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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

DEC 16 20114 

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 Paper 
5. 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 . 

Sincerely, 

r ~Wleff Morris, Deputy Director for Programs 

Office of Pollution Prevention and Toxics 

Enclosure