November 25, 2014

Paul Lewis

Chief, Chemical Information and Testing Branch

Office of Pollution Prevention and Toxics

USEPA Headquarters 

William Jefferson Clinton Building 

1200 Pennsylvania Avenue, N. W. 

Washington, DC 20460

Re: Follow up to November 17, 2014 Meeting 

Testing Consent Order for Octamethylcyclotetrasiloxane (D4) CASRN 556-67-2

40 C.F.R. 799.5000; EPA-HQ-OPPT-2012-0209

Dear Paul,

The Silicones Environmental, Health, and Safety Center (SEHSC) and the signatory companies to 

the Enforceable Consent Agreement for Environmental Testing for Octamethylcyclotetrasiloxane 

(D4) CASRN: 556-67-2 (ECA) appreciate the U.S. Environmental Protection Agency’s (EPA)’s 

collaborative engagement during the November 17, 2014 meeting discussing the implementation of 

the ECA. We thank you for the opportunity to discuss our progress in moving the monitoring 

program forward and strategies for meeting program challenges. We look forward to continued 

dialogue and cooperation throughout the D4 monitoring program to meet our shared goal of 

collecting a robust data set as well as share and support the implementing concepts expressed in 

the meeting for effectiveness and efficiency. We are providing this letter to summarize the key 

outcomes of the meeting.

POTW Identification

SEHSC reported that 5 residential and 4 industrial sites have agreed to participate in the monitoring 

program and have signed site access agreements. SEHSC noted that at least 3 POTWs have 

expressed an interest in participating in the program, and might be inclined to formally agree to 

participate if they received a letter of encouragement from EPA.

EPA agreed to use the template letter previously provided by SEHSC to develop an encouragement 

letter that will be sent to POTWs to encourage their participation in the program. The template 

encouragement letter is included in Appendix I of this letter. The contact information for those 

POTWs that requested an encouragement letter from EPA is included in Appendix II of this letter.

EPA also agreed to send a letter of appreciation to those POTWs that have agreed to participate in 

the program. The template POTW appreciation letter is included in Appendix III of this letter. The 

contact information for the 9 POTWs that have already agreed to participate in the program is 

included in Appendix IV of this letter. EPA also expressed a willingness to participate in a phone 

call or webinar with POTWs to address questions or concerns about the program with the aim of 

encouraging participation. We look forward to working with EPA in engaging POTWs to encourage
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those that have yet to agree to participate, and to thank those POTWs that have agreed to 

participate in the program.

Site Study Plans / Quality Assurance Project Plan (QAPP)

EPA reviewed the “initial comments” it provided via letter dated October 31, 2014 on the draft Study 

Plan submitted by SEHSC on August 8, 2014 for the four direct discharge sites. EPA also provided 

some initial feedback on the draft QAPP submitted by SEHSC on October 1, 2014 and indicated 

that written comments would be forthcoming by the end of this month. 

SEHSC reviewed some of the challenges that were encountered during a field training exercise that 

was designed to provide the field technicians with practical experience with identifying, securing, 

handling, tracking, and shipping the field samples for the program. These included such items as 

identification of the mixing zone for surface water and benthic organism sampling, collection of 

benthic samples, and weather disruptions that caused delays in sampling scheduling.

There was agreement that the study plans should include appropriate flexibility to allow field 

personnel sufficient discretion for sample collection, and include sufficient detail regarding 

methodological options for sampling for issues such as how far from mixing zone to collect samples 

and how long to look for samples when they are difficult to locate.

It was noted that when challenges are encountered in the field that impact data quality and/or the 

program schedule, those challenges should be communicated as soon as possible to EPA. Health 

Ngo was identified as the primary EPA contact for field sampling issues.

Program Quality and Schedule

In recognition of the unique challenges that can be associated with environmental monitoring 

programs, Jeff Morris indicated that the Agency would adopt a change process for the D4 ECA to 

accommodate potential future challenges regarding data quality and/or the program schedule. The 

request for a change process must include three elements: 

1. Description of incident,

2. Identification of appropriate remedy,

3. Determination of impact on program timing.

EPA agreed that this change process will be used to accommodate the signatory company’s intent 

to submit a complete Study Plan and updated QAPP for all 14 sites (i.e., 4 direct discharge 

locations and 10 POTWs) by February 1, 2015. These documents would address and incorporate, 

as appropriate, the “initial comments” provided by EPA on the draft Study Plan for 4 Direct 

Discharge Sites and those expected to be provided shortly by EPA on the draft QAPP. EPA 

expressed a willingness to modify the ECA schedule to accommodate the proposed change in 

submission date for the complete Study Plan and QAPP. SEHSC will submit a formal request 

under separate cover for a letter of approval from EPA for this change in schedule consistent with 

40 C.F.R. 790.68.

* * *
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Please do not hesitate to contact me directly if you have questions or if any portions of this 

summary are not consistent with your view of the meeting. We look forward to continue to work 

with the Agency throughout completion of the D4 ECA monitoring program.

Sincerely,

Karluss Thomas

Sr. Director, SEHSC
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Appendix I

Template POTW Encouragement Letter

Dear [Wasterwater Treatment Plant Owner/Operator],

In partnership with the U.S. Environmental Protection Agency (EPA), members of the silicones 

industry have agreed to conduct environmental monitoring for a silicone material known as 

Octamethylcyclotetrasiloxane (D4). Ultimately, EPA intends to use this data in an ecological risk 

assessment for D4. To obtain sound, accurate, and representative data for the D4 assessment, we 

would encourage you to allow your wastewater treatment plant (WWTP) to serve as a monitoring 

location for this study.

Under the agreement between EPA and the silicones industry, environmental monitoring will be 

performed at select locations throughout the U.S., including at WWTPs that primarily serve 

residential customers as well as at WWTPs that serve industrial dischargers that process or 

formulate with D4. Industry already has received a participation commitment from several WWTPs. 

In an effort to secure the additional plants required to meet the program testing requirements, your 

WWTP has been identified as a candidate to be a monitoring location. To be clear, this testing is 

narrowly focused, minimally intrusive, and should not interfere with your plant’s normal operations. 

This program will focus exclusively on the fate of D4 in wastewater. 

The silicones industry has hired a consultant with extensive experience in this field to perform the 

monitoring. They should only need access to your site three times: once for an initial site visit to 

confirm sampling locations/logistics and twice to conduct the actual sampling (two events at least 3 

months apart during normal WWTP operations). During the two sampling events, they would 

sample influent, effluent (at the compliance point), and biosolids at the WWTP and biota, surface 

water, and sediment in the receiving waters (i.e., where the effluent and river are well mixed). D4 

will be the one target analyte (no other chemical speciation will be performed).

In order for EPA and industry to gain a fuller understanding of the environmental fate of D4, we are 

depending on the cooperation of WWTPs like your facility. The success of this D4 monitoring 

program hinges upon the voluntary participation of wastewater treatment plants. Without you, the 

silicones industry simply cannot produce the data needed for EPA to conduct a complete 

assessment of D4. Therefore, your role in this undertaking cannot be overstated. EPA will formally 

recognize WWTPs participation at the conclusion of sampling.

More broadly, health and environmental safety are a shared responsibility. In our agency’s efforts to 

be better informed about the safety profile of a variety of substances, we depend on voluntary 

partnerships. I hope you will agree to participate in this process and help EPA and industry 

generate additional data to better protect our environment. 

I hope your facility will agree to participate in this program when contacted by the consultant. 

Should you have any questions or concerns, please do not hesitate to contact ________.

Thank you for your support. 

Sincerely,

Gina McCarthy

Administrator

USEPA
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Appendix II

Contact Information for POTWs Requesting Encouragement Letter

Site Contact & Address

Southport WWTP Jamie Dillard

3880 W Southport

Indianapolis, IN 46217

317 - 927- 6431

City of Winston-Salem Frank Crump

2801 Griffith Rd

Winston Salem, NC 27103

336-727-8000

Hopewell WWTP Jeanie Grindstaff

231 Hummel Ross Road

Hopewell, VA 23860

P: (804) 541-2210
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Appendix III

Template POTW Appreciation Letter

POTW Operator

5 Sunshine Lane

Clearwater, FL 23456

Dear POTW Owner/Operator:

On behalf of the United States Environmental Protection Agency (USEPA), I would like to thank you 

for participating in the environmental monitoring program for Octamethylcyclotetrasiloxane (D4).

The data generated as part of this program will support the development of a risk assessment for 

D4 which USEPA will use to assess its safety. The risk assessment is part of the EPA’s Work Plan 

Chemical program which is an essential element of the Agency’s priority work programs.

The Agency very much appreciates your willingness to be a part of this program, and I am 

personally grateful for your cooperation and willingness to engage with USEPA and industry to 

ensure national efforts to reduce environmental risk are based on the best available scientific 

information. 

Sincerely,

Gina McCarthy

Administrator

USEPA
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Appendix IV

POTWs that Agreed to Participate and Require Appreciation Letters

Site Name Location (Address) Contact Information Name, Phone# 

and Email

The City of Gresham 

Wastewater Services

20015 NE Sandy Boulevard

Portland, OR 97230

Alan Johnston (503-618-3450)

Boulder, CO WWTP 4049 N. 75th Street

Boulder, CO 80301

Chris Douville (303-413-7341; 

douvillec@bouldercolorado.gov)

Lexington, KY (Town 

Branch WWTP)

301 Lisle Industrial Avenue

Lexington, Fayette County, 

KY 40511

Mark Stager (859-425-2413; 

mstager@lexingtonky.gov)

Anthony Ragnone 

Treatment Plant (ARTP), 

Genesee County, MI

9290 Farrand Road

Montrose, Michigan 48457

Joe Goergen (810-232-7662 

ext.2222; jgoergen@gcdcwws.com)

Steamboat Springs WWTP 39565 Routt County Road 

#33

Steamboat Springs, CO 

80477

Gilbert Anderson (970-879-7700; 

wwtp@steamboatsprings.net)

City of Elmhurst WWTP 625 South Route 83

Elmhurst, IL 60126

Dan Rosenwinkel (630-530-3099; 

Dan.Rosenwinkel@elmhurst.org)

South Iowa City WWTP 4366 Napoleon Street SE

Iowa City, IA 52240

Al Figueroa (319-356-5170 ext 6103; 

albert-figueroa@iowa-city.org)

Wichita WWTP 2305 E 57th Street

Wichita, Kansas 67216

Mark Bradshaw (316-303-8703; 

mbradshaw@wichita.gov)

Jackson Pike WWTP 2104 Jackson Pike

Columbus, OH 43223

Jeff Hall (614-645-3248 ext 2211; 

JAHall@columbus.gov)