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_ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460
DEC 16 20 1 14

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION Karluss Thomas Senior Director Silicones Environmental, Health, aizd Safety Center American Chemistry Council 700 2nd Street NE Washington, DC 20002 Re: Follow-up to November 17, 2014 Meeting Testing Consent Order for Octamethylcyclotetrasiloxane (134) (CASRN: 556-67-2) 40 C.F.R. 799.5000; EPA-HQ-OPPT-2012-0209 Dear Mr. Thomas: This letter is in response to your November 25, 2014, letter summarizing key outcomes from the November 17, 2015, meeting between the Silicones Environmental, Health, and Safety Center (SEHSC), the U.S. Environmental Protection Agency and the signatory companies to the Enforceable Consent Agreement (ECA) for Environmental Testing for Octamethylcyclotetrasiloxane (D4) (CASRN. - 556-67- 2)(ECA). The Agency has reviewed the summary and is providing the following comments: 1. The Agency will send a letter of appreciation to the wastewater treatment plant sites that meet the site selection criteria outlined in Appendices 2 and 3 of the ECA for D4 and, accordingly, have been selected to participate in the D4 environmental monitoring program. 2. Heather Njo is the primary EPA contact for the D4 ECA, including field sampling issues. 3. The Agency agrees that the Study Plan and Quality Assurance Project Plan (QAPP) should include appropriate flexibility to allow field personnel sufficient discretion for field sampling activities; however, modifications of the ECA (including the ECA schedule) shall follow procedures identified in the ECA and codified in 40 CFR 790.68. 4. Further discussion of the elements of the proposed "change process" for the D4 ECA is needed. The Agency, therefore, recommends that SEHSC incorporate language into the Study Plan and QAPP for:
a. Routine versus non-routine adjustments, b. Minor versus major changes to field sampling schedule, c. Criteria for notification to EPA of routine, non-routine, and minor or major changes. An example of criteria developed for the perfluorooctanoic acid (PFOA) environmental assessment program is attached for your consideration (please refer to page 18, Section VI.B).
Internet Address (URL) • http:/lwww.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper5. Routine adjustments and minor changes should be communicated to EPA (and documented in

interim or final reports), but may not need to be "reported" in real time. Non-Routine adjustments and major changes need to be reported and approved by EPA, in real time and before they are undertaken in the field or laboratory. 6. The Agency is willing to work with SEHSC and the signatory companies toward a positive outcome of the ECA and is looking forward to receiving the complete Study Plan and QAPP for all 14 sites by February 1, 2015. If you have any questions, please contact Heather Njo of my staff at 202-564-2574 or at njo.heather@epa.gov

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### Sincerely, 

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# ~ W leff Morris, Deputy Director for Programs Office of Pollution Prevention and Toxics

Enclosure