

introduces 75:2

intuitively 21:13

invertebrate

50:12

invertebrates

56:3

invite 10:20 61:8

61:22

issue 18:5 57:8

issues 8:12

26:7 56:23

isthey 19:9

Italy 51:22

items 8:24

Itlucky 9:17

it's 9:6 9:20

13:2 13:6

13:14 16:11

17:21 17:25 18:1

19:18 19:19 22:6

23:3 24:7

24:12 25:8 26:21

32:3 32:19 34:15

35:13 38:14

38:15 38:15

38:15 40:18

40:18 40:19 41:7

41:12 42:17

42:18 42:18

43:21 45:3

50:3 50:6 50:7

50:24 57:9 66:22

68:8 70:12 70:24

74:13 77:11

78:22 80:16 83:1

IUR 72:23 73:5

I've 11:13

J

Jaeshin 6:10 30:3

30:5 30:21

Jaeshin's 40:5

Jason 59:22

Jay 30:12
MEETING Case Ref # 16194-6 Page 102

Jessica 5:12 8:1

Joe 5:8

John 7:22

Jones 5:6 5:6

Journal 57:11

57:11

jump 23:8

justification

10:4 12:5

K

kahuna 50:5

Karluss 6:12 11:2

12:2 21:17

61:3 64:2 67:7

75:17 78:7

Kathleen 6:14

Kathy 10:20 10:23

29:25 42:11 69:7

69:11 80:4

Keller 7:21

Kent 47:19

47:21 48:5 50:18

51:16

Kevin 6:16 20:5

key 52:6

killer 45:10

45:10

kilometer 26:5

kilometers

17:23 26:20

Kim 6:10 6:11

30:3 30:4 30:5

31:2 31:5 31:9

31:15 33:12

33:19 34:3 35:13

35:21 36:3

36:5 36:20

37:7 38:8

38:13 38:22

39:14 46:17

kinds 27:8 63:20

knew 63:16

knowledge 17:7

25:4 27:4

Koch 7:5 7:6

Kozerski 6:6 6:7

Kroger 7:22 7:22

L

LA 57:24

lagoons 32:9

32:11 32:16 38:6

39:11 58:6

58:9 58:9

Lake 16:5 16:22

17:21 26:14

26:19 26:25

28:14 28:21

28:23 29:6 29:11

55:24 56:3

large 27:6

36:16 36:17 37:2

37:5 37:18 37:19

42:5 42:10 65:1

larger 36:14

largest 27:9

35:10 35:11

last 8:7 10:16

36:21 55:22

56:11 58:10

65:23 80:2

80:6 80:25 81:7

late 9:5 9:14

laws 57:14

lead 14:19

learn 24:5

least 61:12

64:1 65:19 74:20

76:13 77:20

leave 82:12

leaving 71:12

less 20:11

20:15 20:18

20:19 25:21

32:10 54:25

62:20 62:20 72:2

75:10

let's 36:4

80:10 82:17

level 22:10 22:24

23:1 37:9

37:25 44:15

77:12 77:18 78:1

levels 22:10 23:2

28:14 28:15

32:14 32:21

32:22 39:22

39:23 42:5 77:15

77:15

Lewis 7:14 7:14

liberty 63:23

likely 24:18

34:25 49:8

50:3 51:2

51:11 51:13

61:12 75:20

limit 22:25 49:3
MEETING Case Ref # 16194-6 Page 103

limited 13:25

line 5:5 10:6

57:18

Lined-up 45:7

lines 18:2 49:9

49:20 49:22

51:13

lipid 56:1 56:8

56:25 57:1

lipoglycopeptide

50:6

Lisa 7:16 7:18

Liscoe 7:20 7:20

list 5:15 68:6

69:23

listed 71:10

literature 51:18

little 14:13

14:14 16:19 33:7

60:12 60:17

78:14 81:23

load 31:25

33:23 74:19

loading 36:13

66:17 76:6

local 40:7

40:14 40:17

40:17 41:1 42:10

44:8 46:23

location 19:24

19:25

locations 49:15

49:19 52:21

54:14

logic 24:16 24:17

72:5 79:17

logical 18:9 20:4

33:3 33:23

logically 35:25

long 30:19 46:1

62:13 73:15

lost 13:20 13:22

lot 32:6 40:19

44:22 77:4 82:9

lots 57:4

low 18:25 33:21

34:1 35:7 36:1

36:2 36:2

36:12 39:11

43:25 49:22 51:8

59:14 64:21

low-case 48:18

lower 36:7 36:8

54:17 77:5 77:15

77:18

lowest 54:3

low-risk 48:19

M

ma 8:8

magnitude 48:24

48:24 49:6

major 10:16

21:4 30:6 30:11

majority 16:4

17:19

MALE 7:2 11:19

22:10 25:23 26:1

26:8 26:10 26:13

27:1 27:12 27:22

27:24 28:2

28:7 28:18 28:20

29:1 29:9

38:14 41:25 45:4

45:9 45:16 45:23

54:11 55:19

management

20:11 20:18 21:1

76:19 76:22

manufacturer

61:10 61:15

72:16 73:9

manufacturers

65:1 74:6 76:7

manufacturing 8:8

8:16 60:24

61:5 62:24

70:8 72:23

73:2 74:18

Marcus 5:11

5:14 8:5 9:19

mass 36:13

36:14 37:1

37:4 37:7

37:18 37:19

39:25

material 65:2

74:25

materials 17:7

17:9 25:6

26:17 26:19 28:8

37:16 37:24 50:5

50:10 52:8

57:4 62:12 65:13

77:21 77:22

81:19

matrix 33:11

matter 57:3
MEETING Case Ref # 16194-6 Page 104

may 15:19 18:4

34:22 42:5 56:19

58:6 58:9

58:11 58:13

58:24 59:1 63:21

63:21 64:8 64:15

65:5 65:12 65:22

66:9 68:3

68:19 69:1 69:11

69:18 70:3 74:22

75:3 75:13 75:16

76:2 81:6 81:9

maybe 11:23 11:24

16:11 16:11

20:16 22:22

29:10 29:10 38:2

59:2 60:23

64:5 64:12 65:18

73:13 73:14

73:20 80:1 80:21

82:18 83:4

Mayron 52:11

52:23 53:7

McNett 5:25 6:1

MDHSC 7:19

mean 13:25

14:17 16:9 17:22

19:18 25:2 25:25

28:9 33:15 36:22

37:22 37:22

41:19 43:7

43:9 45:13 45:25

46:4 47:5

53:18 54:6

55:5 58:19

62:9 63:9

65:23 68:16

68:23 69:24

69:25 72:12

73:23 73:25

74:11 74:15

78:23 79:24

means 28:15 54:23

meant 13:6

measure 40:13

41:3 41:8

measured 41:22

measurement 35:3

measurements

42:16

media 13:1 23:3

median 39:1 48:18

meet 79:10

meeting 8:10 8:22

8:23 53:20 57:25

62:10 79:13 80:1

80:1 80:16

81:9 81:23 83:21

84:13

meetings 51:21

51:21

megaflush 49:14

52:20 53:5

member 78:20

members 61:8

61:19 65:8 66:20

membership

63:25 67:1

mention 15:23

mentioned 20:9

21:19 29:16

56:18 57:12 59:5

74:4 83:20

merit 40:2

messy 40:20

metals 26:17

meters 26:3 26:4

method 31:12

Michigan 68:7

68:25

Midland 68:25

Mihaich 6:2 6:3

6:3 6:5

Mike 7:13

Milan 51:22

miles 17:22

million 37:13

mind 55:20

77:20 82:25

Minneapolis 27:14

28:4

minute 38:16

missing 14:17

Mississippi 26:18

26:22 27:5

27:6 27:11

mistake 9:18

mix 72:20

model 12:22

13:5 49:14 49:14

53:5 56:25 57:1

models 12:10

12:24 13:14

modes 57:7

modifications

79:2

modified 79:12
MEETING Case Ref # 16194-6 Page 105

Momentive 7:16

20:6

monitor 21:9 26:1

26:2 26:3 38:7

42:24 43:9 43:14

63:5 72:7 78:2

monitored 39:13

monitoring 5:2

8:11 10:5 13:1

13:4 13:6

15:11 15:12

15:24 16:7

17:1 19:15 19:20

22:20 23:5 25:12

26:16 28:4

28:6 28:16 30:19

32:23 32:25 36:6

39:9 42:9 46:9

46:15 52:13

52:23 52:24

61:20 62:5

72:3 72:10

74:1 74:16 75:19

75:24 76:12

77:10 78:8 79:18

morning 60:9

mostly 17:19

motive 56:24

56:24 57:5 57:8

move 38:3 58:3

60:24

MPF 62:8 62:11

62:14 78:10 79:1

83:11

MPFs 78:19

multiple 15:16

27:18 35:4

35:8 35:15 38:21

municipal 49:17

67:19

municipally 71:1

muted 44:25

N

NACWA 5:21

11:12 57:24 60:7

Nahn 66:5

nanograms 54:20

narrow 66:1 67:2

nation 18:18

25:11

national 14:6

nationwide 32:19

nature 9:2

nearest 17:21

necessarily

13:4 21:14

35:9 35:10 62:11

66:23

negotiating

8:20 62:10 79:11

80:24 81:9 81:15

Nguyen 5:7 5:7

66:4 66:5

66:11 67:3

Nhan 5:7

nice 48:15

nickname 45:12

nine 49:17

ninety-five 36:15

NOEC 56:15

non 51:6

non-content 70:12

non-detectable

49:1

non-detects 21:23

none 78:6

non-siloxane

59:20

normal 46:20

normalize 46:10

normalized 56:1

56:8

normalizing 46:16

North 51:23

Nothing 84:7

notification

34:11

noting 13:13

NPDS 33:19 38:24

O

objective 15:1

75:5

obligation 77:22

obtain 19:20

obviously 12:24

15:3 24:21

27:7 30:8

30:16 33:3

47:6 47:20

51:8 52:7

53:13 54:7

57:6 60:16 63:10

82:3

occur 29:6 29:7
MEETING Case Ref # 16194-6 Page 106

55:16

occurring 55:14

odd 50:2 50:2

offer 80:23

offered 78:20

offering 68:3

office 33:16

officer's 10:10

off-site 34:22

oh 9:18 47:24

54:18 65:10

okay 5:16 6:4 6:5

6:10 6:14 6:16

7:3 8:3 8:4 9:12

10:2 10:5 10:7

11:11 11:14

11:21 12:23

14:11 14:11 19:8

19:14 27:1 28:19

29:8 29:22

30:2 30:5 31:9

31:21 32:15 34:4

35:16 35:22 36:4

36:5 37:17

38:2 38:9 39:7

39:15 43:23

45:24 47:1

47:5 47:17 50:14

51:24 53:8 57:15

57:20 58:2

60:5 60:17 60:22

60:23 61:2

62:1 64:12 70:18

70:19 70:21

71:25 73:4 73:19

78:4 78:6

78:23 80:7

83:4 83:15 83:18

84:3 84:4 84:5

older 32:15

on-call 82:11

ones 30:14

52:14 58:23 63:4

63:7 63:18 64:14

ongoing 14:1

online 57:10

on-site 63:11

66:15

open 12:1

opening 67:7

operating 76:14

76:20

optimal 30:7

order 5:17

orders 48:24

48:24 49:6

Oregon 21:21

21:24 22:21

22:23 23:22

23:22 77:14

77:16

organic 26:17

32:18 40:8 40:22

40:23 41:7 41:10

41:16 41:18 42:4

42:12 43:20

44:13 44:17

46:20

organism 55:24

organisms 50:7

52:8 56:9

organize 79:25

organized 36:10

organizing 10:8

original 74:7

Oslo 55:25

others 11:7 15:17

61:22

ours 70:6 71:5

ourselves 81:16

81:23

outcome 8:22

outfall 27:20

27:21 28:17

29:13

outline 61:4

output 30:16

outside 63:25

70:10

overall 25:18

31:16 32:12

32:20 32:24

overflows 34:25

overlap 56:11

oversight 59:10

over-sighting

16:11

overview 11:23

owned 69:13 71:1

P

page 14:23

paper 22:24 22:25

23:2 23:22 56:19

56:20

parameter 41:14

parameters 40:3
MEETING Case Ref # 16194-6 Page 107

41:12 42:23

46:22

park 17:5

participants 78:5

participate 58:16

participating

52:13 52:14

particles 32:2

particular 5:17

15:8 34:21 74:10

particularly

16:22 75:18 82:6

parties 22:6

party 7:9

pathways 13:17

66:7 66:13

Patrick 6:18

57:23 60:12

Paul 6:20 7:14

27:15 28:4

pause 12:13

PCBs 26:17

PCPC 9:6

PDF 57:13

peer 77:23

Penberthy 5:4 5:5

5:13 8:4 9:8

9:12 9:15 9:22

9:25 10:2 11:2

11:14 11:17

11:20 12:16

12:23 13:21

14:11 14:23

15:23 16:3 17:13

17:17 17:25 18:9

18:19 19:4

19:8 19:11 19:14

19:23 21:3

22:2 22:6

22:13 23:14

23:17 24:15

25:14 25:20

25:25 26:6

26:9 26:12

27:2 27:17 27:21

27:23 28:9

29:8 29:10 29:20

30:24 31:10 33:2

33:13 33:24 34:4

35:6 35:16 35:22

36:4 36:9

36:22 37:11

37:17 38:2

38:9 38:18

39:7 39:15 42:20

43:6 43:18 43:23

45:2 45:6

45:11 45:21

45:24 46:4

47:1 47:17 47:24

50:14 53:22

57:15 57:20

57:22 58:2 58:17

59:9 59:13

60:5 60:15 60:20

60:23 62:17 63:9

64:5 64:12 64:24

65:7 65:10 65:14

68:16 68:21 69:5

69:16 69:23

70:18 70:21 71:2

71:6 71:13 71:20

71:22 71:25

72:11 73:2

73:4 73:8

73:12 73:19

73:23 74:15 75:1

75:7 75:15 75:23

76:4 77:25 78:11

78:23 80:7 80:15

81:3 81:8

81:10 82:2 82:16

82:24 83:4 83:14

83:16 83:18 84:2

84:5 84:8

people 18:10

21:13 33:16

34:18 35:4

35:8 35:15 38:21

Pepin 16:6

16:22 17:21

26:15 26:25

28:15 28:21

28:23 29:6 29:11

55:24 56:3

per 37:12 37:13

38:16 54:20

PERBERTHY 62:1

percent 34:24

36:15 36:16 49:3

54:24 55:14

55:15 59:17

percentile

54:17 54:20 55:6

55:7 55:11 55:17

perhaps 43:2

59:16

period 59:17

Perricase 7:18

7:18

persistent 23:4

23:9

Personal 7:22
MEETING Case Ref # 16194-6 Page 108

PERSONS 27:18

perspective

14:6 18:13 48:12

perspectives 8:17

10:19 79:20

80:17

pertinent 50:8

phase 32:8

44:13 44:21

phone 44:25

45:1 46:7

60:13 81:4 82:22

83:5

phonetic 7:25

9:18 12:3

PHWs 58:15 59:19

physical 31:22

42:15 43:15

44:22

pick 25:6 29:23

33:8 33:9 33:9

33:25 39:9

63:2 79:18

picked-up 61:13

pick-up 78:17

pieces 12:15

80:23

Pipin 26:20

places 15:16

29:24

plan 24:12

32:25 77:1

plane 82:23

planning 64:3

plant 18:8

49:15 49:18 68:2

68:9 69:10

70:7 70:21 70:25

71:3 71:12 71:19

71:23

plants 49:18

58:22 67:12 70:2

70:8 70:9

70:10 70:17

70:19

play 37:23 40:15

please 5:15 7:8

29:20 36:20 61:6

plot 53:22

53:24 54:3 54:4

plots 54:12

PLOTSKE 16:18

17:15 24:9

25:2 25:15

Plotzke 6:14 6:15

11:21 12:19 15:2

30:2 69:7 69:7

69:14 69:20 71:4

71:18 71:21

71:23 80:4 80:4

plunge 11:6

plus 21:22 21:24

point 13:11 13:16

20:16 21:18

23:21 23:22

23:24 27:2 27:12

29:7 30:22

34:6 35:13 39:19

40:4 45:22 54:11

65:25 74:7

78:2 78:17 79:8

pointed 40:14

41:18

pointing 45:11

points 13:15

40:21 43:10 51:1

53:24 54:2

54:6 80:22 83:19

polymers 65:16

pond 32:11

population

31:16 33:6 33:17

33:20 33:22

34:14 34:17 35:5

35:7 35:17 35:19

36:1 39:20 39:23

43:25 58:8

58:8 59:14 59:16

60:2 60:3

populations 34:1

portion 8:10

10:13 12:17

61:14 65:15 67:2

76:12 76:17

78:19

possible 19:1

24:21 28:15

83:12

possibly 47:12

postpone 82:19

potential 72:13

72:15

potentially 50:12

66:2 75:25 81:24

83:10

POTW 8:11 10:5

10:13 12:21

22:17 27:17

31:12 32:3 33:14
MEETING Case Ref # 16194-6 Page 109

33:20 33:23 34:2

36:15 37:1

37:4 43:25 61:13

62:5 62:20 63:12

63:13 67:9 67:19

67:19 68:15

68:21 69:1

69:2 70:22

71:7 71:8

71:14 72:9 75:20

76:11 78:19 83:9

POTWs 8:14 8:25

20:1 23:20 24:19

29:13 33:9 33:16

33:18 33:25

39:10 39:13

62:14 65:25

67:10 68:13 69:5

69:9 69:11 75:19

79:1

POTW's 33:5

pounds 36:13

Powell 5:23

5:24 16:21 40:14

power 12:7 12:12

PRA 55:3

predict 17:9 36:7

predicted 35:2

preference 80:3

80:6

pre-manufacturing

34:10

preparation 77:1

prepared 50:16

preparing 51:19

Presence 10:17

present 23:23

79:11

presented 15:24

16:15 51:23

presses 52:2

presumably 61:12

presumptive 56:24

pre-treatment

63:11

pretty 10:11 35:2

53:25 54:10

61:24 68:25

79:21 80:16

prevention 77:1

previous 52:25

80:21

primary 19:23

19:24 19:25 37:8

37:10 37:11 61:9

prior 30:19

priority 43:2

private 69:20

69:21 69:21

69:22 70:24

70:25 71:3 71:19

probabilistic

48:14

probabilities

55:8

probability 55:13

55:15

probably 21:9

21:19 38:16

43:12 52:4 74:12

74:19 79:4 84:3

problem 24:2

46:12 59:10 64:8

75:4

problems 22:21

procedure 30:22

proceed 10:3

proceeding 79:13

process 10:19

processes 67:14

70:7 70:12 74:25

processing 8:9

8:16 60:24

61:5 62:24

64:6 64:7

64:18 70:8

73:1 74:19 74:20

74:23

processor 61:10

61:15 72:14

73:17 75:12

processors

63:24 74:5 74:9

processors-only

72:19

Proctor 7:11

produce 32:10

product 7:23 34:8

34:12 55:9

program 13:2 13:4

21:12 22:20 23:5

23:7 24:14 24:16

25:5 30:20 41:21

52:17 58:16

61:20 79:19

programs 52:13

52:15
MEETING Case Ref # 16194-6 Page 110

progress 79:15

proper 32:25

properly 42:3

properties

31:22 42:15

property 43:15

44:23

proposal 8:8 8:20

10:13 24:25

35:17 36:1

47:9 47:13 51:12

61:4 61:9

61:14 62:4 76:12

78:8 78:25

79:9 79:12 79:12

80:19 82:1

83:9 83:11

proposals 80:21

propose 28:9

30:13 31:20

proposed 10:5

19:15 30:12

47:11 49:7 61:18

78:15

proposing 81:7

83:25

provide 10:10

13:6 13:16 14:13

47:23 74:8 82:10

provided 10:13

10:18 11:8

63:3 79:7

publically 69:13

publication 51:17

published 26:16

57:9

pull 41:6 54:1

81:25 82:14

purpose 23:5

purposes 13:6

Q

quantify 20:19

quantitative

30:18

question 24:9

25:3 36:9 48:4

48:8 50:17 50:18

52:9 56:11

64:2 65:4 67:6

67:7 67:16 68:22

70:1 72:21 80:12

questions 9:1

11:24 12:14 15:3

15:4 33:1

39:17 47:2 51:15

quick 61:8 67:7

quickly 10:24

11:4

quite 24:25 34:16

R

raft 39:12

rain 70:17

raise 44:15

random 54:13

54:16

range 18:17 18:25

20:2 20:10 20:22

23:18 24:11

24:11 24:13

24:14 25:5 25:10

25:10 25:13

25:18 27:5 35:24

38:25 40:12

41:17 48:15

48:19 48:23 49:5

50:9 64:19 65:24

66:25 67:2

rate 26:22

33:21 33:22

35:19 37:3 38:11

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26:14 37:15

37:22 40:6

40:6 40:14 40:16

40:22 47:8

79:3 79:16

Z

Z45 12:21

zero 20:12

20:15 20:19

zone 26:2 26:4

42:7

zones 26:25