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

 DECEMBER 6, 2012

 1:35 P.M.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 2

1 APPEARANCES

2 Ward Penberthy, EPA

3 Cathy Fehrenbacher, EPA

4 Ellen Mihaich, ERR (contractor for Bluestar)

5 Paul DeLeo, American Cleaning Institute

6 Charles Staples, Attourney for SEHSC

7 Hugh Flack, Wacker Chemical

8 Gene Browning, Shinetsu Silicones

9 Betsy Carlton, Bluestar Silicones

10 Kevin West, Momentive

11 Lisa Dumars, Momentive

12 Russell Mait, Evonik

13 Kathy Plotzke, Dow Corning

14 Karluss Thomas, SEHSC

15 Marcus Aguilar, EPA

16 Paul Lewis, EPA

17 David Tobias, EPA

18

19

20

21

22

23

24

25
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 3

1 U.S. ENVIRONMENTAL PROTECTION AGENCY

2 SILOXANE TECHNICAL WORKING GROUP/POTW MONITORING

3 December 6, 2012

4 MR. PENBERTHY: We will take attendance.

5 MR. THOMAS: Okay.

6 MR. PENBERTHY: Karluss, why don't you

7 start?

8 MR. THOMAS: I'm Karluss Thomas with the

9 Silicone's Environmental Health and Safety Council.

10 MS. PLOTZKE: Kathy Plotzke with Dow

11 Corning.

12 MR. MAIT: Russell Mait, Evonik.

13 MS. DUMARS: Lisa Dumars, Momentive.

14 MR. WEST: Kevin West, Momentive.

15 MS. CARLTON: Betsy Carlton, Blue Star

16 Silicones.

17 MR. BROWNING: Gene Browning,

18 representing Shin-Etsu Silicones of America.

19 MR. FLACK: Hugh Flack, Wacker Chemical

20 Corporation.

21 MR. STAPLES: Charles Staples, with the

22 SEHSC.

23 MR. DELEO: Paul DeLeo, American

24 Cleaning Institute.

25 MS. MIHAICH: Ellen Mihaich, ER Squared
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 4

1 for Blue Star.

2 MS. FEHRENBACHER: Cathy Fehrenbacher,

3 EPA.

4 MR. PENBERTHY: Ward Penberthy, EPA.

5 MR. TOBIAS: David Tobias, EPA.

6 MR. LEWIS: Paul Lewis, EPA.

7 MR. PENBERTHY: We'll go around the

8 room.

9 MR. BRUSHESKI: -- Bursheski (Phonetic)

10 with Dow Corning.

11 MS. BARKAS: Jessica Barkas, EPA.

12 MS. EISENREICH: Karen Eisenreich, EPA.

13 UNIDENTIFIED SPEAKER: --, EPA.

14 MR. AGUILAR: Marcus Aguilar, EPA.

15 MR. AVCIN: Joe Avcin, EPA.

16 UNIDENTIFIED SPEAKER: --, EPA.

17 MS. HOPKINS: -- Hopkins, EPA.

18 MS. BILL: Karen Bill, SEHSC.

19 MS. BURERA: Tracey Burera, SEHSC.

20 MR. CRAFT: -- Craft representing

21 Evonik.

22 MR. KOZERSKI: Gary Kozerski with Dow

23 Corning.

24 MR. ANDERESON: Steve Anderson, EPA.

25 MR. PENBERTHY: Could the people on the
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 5

1 phone identify themselves one by one.

2 UNIDENTIFIED SPEAKER: --

3 MR. HILEY: This is Raymond Hiley with

4 Momentive Performance Materials.

5 MS. SMITH: This is Kristan Smith with

6 Momentive Performance Materials.

7 MS. MCNETT: Deborah McNett with Dow

8 Corning.

9 MR. POWELL: Greg Powell with Dow

10 Corning.

11 MR. JIN: Jason Jin, Dow Corning.

12 UNIDENTIFIED SPEAKER: --

13 MR. GRIFFITH: Patrick Giffith with the

14 Los Angeles County Sanitation Districts.

15 MR. PENBERTHY: Has everyone on the

16 phone stated their name?

17 MR. KOGER: John Koger, Personal Care

18 Products Counsel.

19 UNIDENTIFIED SPEAKER: -- Personal Care

20 Products Counsel.

21 MR. PENBERTHY: Anyone else? Okay.

22 Paul, do you want to go through our how meetings are

23 typically run as usual?

24 MR. LEWIS: Sure, thank you, Ward.

25 Again, this is Paul Lewis from EPA Chemical Division.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 6

1 I want to welcome everyone today for this meeting

2 dealing with the Siloxane's ECA, and we have two hours

3 scheduled for this meeting. We are going to begin by

4 having a presentation on Objectives for EPA's

5 Objective for Siloxane Monitoring followed by

6 estimated costs of monitoring, EPA's plan for D4 risk

7 assessment, and give an opportunity for SEHSC

8 perspectives on D4 risk assessment. This meeting also

9 provides an opportunity like we have had for our other

10 ECA discussions for interested parties to identify

11 themselves and divide their input in terms of the

12 deliberations today, and then we will adjourn.

13 Like, this meeting similar to other

14 meetings, all of the materials that will be presented

15 today will be available at docket. So, we will make

16 that available for public inspection. Any questions

17 for me in terms of the format for our discussion today

18 before I turn it back to Ward to kind of kick-off our

19 discussion today.

20 MR. THOMAS: Just one quick question.

21 Is it okay if during the presentations if we have

22 questions we can ask informal questions during the

23 presentations, or would you prefer for us to wait

24 until afterwards.

25 MR. PENBERTHY: Interested parties can
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 7

1 ask questions, sure.

2 MR. THOMAS: Okay, thank you.

3 MR. PENBERTHY: Observers should

4 observe.

5 UNIDENTIFIED MALE: Could you move a

6 couple of those chairs away from the end of the table,

7 it is tough to see the screen?

8 MR. LEWIS: Sure, we can do that. Thank

9 you. Any other questions in terms of our meeting

10 today?

11 MR. AGUILAR: I just want to remind

12 everybody if you can please state your name before you

13 make a comment, that will really help with the

14 transcript making sure that it is accurate. I know

15 people do not remember every time, but if you could

16 please try and make sure you do that, that will really

17 help us out.

18 MR. LEWIS: Thank you, Marcus.

19 MR. PENBERTHY: And we have a few extra

20 copies of the presentation if you don't have one- that

21 we can pass around.

22 MR. AGUILAR: There is also a sign-in

23 sheet going around, so if you could -- you know, write

24 your name, who you are representing and then your

25 email address, that would also help us out as well.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 8

1 MR. LEWIS: Ward, do you want to take it

2 or leave it for Cathy?

3 MR. PENBERTHY: Uh, no Cathy is going to

4 make our first presentation. Any thoughts you would

5 like to say, before we start off?

6 MR. THOMAS: No, we do have a

7 presentation, we will make it available during the

8 course of the meeting. I apologize for not having it

9 sooner, but we will make that available, and we will

10 provide it to the document as well. The docket as

11 well.

12 MR. LEWIS: Thank you.

13 MR. PENBERTHY: Okay, Cathy.

14 MS. FEHRENBACHER: Okay. So, again,

15 this is Cathy Fehrenbacher from the EPA's office of

16 pollution prevention and toxics, and my presentation

17 is on the EPA objectives for the Siloxane

18 Environmental monitoring. There is a brief

19 presentation that I will be walking through. So, we

20 have been very clear in identifying our objectives for

21 the Siloxane Environmental Monitoring, and this really

22 goes back to some communications in writing -- most

23 notably, on December 20th, 2010, and then email as

24 well as in a follow-up letter of December 19, 2011.

25 There were informal pre-ECA process meetings, and we
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 9

1 have also been very clear on these objectives during

2 the ECA process. And, we excerpted text from these

3 written communications, and included it within the

4 slides for this presentation. So, from these early

5 communications, we identified for D4 and D5

6 environmental monitoring that the program is intended

7 to develop a better understanding of the sources and

8 pathways of environmental concentrations and

9 environmental media, and by biota associated with

10 industrial releases from manufacturing processing

11 formulation and high volume industrial or commercial

12 end users. We also clarified that the intent was to

13 include the full product life cycle from manufacturing

14 through processing formulation high volume industrial

15 or commercial end use and disposal. And, we

16 identified the proposed essential elements of the

17 monitoring program which would include representative,

18 municipal and on-site industrial waste water treatment

19 plant monitoring, concentrations and flow rates for

20 both influent and affluent biosolids and potential

21 migration from land application. We addressed site

22 selections stating that it should encompass a

23 representative range of on-site handling and treatment

24 practices for waste, discharge waters, nearby

25 population centers, and low and high-flow conditions.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 10

1 We stated that the sampling locations should include

2 points upstream and downstream progressively distant

3 from the point of discharge, and that we were

4 interested in examining surface waters, suspended

5 solids, bottom sediments, air, biosolids, benthic, and

6 aquatic organisms.

7 In terms of monitoring site selection

8 as I stated, the program -- yes, Karluss?

9 MR. THOMAS: One comment on the first

10 slide before you move on to the second one. I did

11 want to point out that you are right that this

12 information was communicated a couple of years ago, so

13 prior to our initiating formal ECA negotiation

14 process, but I did want to point out that our

15 understanding was that the scope of what is described

16 in this initial slide had been narrowed pretty

17 substantially based on subsequent discussions. I

18 would point out not only the conference calls that we

19 held this year, but the discussions that we had prior

20 to those conference calls in our view suggested that

21 the scope of the program had been narrowed to not only

22 exclude the product life cycle components, but also

23 probably the on-site industrial waste water component

24 as well. So, and it was our view that the scope had

25 been narrowed to focus exclusively on data that would
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 11

1 facilitate the development of an environmental risk

2 assessment, so that is essentially the basis for our

3 proposal. So, I just wanted to clarify that indeed

4 these things were communicated very early on in the

5 process, but our proposal was responsive to what we

6 thought was our most recent understanding of what the

7 scope of the program was -- which from out

8 understanding was much more narrow than what is

9 described here, and I think that some of the

10 subsequent communications between us and the EPA would

11 probably highlight that as well.

12 MR. PENBERTHY: Yes, I think you are

13 right, that we have changed some of our positions from

14 this, and I think there is a slide later on that lists

15 the major changes that we've made to be accommodating

16 to our mutual interest, so.

17 MS. FEHRENBACHER: Okay, so moving on,

18 the next slide as I said addresses the monitoring site

19 selection. Again, these are from the early

20 discussions. Representative watersheds and industrial

21 manufacturing processing and formulation sites. A

22 representative number of sites should be selected. We

23 had a lot of discussion about conceptual site models,

24 which characterize sources or and their releases for

25 all manufacturer, processor and formulator facilities.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 12

1 We also had a number of discussions about treatment

2 configurations of waste water treatment plants,

3 including activated sludge, lagoons, et cetera. We

4 stated that the population of the area connected to a

5 facility must be a consideration in the selection of

6 sites for both municipal and waste water treatment

7 plant sites and for the MPF sites. And, in addition,

8 geologic, geographic and climatic parameters must also

9 be considered. In addition to the characteristics of

10 the receiving water body and finally, that we should

11 be careful in selecting which POTW's would be chosen

12 for a given metropolitan area, as a large municipality

13 may have facilities of varying sizes.

14 Okay, and then moving on to the next

15 slide, which is focusing on biota monitoring. Biota

16 monitoring, in terms of EPA objectives must support

17 the evaluation of bio- accumulation and bio18 magnification in biota including at least three

19 replicate samples of specific species per site with

20 fish species selected to represent at least two

21 trophic levels or levels of aquatic food web, low and

22 high. And, additional benthic species and

23 environmental occurrence sampling.

24 MS. PLOTZKE: One question I have there,

25 Cathy maybe you'll get to it when you get to that last
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 13

1 slide, on the biota type of monitoring, and how have

2 you factored in what's already available out there on

3 the food webs and what criteria have you used to say

4 that would apply to generating this type of

5 information?

6 MS. FEHRENBACHER: We have evaluated all

7 of the available data.

8 MS. PLOTZKE: Is there a set of criteria

9 that you're using to define what isn't already

10 available or what isn't known and what needs to be

11 known? I think that will be helpful in understanding

12 that.

13 MS. FEHRENBACHER: Okay.

14 MS. PLOTZKE: Maybe you will get to it

15 at that last slide.

16 MR. PENBERTHY: Maybe, I guess what's

17 unclear about the slide?

18 MR. THOMAS: Well, what specifically

19 about the available data would not allow you to make a

20 determination about bio-accumulation at this point?

21 What specific needs are there that aren't met with

22 existing data that would allow you to make a

23 determination here?

24 MR. PENBERTHY: I don't think we think

25 there is an adequate data set.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 14

1 MR. THOMAS: Are there specific

2 components in particular that you might point to in

3 terms of where the inadequacies are?

4 MR. PENBERTHY: There's just not enough

5 data to that. I don't know Karen, do you have

6 anything to add to that?

7 MS. ELZENREICH: Yes, this is Karen

8 Elzenreich, EPA. What we need is data that is going

9 to represent the industrial facilities here in the

10 U.S., much of the data is not for species found in

11 food webs. That is not all of the data, but what

12 we're asking for, a representative sampling of waste

13 water treatment plants here in the U.S. that represent

14 the manufacturing, that has overlooked the biota to be

15 represented as well.

16 MS. PLOTZKE: So, are you concerned that

17 the behavior of these chemicals in the biota and in

18 the food web would be different under those

19 circumstances compared to what we have already

20 generated?

21 MS. ELZENREICH: It could be potentially

22 different.

23 MS. PLOTZKE: Well, for us, it tries to

24 address, sort of the chemical/physical properties of

25 the materials from what's already known, but more on
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 15

1 that later then.

2 MS. FEHRENBACHER: Okay. Thank you.

3 And, then finally, in terms of the EPA objectives with

4 respect to existing monitoring data, the Agency made

5 it very clear that we would consider existing

6 monitoring data collected at sites inside and outside

7 the U.S. provided there is shown to have similar and

8 representative site characteristics. And, these

9 characteristics would include the water shed, the air

10 shed, the facility production releases of D4 and D5,

11 run-on and run-off potential, waste generation,

12 handling and disposal for on-site waste water

13 treatment facilities, on-site waste disposal unit --

14 such as, waste piles, dumps, ponds, pits, land fills,

15 ditches, or land applied sledge areas. The site

16 climate, hydrology, geology, soil type, receiving

17 stream morphologies, sediment, flow-rate, nutrient

18 load, water chemistry, aquatic biota, on and around

19 the chosen manufacturing facilities. In addition, we

20 said that the submission of existing monitoring data

21 is encouraged to further enhance our understanding of

22 the behavior of D4 and D5 in the environment.

23 Although, the agency will have a high bar for a

24 substitution of foreign data for monitoring at U.S.

25 sites based on representativeness.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 16

1 MS. PLOTZKE: Kathy Plotzke, one other

2 question on that is, do you also, have you defined

3 criteria for accepting non-U.S. site data. Is there

4 any guidance that you would give us on what would be

5 acceptable as a non-U.S. site?

6 MS. FEHRENBACHER: Well, I think this is

7 fairly clear in terms of the criteria that we would

8 use to evaluate non-U.S. data. We are looking at

9 representativeness, and that there would be a high bar

10 for acceptance of non-U.S data.

11 MS. PLOTZKE: Well I guess that's

12 probably the part that's a little bit challenging to

13 understand as the high bar. I think we could lay out

14 the criteria around all of the sites that we have

15 already monitored or where there is monitoring data

16 where it meets a lot of these, but what's that

17 acceptance criteria?

18 MR. PENBERTHY: I think you just need to

19 make your case.

20 MS. PLOTZKE: Make the case?

21 MR. PENBERTHY: Right.

22 MS. FEHRENBACHER: I think we have made

23 it clear that we would welcome data that you have, and

24 we would evaluate whether it is representative of

25 U.S., and then we would use it accordingly. And,
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 17

1 these are the criteria that we would use in evaluating

2 the data.

3 MR. MAIT: But, you do not have any

4 quantitative type process here?

5 MS. FEHRENBACHER: Well, I mean in terms

6 of representativeness, there are -- we do not have

7 specific criteria, but we know how many MPF facilities

8 there are in the U.S. We know that the data

9 available, and we have information -- we have had

10 lengthy discussions about sample size and the numbers

11 of samples. So, those would also be additional

12 criteria that we would consider in determining how we

13 would and whether we would utilize the data in our

14 assessments.

15 MR. THOMAS: I think part of the

16 difficulty as well, Cathy, is that much of what is

17 described here has not been proposed for monitoring

18 even the U.S. site, so it is difficult to understand

19 from a quantitative perspective how would you compare

20 the representativeness of non-U.S. data to U.S. data

21 from the standpoint of these considerations when much

22 of this information won't even be known about the U.S.

23 sites.

24 MS. FEHRENBACHER: Well, I mean for

25 instance -- we have had some discussions -- some of
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 18

1 the -- in fact, a lot of the data that is available

2 represents marine environments, and for the risk

3 assessment that we would be conducting, we would be

4 looking at fresh water environments, so that data is

5 not very relevant to the assessment that we would be

6 conducting.

7 MR. PENBERTHY: I think a monitoring

8 program if it was developed -- the ECA would have

9 provide some information relevant to this and to these

10 specifics that -- so that those circumstances of

11 monitoring were understood.

12 MS. FEHRENBACHER: Okay, so in terms of

13 the last slide, and Karluss you made a comment that

14 there have been modifications to the agencies

15 objectives, and we agree there have been modifications

16 to the EPA siloxane monitoring objectives during the

17 ECA negotiation. In fact, we have intended to focus

18 on the monitoring -- the minimum defensible monitoring

19 needed for risk assessment purposes, and so, we have

20 agreed to a smaller number of MPF monitoring sites,

21 fewer POTW monitoring sites, the deletion of air

22 monitoring, and the deletion of down-stream

23 monitoring. We have also limited the biota monitoring

24 to industrial sites. We believe that this is a bare

25 bones plan that allows for a scientific assessment,
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 19

1 and just in closing, again the Agency has been very

2 clear from the start on the elements of the monitoring

3 plan. We have again made modifications during the ECA

4 discussions and the formal negotiation to arrive at

5 what we believe is a minimum defensible approach for a

6 scientifically sound national risk assessment.

7 MR. THOMAS: So, now just for

8 clarification, when you say "fewer MPF monitoring

9 sites," our initial proposal was that the four direct

10 discharges be monitored. What has been beyond the

11 change there?

12 MR. PENBERTHY: Well- as you recall we

13 actually started at 41 and 42, and we dropped the

14 number right? Of the POTW's sorry.

15 MR. THOMAS: No, I am talking about at

16 the first point on the fewer MPF monitoring sites.

17 MR. PENBERTHY: Well, I think if you

18 look at our initial written communications- that were

19 a lot more expansive about the processing formulating

20 sites than we are. But defiantly yeah we've come -.

21 MR. THOMAS: Many of those maybe even

22 most of those we have no control over. I mean many of

23 the processors and formulators in particular are not

24 going to be SEHSC sites, so from the standpoint of a

25 universe of sites over which we have some control, we
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 20

1 have essentially offered all of the direct discharges.

2 MR. PENBERTHY: Right, and, so I've

3 recognized that and have targeted or went to focus on

4 the sites that you have control over.

5 MR. THOMAS: Okay. All right, I guess it

6 was just unclear how that was a change, but I just

7 want to -- overall, I think again if we go back to

8 what was originally communicated in the discussions

9 maybe a year or two ago, I think we would both agree

10 that there has been some narrowing of the scope such

11 that we provide a useful data set to support a risk

12 assessment. I think on that point we would agree.

13 And, I guess I would say from our standpoint, we have

14 modified our original proposal pretty substantially.

15 That first slide that you put up -- the excerpt taken

16 from the letter that we got from Dr. Doa a couple of

17 years ago was in response to a proposal that has not

18 been the focus of these discussions at all. But, that

19 I would say represents a substantial change from our

20 perspective. I think in addition, during the last

21 meeting we also offered to change the mix of waste

22 water treatment types as a result of some of the

23 concerns that have been expressed. So, I think from

24 our perspective, we would say that -- you know, we

25 have been flexible as well with respect to those
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 21

1 elements of the program that we think would need to be

2 changed to accommodate a risk assessment.

3 MR. PENBERTHY: Okay.

4 MR. GRIFFIN: This is Patrick Griffin

5 from Los Angeles County Sanitation Districts and

6 NACWA. I had a clarification question. You mentioned

7 in that slide that you guys deleted air monitoring. I

8 am not recalling that in any of the discussions then.

9 I know it was not a big factor any how; but, I think

10 in the drafts that they sent to you, there was one of

11 POTW that was planned for air monitoring and also in

12 the conceptual site model, it looked like the only

13 pathways for human exposure were by air. Can EPA

14 touch on that a little bit?

15 MR. PENBERTHY: I mean, I think over the

16 course of discussions, we have pretty much determined

17 that would not be our main focus; but, it was included

18 in our last proposal recognizing that folks like you

19 are participating with interested parties in the

20 process, so while that might be a concern of yours, it

21 is not necessarily one of ours.

22 MR. LEWIS: Other comments from people

23 on the phone, or around the room? Okay, Mr. Tobias,

24 do you want to talk about some estimated costs?

25 MR. TOBIAS: Sure.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 22

1 MR. LEWIS: Thank you.

2 MR. TOBIAS: Again, David Tobias from

3 the EPA, and we are going to be discussing some data

4 sources that we looked at to create cost estimates for

5 the monitoring programs. Next slide thanks. So, ther

6 are three main sources we have for creating cost

7 estimates for these programs -- the first one is just

8 to give an idea of how -- what the cost was for a

9 recent monitoring program that was completed by the

10 office of water, called the Target National Sewage

11 Sledge survey. The next step we did was to talk to

12 Environment Canada about the costs that they

13 encountered during their recent monitoring program for

14 Siloxanes at waste water treatment plants, and then

15 the last bullet point indicates that we also went to a

16 academic with the EPA proposal and asked for a cost

17 estimate or a quote from him for how much he thought

18 he would require to perform the EPA's monitoring

19 program. Thanks.

20 So, the office of water in 2006 and

21 2007, they went to 74 waste water treatment plants

22 spread across the country -- gathered only sewage

23 sledge samples, and they -- the stats, they are there

24 - the difference they had is they have one media they

25 are monitoring, only the sludge, but they are
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 23

1 interested in a much wider spectrum of possible

2 chemicals in those samples. The list is there, it is

3 pretty broad -- 145 total with chemicals coming --

4 metals, hydrocarbons, flame retardants,

5 pharmaceuticals, steroids, and this would make their

6 plan more costly and complex for analytical efforts

7 per sample, and that is -- The important thing I think

8 about is that these were not performed by ORD, these

9 are not internal government research, but the EPA

10 awarded these in externally competitive bid contracts

11 to three outside labs, and this is the pretty

12 inclusive price is $1.3 million with all of the things

13 listed there -- labor, travel, sampling, handling, the

14 sample analysis report writing, and also the contract

15 management for that. And, there are many more details

16 that you can obtain from the results of the study on

17 the waters web page that is given at the bottom of the

18 slide.

19 MS. PLOTZKE: David, one quick question

20 -- do you know if they included a QAQC program as a

21 part of this, I did not get a chance to take a look at

22 their website.

23 MR. TOBIAS: I do not know the complete

24 details of it, but if you look at their documentation,

25 they do discuss -- they took duplicate samples and
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 24

1 they discussed how they performed the QAQC.

2 MR. PENBERTHY: An EPA monitoring

3 program would be required to do that.

4 MR. TOBIAS: Yes. Thank you. So, I

5 talked to a Meltran Alaee at Environment Canada who

6 was one of the leads for performing Canada's Siloxane

7 monitoring program, and I asked for him to give

8 estimates of what his labor costs would be for

9 different components of his monitoring program --

10 including labor costs for travel, what his estimated -

11 - his analytical costs would have been per sample.

12 How much he had to pay for fixed costs -- for things

13 like isotope analytical standards, and lab supplies;

14 but, the big difference between this and the OW study

15 is this was performed in house at Environment Canada,

16 so he had access to probably lower labor costs similar

17 to a university that would be post-docs and graduate

18 students. So, I did not use any of his numbers for

19 what his labor costs were, and I discuss on the

20 subsequent slides what I did use instead for those

21 costs.

22 MS. PLOTZKE: Sorry, this is Kathy

23 again, and the question -- so, and for this would be

24 what type of samples that they collected? Was it just

25 influent, affluent?
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 25

1 MR. TOBIAS: The?

2 MS. PLOTZKE: Because they did a number

3 of different programs, so I am not sure what this is.

4 MR. TOBIAS: This is the compository --

5 the in fluent/affluent sediment and water and sediment

6 were the two that they did.

7 MS. PLOTZKE: Right.

8 MR. TOBIAS: You are rightthey did not

9 have biota in the Canadian program.

10 MS. PLOTZKE: Right, I just wanted to

11 make sure.

12 MR. TOBIAS: Yes.

13 MR. TOBIAS: Anyone else have questions

14 on this slide or anybody on the phone? Just to make

15 sure. Okay. So, what I used these numbers to create -

16 - I used a preliminary cost estimate for the two

17 proposals that are in discussion right now. The first

18 slide is for the SEHSC proposal. So, the SEHSC

19 proposal has nine sites and I multiplied the numbers

20 on the previous page for travel and labor costs that

21 Mehran gave for traveling and labor at those sites.

22 There are 55 samples in the current SEHSC program. I

23 used his numbers for laboratory supplies and the study

24 would be completed, and then I put in numbers for the

25 labor costs. Now, so I get the labor costs, I have
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 26

1 eight workers for six working months at $15,000 per

2 month, and to get that number, there are two numbers

3 that it is very close to -- the $15,000 per month.

4 That is very close to what the EPA would pay for a

5 contract labor for an entire month, which is

6 approximately $100 an hour, or $16,000 a month; and,

7 it also is very close to what it comes out to be for

8 the cost, not the salary of a fully-loaded government

9 staff employee. It comes very close to $15,000 as

10 well. So, by taking together those numbers, you get

11 an SEHSC proposal estimated to cost around $800,000.

12 MS. PLOTZKE: And, this is Kathy Plotzke

13 again, I have a question on the 55 samples, what was

14 the basis for coming up with the 55 for the number of

15 samples for our proposal?

16 MR. TOBIAS: That was out of your plan.

17 You had four sites with the first -- your four sites

18 that were directly controlled by you, and then five

19 sites outside. So, for the four sites directly

20 controlled by you, I think there was -- was it

21 effluent, water, sediment and in fluent -- so, four

22 samples; and, then at the other sites there were --

23 plus the fish -- and, at the other sites, I think --

24 did you test three fish, I think?

25 MS. PLOTZKE: One fish, one benefit.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 27

1 MR. TOBIAS: One fish, one benefit.

2 MS. PLOTZKE: Yes. Okay, so, one sample

3 per

4 MR. TOBIAS: One of each. One of each

5 medium.

6 MS. PLOTZKE: -- per environmental

7 matrix?

8 MR. TOBIAS: Yes.

9 MS. PLOTZKE: Okay. That was my -- when

10 I am looking at this, and I see 55, that was not our

11 number, because we look at it -- we have based it on

12 our experience where we have already been doing

13 monitoring. Recently, when we just went out in Lake

14 Champlain

15 MR. TOBIAS: Uh-huh (indicating

16 affirmatively).

17 MS. PLOTZKE: -- we are collaborating

18 with the University of Vermont, and we had 720 samples

19 in total for a very similar sampling program. When we

20 have done a power analysis to look at what is the

21 adequate number as well as the inclusion of all of our

22 quality control field and analytical samples. So,

23 that to me I saw that big difference. I did not know

24 what the basis was. So, you were assuming one sample

25 collection for each matrix we put down?
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 28

1 MR. TOBIAS: That was.

2 MS. PLOTZKE: Okay.

3 MR. TOBIAS: See, the problem is, we do

4 not have the details that the ECA completed at this

5 point, so -- you are not sure how many to put in, and

6 these numbers are saying how I do not remember us ever

7 discussing what that number would actually turn out to

8 be.

9 MS. PLOTZKE: Yes, and I think what we

10 had always indicated is, what we would do is the power

11 analysis, and we would determine those numbers. But,

12 this is based on our experience.

13 MR. TOBIAS: Okay.

14 MR. MAIT: Dave, Russell Mait . You

15 only considered how many sampling events?

16 MR. TOBIAS: This is one sampling event.

17 MR. MAIT: In my recollection, there was

18 two -- so, that only represents a single event. Is

19 that correct?

20 MR. TOBIAS: That's true. The sampling

21 number actually is for just one event. Go the next

22 one. So, I had to update the number of samples

23 analyzed here from due to a couple of different

24 estimates, and I will get to that -- that is the red

25 number -- but, this is for the EPA plan. The number
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 29

1 of sites has changed -- there are 25 sites. The

2 number of samples changed, and we have had discussions

3 on this -- so, this number actually is also bringing

4 down the reduction in the number of biota, and to only

5 the industrial sites; and, the number that the -- what

6 is cut and pasted into the proposal unfortunately was

7 from a larger program that we had been discussing in

8 the past. The laboratory supplies and analytical

9 standards are just scaled up, and we have increased

10 the amount of labor costs that we see based upon the

11 increase in the number of sites. So, it is

12 proportional to what that would be, and the number

13 that comes out from that is about $2.1 million.

14 MR. DELEO: This is Paul DeLeo from the

15 American Cleaninng Institute. So, David, are you

16 saying you believe that program could be carried out

17 to your satisfaction by taking 148 samples?

18 MR. TOBIAS: I say that is what is

19 within our proposal.

20 MR. DELEO: Okay.

21 MR. TOBIAS: The ECA was not complete --

22 to be honest, so, this is -- that is why I've also at

23 the top I had preliminary cost estimates for each one.

24 MS. FEHRENBACHER: Does that- may not

25 include QAQC samples?
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 30

1 MR. TOBIAS: There could be other costs

2 that would come in. I agree with that. That is why on

3 each one I've been saying it is a preliminary cost

4 estimate.

5 MR. MAIT: David, Russell Mait. So, is

6 this a single sampling event, so it is comparitable to

7 the prior slide?

8 MR. TOBIAS: The samples would have to

9 be updated. I did not think that you would need 10

10 workers for 12 working months to do one sampling event

11 to be honest. But, the number of samples might be

12 incorrect for that purpose.

13 MR. LEWIS: And do they got idea on how

14 many months?

15 MR. TOBIAS: We were -- there is a lot

16 of conversation on how do so to establish how many

17 labor months you would need? Given that the plan is

18 not completed yet, so, the -- we did this based upon

19 the workers and the working months. I talked to the

20 Canadians about how many people were involved, how

21 many people ended up on their publications. Talked

22 with people in the EPA who have done environmental

23 monitoring projects to try to come up with an

24 estimate. So, the whole thing is in the context of a

25 preliminary cost estimate.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 31

1 MS. PLOTZKE: And, again this is Kathy

2 Plotzke, but 148 is based on one sample per

3 environmental matrix and any inclusion of field or lab

4 QC's?

5 MR. TOBIAS: There is not QC-specify in

6 our plant right now, so it is not described here.

7 MS. PLOTZKE: That is one of the things

8 that we obviously have factored into ours.

9 MR. TOBIAS: Okay.

10 MS. PLOTZKE: And, that is a critical

11 component for these materials given their chemical

12 physical properties -- the volatility. We have seen

13 loss of these samples even transferred from the field.

14 Canada has seen it as well. So, having field QC's as

15 well as lab QC's is very critical for these materials.

16 MR. TOBIAS: That is true. I agree.

17 MS. FEHRENBACHER: Yes, we would

18 certainly agree with that, and I think the information

19 that David has presented does not include

20 consideration for QAQC's samples we - We do agree

21 with you that those samples and criteria are

22 important, and so that would increase the cost of the

23 estimates that were providing, but we don't believe it

24 would be appreciable cost. It would be an incremental

25 additional cost.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 32

1 MS. PLOTZKE: It is actually quite

2 substantial. I mean, we have been doing a number of

3 programs already, and a good portion of our samples

4 are field and lab QC's because of the unique

5 challenges from both a loss and a contamination sample

6 stability from transport to the field to the lab. It

7 is significant with these materials. The other thing

8 that we have seen and have factored in to our cost is

9 the pre-work for either going out to the site and

10 ensuring you have identified the appropriate areas to

11 sample from, how you are going to sample. That's been

12 critical to do a pre-field evaluation, and then the

13 other part is the analytical method validation with

14 which ever contract laboratories you would use. The

15 analytical labs -- the analytical methods for these

16 materials are quite challenging, and each lab has to

17 establish that they can conduct those type of analyses

18 per matrices in their laboratory. So, that has all

19 been factored into our cost.

20 MR. MAIT: Dave, Russell Mait. Just to

21 go back, if I do my math right just like I did on the

22 other side. 25 sites times 6 would give you 150,

23 would it not?

24 MR. TOBIAS: 25 times 6. It is not that

25 straight forward unfortunately, because
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 33

1 MR. MAIT: It appears to be.

2 MR. TOBIAS: The -- you want to get to

3 the -- are you worried about the 148 number right now?

4 MR. MAIT: Yes, I am trying to get to

5 148 because that is what you put down.

6 MR. TOBIAS: Unfortunately, there are

7 three fish at some of the sites, not at others. There

8 would be sludge monitoring at some of the sites, not

9 the others -- because, you said for your four direct

10 sites, the sludge has all been incinerated. Even in

11 your program you have differences in the meti -- I can

12 lay out how I multiplied out those numbers. If you'd

13 like.

14 MR. MAIT: But, at a very high level

15 like we are dealing right now, that is about what it

16 is? Isn't it?

17 MR. TOBIAS: So, you do not want me to

18 say 148, you want me to say 150. Is that it?

19 MR. MAIT: No, I am just trying to get

20 at how you got 148.

21 MR. TOBIAS: It is by taking whether

22 there are

23 MR. MAIT: I am just an engineer. I am

24 not a toxicologist. You guys are all smarter than me.

25 MR. TOBIAS: I am not a toxicologist
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 34

1 either, but it was by adding up the in fluent

2 affluent, sludge was going to be there, water,

3 sediment, and then perhaps up to three fish species

4 depending upon the site. I agree, but for the needs

5 of analysis at this level, it does not matter.

6 MR. MAIT: Okay.

7 MR. TOBIAS: Whether it is plus or minus

8 a few.

9 MR. MAIT: Okay.

10 MR. TOBIAS: I also have been trying to

11 emphasize this message. So, are there any more

12 comments on this slide? None? Anybody on the phone?

13 So, the EPA described its program to a

14 professor at SUNY Albany. We sent him the proposal

15 that we have been discussing with the requirements for

16 the number of samples, number of sampling events, the

17 different media, and we also were fortunate enough to

18 find someone who has performed previous work on

19 siloxanes and POTW's and consumer products. We asked

20 him how would a fair quote for what he would need to

21 do this work, and his quote for analytical work

22 travel, sample collection and labor, he gave a cost

23 estimate a little below $500,000 for the EPA proposal.

24 We did not ask him to do QCQA, but we think that for

25 someone in his position, he has pretty extensive
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 35

1 experience with doing related work to monitoring

2 siloxanes. His work is actually already published as

3 well on those sectors, and as I point out in the

4 bottom one, he will have significantly lower labor

5 costs than would be possible in a govermentor contract

6 situation. Anybody have questions on that slide?

7 MS. PLOTZKE: This is my only comment,

8 this is Kathy again. From the university perspective,

9 again, we just had recent experience with the

10 University of Vermont, and these costs are not in line

11 with what they have put together for our program, so.

12 MR. TOBIAS: Okay. So, for the last

13 slide -- as just a summary of the relative sizes of

14 the different programs. The relative analytical

15 complexity they had, and their prices beginning with

16 the OW ( opposite water) water sewer sludge survey,

17 that should not be sediment. There are then also

18 explained the tables shows how that we have different

19 cost estimates based upon assignment candidate

20 experience, and costs or a quote from a university

21 researcher, but only for the EPA proposal.

22 MR. THOMAS: So, I guess just so

23 summarize, Dave, and thanks for putting this together.

24 I think it really helps us understand, you know, what

25 kind of motivated your thinking about cost. I guess
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 36

1 just in a macro way, based on what I think I am

2 hearing you say is that even your estimate of the

3 SEHSC proposal, assumes one sampling event, and I

4 think our proposal has two -- I think from our

5 perspective, that would have pretty substantial

6 implications on the estimated costs. The other thing

7 is the number of samples you have estimated to be 55,

8 I think by our own reckoning, it would be at least an

9 order of magnitude more than that. So, I think that

10 would certainly have a big impact on costs. But, I

11 guess just to sort of take a step back from costs, I

12 mean I just do want to be clear though that the basis

13 for our proposal has really not been on costs. I mean

14 what we really tried to focus on is how to develop a

15 program that is responsive to the agencies needs to

16 develop a risk assessment. So, I guess from my

17 perspective, it probably would not even be all that

18 constructive for us to have a protractive discussion

19 about costs, because what we really tried to do was

20 put together a program that allows you guys to

21 generate data for risk assessment. I think part of

22 the challenge has been -- clearly, there is somewhat

23 of a philosophical difference in terms of not only how

24 the program should be constructed, but what the focus

25 should be. The way we have laid out our program is as
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 37

1 a screening assessment, followed up by consideration

2 of risk management, if necessary. Now, it is my

3 understanding that is the way the agency typically has

4 gone about doing a risk assessment. You do a screening

5 level assessment based on worse case data, and that is

6 essentially what our proposal intends to provide. So,

7 I think if we can get past -- or we can come to some

8 agreement on the critical philosophical elements, or

9 at least come to some common understanding of -- how

10 do you construct a risk assessment, and what are going

11 to be the data needs to support that? I think we

12 probably would be much better off having that

13 discussion than having a discussion about costs

14 because to be totally honest, that is not going to be

15 a huge driver for us in terms of whether we are able

16 to come to an agreement on this.

17 MR. PENBERTHY: Fair enough. I mean the

18 only reason we've put this in is in some popular press

19 articles that circulated in the city say 50 million,

20 and we do not think that is anywhere near the right

21 number; and, so we just want to set the facts

22 straight. And, it may not be the numbers we say.

23 MR. THOMAS: Uh-huh (indicating

24 affirmatively).

25 MR. PENBERTHY: But, it is not $50
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 38

1 million.

2 MR. THOMAS: We do not have any control

3 over what numbers people report in the press.

4 MR. PENBERTHY: Well, they got the

5 number from somewhere, so

6 MR. TOBIAS: I just want to make a

7 couple of points for clarification. It is correct

8 that I misstated the number of samples that would be

9 in a twice performed monitoring program, but I think

10 the driver is labor costs. So, in this estimate, and

11 you can disagree with how I made the estimate -- I

12 agree. It's a very rough estimate, but we have not

13 received anything in the past for what your thinking

14 was for what these cost estimates would be. It is

15 really just during this discussion that you have

16 started to elaborate and discovered -- well, we have

17 not received any sort of breakdown or numbers at all

18 about what you view this as costing. So

19 MR. MAIT: Well, Dave -- Russell Mait, I

20 think what I recall from our prior meetings was, we

21 were not going to talk about costs, but we had planned

22 to talk about a sampling and monitoring plan once we

23 could get past what Karluss just mentioned -- which

24 was the philosophical approach of how to do this.

25 Once we can get there, then we can start getting down,
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 39

1 and I appreciate the level to which you got to --

2 talking about those aspects, and I think that is where

3 again, we are sort of -- you know, at cross. We did

4 not get to that meeting.

5 MR. TOBIAS: I was just clarifying the

6 specific points. I am sorry.

7 MR. MAIT: I understand that, but what I

8 am getting at is that meeting did not take place. We

9 had talked about that, and I recall that from prior

10 meetings. We had talked about getting to that, and I

11 recall Paul, you even mentioning that. We have never

12 had that meeting.

13 MR. LEWIS: I think what we are trying

14 to do here is just put things in context knowing that

15 how we want to move forward on the ECA -- any other

16 questions on this?

17 MR. WEST: I have a question. Kevin

18 West from Momentive. Dave, do you know if this work

19 done by this gentleman from Albany has been published?

20 MR. TOBIAS: Yes.

21 MR. WEST: I just tried to find it

22 quickly and only got this I think form you yesterday,

23 and I did not find anything, and do you know if there

24 were volatile siloxanes that he has been looking at?

25 MR. TOBIAS: It is D4, D5, D6 that are
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 40

1 definitely part of the set. He also has some linear

2 siloxanes he is looking at, and different chain

3 lengths and cyclical components. He has a publication

4 for work from a waste water treatment plant and for

5 consumer products, and we can forward those if you

6 would like to see them. And, from discussions with

7 him, he has also done further work on waste water

8 treatment plants in other locations.

9 MS. PLOTZKE: And, this is Kathy Plotzke

10 again. Just a couple of things, I know we want to

11 move away from the costs and why we have not provided

12 the details, but one of the things that I clearly can

13 talk from is experience where we have been monitoring

14 for these materials for three years -- three plus

15 years already doing very similar programs. You made

16 the statement that the most critical factor is going

17 to be labor costs. It is not going to be labor costs.

18 It is going to be sample handling and analysis costs.

19 The analytical, the QC, the QA that goes into these

20 programs is huge, it really is because of the nature

21 of these materials. A recent publication just out,

22 where they have employed this, -- this type of QAQC

23 continues to demonstrate the value of that and all of

24 our publications do as well.

25 MR. LEWIS: So, let's move to the next
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 41

1 presentation and Karluss and others kind of spoke

2 about in terms of what the purpose is for this. We

3 want to at least talk now and move to the next phase

4 of the EPA's plans for D4 risk assessment, because

5 that is really what the value is of what we are trying

6 to accomplish here. So, let me turn the floor over to

7 Ward in terms of laying out our plans for the D4 risk

8 assessment.

9 MR. PENBERTHY: You know, recently, in a

10 comprehensive approach to enhance our existing

11 chemicals program, the EPA recently identified a work

12 plan of 83 chemicals for assessment under TSCA.

13 Basically, we focused our selection of these chemicals

14 based on a number of factors -- their potential

15 concern to children's health, their neurotoxic effects

16 if there are carcinogens, if they are persistent in

17 our body cumulative and toxic. They are used in

18 consumer products or children's products and detected

19 in a biomonitoring programs. Initially, we identified

20 seven chemicals of the 83 for a risk assessment in

21 2012, and my understanding at current is that those

22 assessments will be forthcoming before the end of the

23 year. On June 1st of this year we had -- EPA

24 identified another 18 chemicals for assessment during

25 the 2013/2014 period. D4 was one of those chemicals.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 42

1 And, if you want to have more details about our

2 enhanced existing chemicals and how these criteria

3 were applied, there is elaborate explanation on our

4 website and under our existing chemicals program.

5 D4 was included as a chemical for

6 assessment in the work plan because it is a high

7 production volume chemical. It is persistent, it is

8 biocumulative. There is potential for reproductive

9 toxicity. It certainly has some aquatic toxicity. It

10 is used in consumer products, and this is information

11 reported to IUR our CDR now. It is present in

12 biomonitoring, blood, breast milk and aquatic species.

13 It has been found in indoor environments, sediment and

14 surface water. As an aside, of course, there is this

15 ECA activity going on, so that provides an additional

16 focus to D4, and then there is an IRIS of assessment

17 going to start in 2013, and those typically stretch on

18 charged for a number of years.

19 MS. PLOTZKE: Ward, just one quick

20 question on some of the data sources, do you have

21 references for

22 MR. PENBERTHY: Yes, that is on our

23 website. They are all listed there in a document.

24 MS. PLOTZKE: For like -- for example,

25 the biomonitoring, where that has been recorded?
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 43

1 MR. PENBERTHY: Correct, that would be

2 there. If you can't find it, after you take a look, I

3 can get you in touch with the people that did that

4 work. Obviously, the ECA has a lot of relevance to

5 our plan -- work plan risk assessment. Obviously, it

6 would provide valuable monitoring data which would

7 contribute to an exposure assessment, and it would

8 certainly reduce the uncertainty, and we think if it

9 was designed well, you know -- at this point, we

10 believe that the SEHSC proposal of four direct

11 discharge site and five POTW's would be insufficient

12 to develop an informed national exposure assessment,

13 and pursuing such limited monitoring strategy would

14 result in anecdotal data which would likely not reduce

15 uncertainty associated with the understanding of

16 concentrations of D4 in environmental media and if

17 pursued, our concern the way it might be an efficient

18 use of both our resources and your resources. We

19 believe our proposal that we have put forth is --

20 would be a much more -- have much higher quality data

21 set and something that we could use effectively and in

22 a risk assessment.

23 I guess in the event that we cannot

24 conclude an ECA, and obviously, we have plans for the

25 risk assessment, and so this is a logical question is
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 44

1 -- okay, what if things do not work out, what would

2 happen? And, we would still pursue our risk

3 assessment. We would consider all available

4 information in the existing limited monitoring and

5 released data. We would use release estimating

6 methods that we often use in say for instance -- our

7 new chemicals program. We would use models to

8 estimate environmental concentrations, and also by

9 accumulation and persistence. We think that we need to

10 do some scientific work in the interim to enhance

11 those modeling, because siloxanes are some unique

12 chemicals in terms of their properties and their

13 ability to be modeled. We would take into account the

14 substantial information that we have already received

15 under a previous Dow agreement. SEHSC has also given

16 us some conceptual site model information, and there

17 is a number of assessment efforts that have gone on in

18 other countries -- for instance, the UK and Canada.

19 In addition to this, there is other ways that we can

20 supplement the information available to us, or we have

21 talked about a possible test rule. There is other

22 applicable sections of TSCA that could be applied --

23 Section 8A, Section 8D, Section 11. We have heard

24 there is a lot of monitoring data. There has been

25 intimations of past monitoring going on at industrial
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 45

1 facilities and past assessments, and so we think we

2 could secure access to that if we had to, or if we

3 chose that as a logical course of action. There are

4 also other statutes and other programs at EPA that

5 would allow us potentially to get some relevant

6 information, and to the extent that makes sence we

7 would use those as well.

8 This is not -- we have made no plans at

9 all in regard to any of this, so this is a projection

10 of what we would do. It is just a laying out of the

11 possibilities that confront in the absence of a

12 monitoring program in our need to complete a risk

13 assessment. So, that is what we have.

14 MR. THOMAS: Now, most of our

15 discussions have focused on the risk assessment for

16 D4, could you clarify what the plans are for the D5

17 data?

18 MR. PENBERTHY: It would be D4. D5

19 would not be assessed in the work plan.

20 MR. THOMAS: Okay. So, is it essential

21 that data for D5 be generated as a part of this

22 program?

23 MR. PENBERTHY: The monitoring program?

24 MR. THOMAS: Yes.

25 MR. PENBERTHY: You know, this has been
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 46

1 something that we have talked about around the edges a

2 little bit. Our concerns with D5 are much, much less

3 than with D4. There is some debate in circles about

4 the true hazards of D5, and there are some studies

5 ongoing in Europe that may clarify that. So, right

6 now, our main focus is D4. I mean, I think our

7 thinking and including D5 in the monitoring program is

8 that many of these sites, these are -- they had a both

9 D4 and D5, and while we are at it, getting information

10 on D5 would not be at least sort of a conceptual

11 level, not much of an enormous added increment to

12 this. So, that is our thinking.

13 MR. THOMAS: If most of the outstanding

14 questions regarding D5 are related to the hazard,

15 would you expect environmental monitoring data to help

16 clarify any of those?

17 MR. PENBERTHY: Could help. Could help.

18 MR. THOMAS: But, you are not planning a

19 formal risk assessment for D5 as you are with D4?

20 MR. PENBERTHY: Not at this time. That

21 is not a guarantee that that will never happen; but,

22 it is not scheduled for the 2013/2014 time period.

23 The focus of our activity in assessment activity would

24 be D4.

25 MR. THOMAS: Okay, Yes, I guess,
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 47

1 notwithstanding the outcome of this exercise, I think

2 we would certainly encourage the Agency, whether data

3 is generated as a part of this effort or not, to use

4 as much of the available information as possible. I

5 would say in particular the D5 water review in Canada

6 provides a lot of good information on doing risk

7 assessment for D5. I think by extension, there are

8 some things you could learn about doing a risk

9 assessment for D4 if in particular, if you look at

10 the fact that D4 is probably more rapidly degraded,

11 more readily metabolized than D5, that certainly might

12 provide some guidance with respect to some of the

13 elements of a risk assessment for D4. So, the overall

14 encouragement is just to use as much of that data as

15 possible, because we certainly will use it -- most of

16 it, if not all of it has got to be extremly relevant

17 for any assessment done here in the U.S.

18 MR. PENBERTHY: Okay. Thanks for the

19 coaching.

20 MR. LEWIS: Other questions, comments on

21 the presentation. Especially those on the phone?

22 MS. PLOTZKE: Just one -- Kathy one more

23 question. So you talked about the use of models and

24 that you acknowledged that there would need to be some

25 update around some of those models to be adopted or
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 48

1 adapted for siloxanes, and also inclusion of more

2 relevant, more current, accurate physical chemical

3 property data too, would that be the way you would

4 approach it, if available?

5 MR. PENBERTHY: I think so.

6 MS. PLOTZKE: Provided?

7 MR. PENBERTHY: This is not my field,

8 but, yes.

9 MS. PLOTZKE: All right, so really

10 everything that is out there right now that we have

11 provided to you in inclusion, there is recently

12 published models by Don MacKay, all of that would be

13 used.

14 MS. FEHRENBACHER: We would consider it,

15 and we would determine whether it made sense for us to

16 use those in our assessment.

17 MR. PENBERTHY: And, generally in all

18 of the risk assessments that are planned, prior to the

19 plan, have a peer review component included in them,

20 so that would happen.

21 MR. THOMAS: And, would the timing for

22 the assessment for D4, would you expect it to be

23 impacted by the extent to which we move forward this

24 program?

25 MR. PENBERTHY: I think if we could come
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 49

1 together and get an ECA, that if there was that level

2 of agreement, that would be pretty compelling argument

3 to assess the time to allow that information to be

4 considered in the risk assessment.

5 MR. THOMAS: We do have a brief

6 presentation. As well -- I apologize for not having

7 sent it earlier. We have got copies available as

8 well, I think.

9 MR. AGUILAR: If you could just after

10 the meeting if you could provide a copy for us so that

11 we can post it to the public dockett. That would be

12 great.

13 MR. THOMAS: Okay.

14 MS. PLOTZKE: Yes, it is pretty small

15 print so I think that would be easier.

16 MR. THOMAS: All right, well, I guess

17 similar to the slides that were presented by Dave, we

18 just wanted to share a couple of thoughts and

19 perspectives from our perspective in terms of some of

20 the critical elements that go into thinking about how

21 to develop a risk assessment for these materials, and

22 then also just some -- Kathy is going to go through

23 some general observations in terms of a more deep dive

24 into the science. And, I spoke about a lot of these

25 things earlier as we were going through the EPA
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 50

1 slides, and you guys feel free to stop me as I go

2 through these if there are any questions for

3 clarification and so forth. But, again, I just want

4 to emphasize that, you know, our commitment to this

5 program is really on the basis of science and

6 developing the data to support a risk assessment. I

7 would also add that this will not be the first time

8 that we have generated environmental monitoring data

9 to support a risk assessment. We have done this in

10 Canada, we have done this is Europe, so we are

11 certainly willing to do it as well in the U.S. We

12 think it's a part of our commitment to environmental

13 stewardship. I just wanted to point out here some of

14 the specific things that kind of go into that making.

15 Again, I will emphasize that the number of sites is

16 not the primary driver for the proposal. I know a lot

17 of our discussions have kind of gotten into this

18 number of sites versus that number of sites. Again,

19 what we try to lay out is a proposal that gives you

20 the scientific rigor to do a risk assessment, and we

21 think there are several things that we try to provide

22 the agency with that provides compelling information

23 that our proposal accomplishes that. One, is the

24 facility release estimates that were developed right

25 before we developed the conceptual site models, and I
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 51

1 will add there that was not a trivial exercise. I

2 would say the industry is probably already well over a

3 $1 million in terms of commitment to what we have

4 already put into just the generation of the proposal

5 that we have on the table. We also generated the

6 facility release estimates, which again -- you guys

7 might not remember this, but I remember it well

8 because we spent a lot of time over the holidays --

9 either last year or the year before, generating that

10 information. We also have employed environmental

11 consultants, environmental engineering consultants

12 that not only helped us develop the conceptual site

13 models, the monitoring program, but they also helped

14 provide a pretty detailed scientific justification for

15 our proposal, and we just wanted to highlight that as

16 well.

17 Some of the things that we talked about

18 before that Kathy talked about earlier in terms of

19 cost, we thought based on the limited amount of

20 information that we had with respect to the agencies

21 cost estimate, you may have missed, and I think we

22 have now been able to confirm among us that some of

23 the things that were missed were the QAQC which could

24 have a serious impact on the cost of the lab and --

25 the lab and field quality control samples are going to
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 52

1 be essential for controlling for loss and

2 contamination. And, also, for assurance and

3 stability. And sample integrity and validation is

4 obviously also important, but we are very committed to

5 working with the agency to help inform our collective

6 understanding of the costs associated with the

7 development of these proposals. We certainly won't

8 say we have all of the answers, but certainly having

9 done it a couple of times in the past, we have got

10 some of them. Let me go to the next slide.

11 And, I think just kind of generally, a

12 more broad point that I think might be relevant not

13 only for this program but with others the agency might

14 be considering. Any of these methodologies that might

15 be used for assessing risk should really be consistent

16 for new and existing chemicals. We believe that would

17 get you a greater transparency and would foster

18 cooperation, and would really be a much greater

19 incentive for product innovation. You know, any time

20 we do not have the full set of information with

21 respect to how assessments are going to be carried out

22 and what the ultimate use of the data is going to be

23 from the standpoint of risk management, it hurts from

24 the standpoint of product innovation. Question, Dave?

25 MS. FEHRENBACHER: It would just be
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 53

1 helpful for you to elaborate on your suggestion that

2 methods should be consistent for new and existing

3 chemicals.

4 MR. THOMAS: The assessment

5 methodologies?

6 MS. FEHRENBACHER: Well, you say methods

7 for assessing risk should be consistent for new and

8 existing chemicals. Could you please elaborate on

9 that?

10 MR. THOMAS: So, the risk assessment

11 process that you would undertake to evaluate a new

12 chemical, it would be very important that also be the

13 same process that you would use for existing

14 chemicals.

15 MR. PENBERTHY: Well, they cannot be,

16 because there is different regulatory standards.

17 Sorry, one hazard may present an unreasonable risk

18 standard in chemicals, and one hazard will present.

19 So, accordingly existing chemicals, that qualitity the

20 data, the rigor assessment of the assessment is

21 generally has to be much greater.

22 MR. THOMAS: Well

23 MR. PENBERTHY: And, that is not because

24 I want it that way, that is what the statute says.

25 MR. THOMAS: Right, and that is a legal
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 54

1 distinction more than a scientific distinction, so we

2 should probably not spend a lot of time on this. This

3 was just sort of a general point, but I certainly

4 understand.

5 MR. PENBERTHY: Okay.

6 MS. PLOTZKE: I think it was Cathy that

7 just said the more we understand what you want, what

8 the process is, the easier it is for us whether it is

9 sitting here today working on a proposal or for the

10 future. That is what I think Karluss is trying to

11 say.

12 MR. THOMAS: And, again, I just wanted

13 to recap where we are at least in terms of our

14 understanding of the proposal that we have made and

15 modifications that have been made based on the

16 discussions we have had over the past several months.

17 For the POTW portion of our proposal, we had

18 identified -- we had suggested five sites be

19 monitored. Four activated sludge sites had initially

20 been three, but I think based on our last discussion,

21 we had suggested that a fourth site would also be an

22 activated sludge. I think based on the discussions,

23 our understanding was that EPA was suggesting that we

24 not monitor air at any other sites, so that is why the

25 air has been stricken. With respect to the monitoring
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 55

1 parameters, and you guys correct me if I am wrong, but

2 based on our last discussion, we had initially

3 proposed enfluent/affluent surface water, bio solid,

4 sediment, and then the biota fish and benthic species.

5 But, our impression was that based on the last

6 discussion, there was some interest in not having

7 those be monitored as the POTW's and then there would

8 be two monitoring events.

9 MS. ELZENREICH: We did not ask for

10 monitoring at the POTW sites, but we did ask for

11 monitoring at the indirect discharge sites, so it

12 totaled nine sites with an indirect discharge sites.

13 MR. THOMAS: You are talking biota

14 monitoring?

15 MS. PLOTZKE: Yes, biota monitoring

16 MR. THOMAS: Right, well, we're going

17 to get to the manufacturing process and formulators

18 next. I just wanted to clarify that this is agreeable

19 in terms of where the existence--

20 MS. ELZENREICH: At the POTW sites we

21 did not ask at the previous meeting for biota

22 monitoring.

23 MR. THOMAS: Okay.

24 MS. PLOTZKE: Just one clarification,

25 Karluss, on site four we changed that from activated
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 56

1 sludge it actually should be -- so it's three

2 activated sludge and two of those, that was what we

3 had proposed the last time we were together.

4 MR. THOMAS: Okay. All right. Thanks

5 a lot. So this is what our proposal had been for the

6 indirect dischargers, so all of the sites under SCHSC

7 control, all the direct discharge sites would be

8 monitored. The monitoring parameters would be

9 efficent at surface water, sediment, fish, the benthic

10 species, and there would be two monitoring events. All

11 right. Next slide. And again, this sort of gets at

12 some of the discussions that we had earlier, Paul,

13 which you alluded to in terms of overall philosophical

14 approach and none of these statements are intended to

15 be inflammatory or provocative. I mean, what we're

16 essentially trying to do is lay out what we believe

17 are the correct philosophical elements for a risk

18 assessment program and what we believe is also the

19 agency's previous guidance in terms of how these

20 things should be done. The -- we thought that the EPA

21 proposal presumes some D4/D5 risk management without

22 having conducted a risk assessment first. The reason

23 for that was because there was some discussion of

24 trying to just make some distinction between those

25 environmental concentrations that would be
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 57

1 attributable to residential sources versus those that

2 would be attributable to industrial sources. We

3 thought that exercise was probably more appropriate

4 for risk management than risk assessment. There was

5 also some discussion last time of some interest in

6 getting waste water treatment and even potential

7 facility efficiency information for treatment

8 efficiencies. We thought that also was outside the

9 scope of what would typically think of as a risk

10 assessment, so again, that statement that you were

11 starting to think about risk management without having

12 thought about risk assessment first was driven by some

13 of the comments that we heard from the last discussion

14 and we just wanted to be clear that our understanding

15 is risk-based decision- making is a two-tier process

16 where the potential environmental risk associated with

17 the material are systematically evaluated through an

18 assessment followed by a separate process for risk

19 management and that risk management should only be

20 considered after a risk is identified. And again, I

21 will highlight the experience in Canada where these

22 things have been studied pretty thoroughly and they

23 went so far as to say not only is there not a risk

24 now, but there will not be one in the future, at least

25 for D5. The nature and magnitude of the risk should
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 58

1 inform the risk management activities including

2 selection of the most practical risk management

3 instrument and I know I'm preaching the choir a lot

4 with this. I think we would all agree on that, but we

5 think a practically designed and efficient monitoring

6 proposal facilitates a determination first of --

7 whether risk management is needed before implementing

8 the risk management instrument. What we also don't

9 believe; sufficient scientific justification has been

10 provided for conducting a national exposure assessment

11 prior to doing the risk assessment. We do believe

12 that a worst-case risk assessment would be sufficient

13 for what we're doing here. We think the data that

14 would be provided by this program would allow you to

15 do a screening level risk assessment and that would be

16 very consistent with the way the agency has typically

17 handled these matters and there is really no need at

18 this point for a national exposure assessment. And the

19 rest of these points just sort of further emphasize

20 that we think a screening level risk assessment is

21 sufficient and the four POTWs and five direct

22 discharge sites, we think, is going to provide a very

23 sufficient data set for doing a screening risk

24 assessment for D4 and D5. Questions before we move

25 onto the next one? All right. Next slide. Also just
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 59

1 wanted to comment briefly on the notion that we've

2 seen in some of the previous documentation that data

3 from SCHSC member and direct discharge facilities

4 might provide data that would be helpful in getting a

5 more complete understanding of the full universe of

6 processors and formulators for these materials. We

7 don't think that's necessarily the case. Certainly, we

8 could not represent that our processors and

9 formulators are representative of the potentially tens

10 of thousands of others that are in the country nor do

11 we feel that information is needed again for risk

12 assessment. Again, that gets at more the risk

13 management elements. Those facilities are not

14 discharging material to the environment. They're

15 discharging material to a municipal POTW in most, if

16 not all cases, and that is already a part of the

17 program, so we don't think that's going to provide any

18 value from the standpoint of supporting a screening

19 level risk assessment. And again, we've touched on

20 this, this last point, many times throughout all of

21 these discussions. The whole idea that available

22 monitoring data really should be considered for

23 informing the development of this program here in the

24 U.S. We feel like it would really be doing the agency

25 a disservice to dismiss those data out-of-hand because
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 60

1 it's our, you know, experience that there's a lot of

2 similarities that the treatment practices in Canada

3 are not so dissimilar from those in the U.S that we

4 think it would warrant not using those data at all.

5 And again, some of the monitoring conclusions or

6 results that we've seen in other countries and in

7 Europe in particular, we think would be helpful here,

8 so I won't go through all of these bullets, but I

9 think that's the overall gist of where we're going

10 with this. Questions before we move onto the next one?

11 All right. I'm going to let Kathy take it from here.

12 MS. PLOTZKE: And I just have a couple

13 of slides, I think you asked for our perspective on

14 the risk assessment on D4. I intend to cover both D4

15 and D5 in one here, but basically I think what we have

16 said all along is we've been conducting research on

17 these materials, so we have quite a bit of research

18 including monitoring data on the environmental effects

19 of D4 and D5 really, in the environment and there's a

20 lot that we have learned, as well, of the chemical

21 physical properties of these materials. We continue

22 to apply that in every new program that we have and

23 what's really critical is these basic physical/

24 chemical characteristics and their relationship to

25 those physical / chemical characteristics in the
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 61

1 environment. It's understanding that and that's what

2 helps you to design a monitoring program is the

3 relationship between your chemicals and the behavior

4 in the environment. Some of the key ones and we've

5 talked about it here as a group as well, the binding

6 to organic carbon. We know that these materials find

7 organic carbon, so understanding the area that you're

8 monitoring and understanding the, basically, the type

9 and the level of organic carbon is critical. We know

10 that for these materials, lipid content of the

11 organisms, another thing, we have a program underway

12 right now that you can look at the impact of different

13 lipids and the impact on numbers around

14 bioaccumulation. This basically has allowed the EPA

15 and other regulators of other countries to really

16 utilize the toxicity threshold data from around the

17 world to develop their own water and sediment quality

18 criteria, so if you understand those fundamental

19 properties around your chemical and apply that to the

20 areas that you're monitoring, whether it be in the

21 U.S. or outside of the U.S., you really can understand

22 the behavior of these materials. And there is no

23 scientific reason why D4 and D5 really should be

24 treated differently. What's key is understanding

25 their differences, their uniqueness, and applying it
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 62

1 really then to these programs and that's what we've

2 done with our learnings. These two chemicals are not

3 toxic at concentrations below their solubility which

4 means they're not toxic at the maximum concentrations

5 that could exist in the environment. This was a

6 significant effort that we went forward with under the

7 Canadian D5 order review, but we've also applied it to

8 D4 and we've also sought outside expertise to review

9 it is, where you look at what is the solubility of

10 these materials in each environmental compartment and

11 what's the maximum you could achieve and then compare

12 that to the concentrations that you're finding out

13 there in the environment for these chemicals. The

14 worst-case scenario from an-- (WHEREUPON, the

15 conference was briefly interrupted by on-hold music

16 playing on phone speaker. Non-related dialogue not

17 transcribed.) So I think and this comes back to what

18 Karluss was saying about why, you know, we proposed

19 what we did originally from the monitoring program is

20 that with our knowledge that we have already, we

21 believe the worst-case scenario for understanding the

22 risk and the potential risks associated with D4 is

23 already understood, so we already understand what

24 those maximum concentrations are or could be. We

25 already understand with all of the monitoring that we
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 63

1 have done how different properties out there in the

2 environment, whether it be in the U.S., whether it be

3 in Canada, whether it be in Olso Fjord, will impact

4 those concentrations. So we can already do that and

5 predict it all through the program that we did, so the

6 United States really just validates this, that

7 understanding already. If you go to the next slide.

8 And we know that D4 and D5 behave differently than

9 other compounds that are similar in molecular weight

10 and size and again, this comes back to this

11 understanding of these unique characteristics and

12 these characteristics do result in unique

13 distributions in the environment and explain their

14 lack of toxicity and risk. So with the experts that

15 we've engaged through the D5 order review and through

16 other programs, all of them have started out looking

17 at this data set and wondering what that end result

18 and then they understand these unique characteristics

19 they come to the same conclusions that we do, that

20 there is no risk. That these concentrations are not

21 going to be at levels greater than their solubility

22 and you're not going to find them at concentrations in

23 the environment that's going to present a risk to

24 biota. We know that they partition the air no matter

25 where they're discharged in the environment. The air
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 64

1 compartment may readily degrade, so that's why

2 everybody has quickly moved away from the air

3 compartment and moved into the aquatic and the

4 sediment compartment. Given the 30-plus years of use

5 for these chemicals, I think it's safe to assume that

6 they're relative -- that they're at a relative steady

7 state in the environment and other, all the experts

8 that we have in the D5 order review concluded that as

9 well and that even if they were not, they cannot

10 accumulate at concentrations in aquatic systems that

11 are above their solubility. This was really key for

12 the D5 order review when the experts got to that point

13 of seeing that, that's where they were very quickly

14 able to say there's not going to be a risk associated

15 with these materials no matter what testing we've done

16 in the laboratory. In addition, the degradation of

17 these compounds in aquatic eco-systems and the

18 metabolism within the organisms, all data sets that we

19 have generated and provided and have published further

20 prevent concentrations that would present a risk and

21 one comment, D4 versus D5, in a recent review we've

22 had of D4, you get even more metabolism and faster

23 degradation of D4, so that's even a greater impact for

24 D4 than it is for D5. Talk about the partitioning to

25 the organic carbon and that's why it does lead to
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 65

1 sometimes elevated concentrations in sediment and that

2 the sediment really is the compartment of greatest

3 exposure for these materials, so I think everybody who

4 has started out evaluating these materials moved

5 through that, moved away from there, moved to the

6 aquatic compartment, and it's very consistent with our

7 conceptual site models that we've put together looking

8 at which compartments are the compartments of real

9 concern here and it comes down to sediments and

10 looking at the microorganisms. But again, then what's

11 critical is taking that next step, what those

12 concentrations are going to be and whether or not

13 they're going to present any risk and that's exactly

14 what we've done with the Canadian work as well as

15 we've now done with the D4. We've conducted a

16 probabilistic risk assessment. We've provided that to

17 you and what we demonstrate is we have significant

18 margins of safety around the concentrations that you

19 find in the sediment when you monitor for these

20 materials compared to where you see any effects in the

21 laboratory and it really is related to these unique

22 characteristics that govern and determine its

23 solubility in sediment. So I think that's the two

24 slides I have.

25 MR. LEWIS: Questions? Comments?
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 66

1 MR. PENBERTHY: It sounds like we'll

2 have a lot to talk about when we put together our risk

3 assessment.

4 MR. TOBIAS: If there's anybody on the

5 phone, they're not going to be able to ask a question.

6 MR. LEWIS: You might make a comment

7 not to be put on hold again because it sounds like

8 they're back on the phone.

9 MR. TOBIAS: Yeah. I think they heard

10 you.

11 MS. PLOTZKE: So I guess one last

12 comment to kind of summarize on the risk assessment,

13 too. I've referred to it in here. Obviously, we've

14 worked with a number of experts for the D5 board of

15 review, but we've also recently reached out to get

16 third-party review on D4 as well, so we're in the

17 process of finalizing that work and we'd be willing to

18 share it.

19 MR. PENBERTHY: Great, okay, thank you.

20 MR. LEWIS: Any comments for SEHSC on

21 their presentation? I see none. Let me open the floor

22 up now to any interested parties that are either on

23 the phone or in the room here if they want to provide

24 commentary on what they've been hearing this

25 afternoon. Yes? Please identify yourself.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 67

1 MR. DELEO: Paul DeLeo, American

2 Cleaning Institute. I have a comment about something

3 mentioned early in the discussion today with regard to

4 data availability for food webs in the U.S. We've

5 seen an epidemic of countries moving away from using

6 data from multiple geographies and requesting data

7 only from their specific countries, so China is going

8 down that road. Very recently, we understand that

9 Japan is going down that road where they're only

10 accepting data for species in their respective

11 countries, abandoning massive environmental safety

12 databases. The U.S. Government has been a strong

13 advocate in international forums for mutual acceptance

14 of data and, you know, we believe that's consistent

15 with the desires for minimizing animal testing and

16 just good stewardship of chemicals. We think it's the

17 best policy for industry and for the U.S. Citizen, so

18 I'm hoping that the comment that was made earlier

19 about the need for U.S. -- data on U.S.-specific

20 species isn't a policy move by the U.S. Government

21 away from what has been a very forceful international

22 stance on mutual acceptance of data.

23 MS. EISENREICH: This is Karen

24 Eisenreich, EPA. I want to clarify that I didn't say

25 that we're not going to review that. In this
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 68

1 instance, we do have it and we are using it. It just

2 may not be the best representation, especially when

3 you're talking about saltwater species versus

4 freshwater species. They're completely different.

5 Completely different environments, different

6 behaviors, so I didn't say that we wouldn't use or

7 consider the data.

8 MR. LEWIS: I think the comment that

9 Karen mentioned right now what we've been saying for

10 our past few meetings in terms of looking at other

11 data sources. Looking at Environment Canada, for

12 example. And look at the applicability of how it can

13 be applied here I think, so your comment now is

14 aligning with what we've been saying since the spring

15 for these ECA discussions.

16 MS. PLOTZKE: Yes, and I guess I'll

17 just, this is Kathy, just add on to that because

18 there's been some reference about marine and certainly

19 we've done a food web study in Oslo Fjord. We've also

20 done a food web study in Lake Pepin. We've done food

21 web studies in Lake Ontario. We've done one just

22 recently in Tokyo Bay, so I know that is marine. But

23 we also just completed one in Lake Champlain in

24 Vermont in the United States this fall. So we are

25 doing, you know, food web studies within the United
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 69

1 States on, with freshwater species and a lot of our

2 biota monitoring is with freshwater species.

3 MR. LEWIS: Ward, do you want to now

4 discuss other comments?

5 MR. PENBERTHY: I don't have any other

6 comments, really, at this point. I know we're winding

7 down to at least the regulatory limit for our

8 discussions, so I'm hopeful that there'll be some

9 modification to the positions over the next week or

10 two, but we'll see.

11 MR. LEWIS: Anything more from anyone

12 else?

13 MR. THOMAS: Well, just so in terms of

14 next steps, in terms of process, what's your

15 expectation in terms of what happens now?

16 MR. PENBERTHY: Well, we still have a

17 couple weeks to go, so we can't obviously -- we'll

18 brief upon chair we'll tell people the circumstances

19 as we have done before and at the end of the six-month

20 period, the decision will be made.

21 MS. FEHRENBACHER: It does appear that

22 the SEHSC position has not changed since the last

23 meeting and I think that's.

24 MR. PENBERTHY: -- that's what we'd be

25 telling people.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 70

1 MS. FEHRENBACHER: -- that's really

2 important --

3 MR. PENBERTHY: Unless we hear

4 differently.

5 MS. FEHRENBACHER: -- for us to know.

6 MR. THOMAS: Well, again, the SEHSC

7 position was moderated I think during, our last

8 meeting when we talked about the mix of sites. I think

9 the fundamental underpinning of our proposal is,

10 again, going to be how you do a risk assessment. I

11 guess our view is that the agency has made little move

12 as well with respect to philosophical approach to this

13 monitoring program. We think the discussion merits

14 more than just considering numbers of sites and so

15 forth. I mean, I think the real substantive basis for

16 the program should be what you're trying to accomplish

17 and I guess if we could come to some mutual agreement

18 in terms of how we do that, I think that's what will

19 precipitate any potential changes in the proposal.

20 MR. PENBERTHY: We are not going to

21 start the activity with a worst-case assessment.

22 That's, that would lead to multiple recycles on

23 assessments that would go on decades. We have a plan

24 for doing a risk assessment in 2014 and it's going to

25 be assessment that would hopefully support a
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 71

1 regulatory action if necessary. That's the guidance

2 that we're operating under and have been given. So to

3 the extent that we can't get to a proposal for a

4 monitoring agreement that would support that

5 objective, then it's hard to see how this ends up.

6 MR. THOMAS: So you think the -- doing

7 an assessment the way the agency has typically done it

8 would require a process that went on for decades?

9 MR. PENBERTHY: Well, if we get into an

10 ECA for a limited number of studies for anecdotal

11 data, that would take several years to accomplish,

12 clearly, then we'd do an evaluation and then we would

13 go through another protracted process like this to

14 develop yet another ECA to get more detailed

15 information if, in fact, there was a concern. That

16 would go on for another several years and so the

17 timeline just doesn't look profitable. We just want to

18 do a good job. Do it as scientifically valid,

19 defensible, that's what allows us to make a decent

20 evaluation. That's just not a maybe maybe-not type

21 judgment.

22 MS. CARLTON: One questions in response

23 to that comment. This is Betsy Carlton from Bluestar

24 Silicones. The most recent evaluation where we have a

25 final decision has been from Canada resulting from the
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 72

1 Board of Review. They indicated that there was no risk

2 now nor any anticipated in the future.

3 MR. PENBERTHY: Is that D4 or D5?

4 MS. CARLTON: This is for D5.

5 MR. PENBERTHY: Well, okay, but we're

6 interested in D4 and my understanding is that they

7 have a mandatory pollution prevention requirement for

8 D4, so obviously there are concerns in Canada for D4.

9 MS. CARLTON: Okay, well that was--

10 MR. PENBERTHY: So now we have

11 concerns. Their concerns support ours more than

12 anything, so that would tell me that we just--

13 MS. CARLTON: Yeah, my question was

14 going to be what's your basis for your concern and

15 you've just answered that question before I asked it,

16 so thank you.

17 MR. PENBERTHY: Okay, good.

18 MR. THOMAS: Would you guys be opposed

19 to a brief break and then we come back and wrap-up?

20 MR. PENBERTHY: Sure.

21 MR. LEWIS: Five minutes.

22 (WHEREUPON, a brief recess was taken.)

23 MR. LEWIS: This is Paul Lewis and let

24 us re-continue or continue our discussion. Karluss, I

25 know you wanted a break to caucus with your group and
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 73

1 anything that you want to share with us at this time?

2 MR. THOMAS: Well, I just want to get,

3 if you guys would indulge us for a minute, could we

4 just clarify what the most recent version of the

5 agency's proposal is and in particular the indirect

6 discharge piece and what you intend to gain from that?

7 MR. LEWIS: Ward?

8 MR. PENBERTHY: The indirect discharge

9 piece, let me just rehash this so I have it straight

10 in my own head. There are SEHSC facilities, some are

11 manufacturing, some are processing, some are

12 formulating, some are all three, some are a

13 combination. But they discharge to POTWs. So we

14 think it's important to have those sites monitored. I

15 think, our estimate, there was, as I recall, five

16 sites that have water discharge some and we want your

17 confirmation because some of those sites don't

18 actually have a discharge to a POTW. I think there's

19 nine total sites. And of those nine, five have a

20 water discharge to a POTW. We would need confirmation

21 about that. That's our best understanding from our

22 discussions, so we would want all of those monitored

23 as well.

24 MR. THOMAS: And, and, and I don't

25 remember the exact numbers, but for those that
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 74

1 discharge to a POTW, so those that we are calling

2 indirect dischargers as opposed to those that are

3 direct dischargers which we fully agree to have

4 monitored, just to clarify again, what's the value of

5 having those sites monitored from a risk assessment

6 perspective?

7 MR. PENBERTHY: Well, it's a -- I mean,

8 it's just a different circumstance, right?

9 MR. THOMAS: Well, but there's no

10 environmental release, so I don't see how it informs a

11 risk assessment if you're discharging to a POTW.

12 MR. PENBERTHY: You're releasing to a

13 POTW, right?

14 MR. THOMAS: Correct.

15 MR. PENBERTHY: TRI calls that a

16 release, right? And then something else happens to

17 it. It's treated, right?

18 MR. THOMAS: Correct.

19 MR. PENBERHTY: Okay. So that's what

20 we want to understand.

21 MS. PLOTZKE: It's treated at the POTW.

22 MR. PENBERTHY: Correct.

23 MS. PLOTZKE: So there's no, there is

24 no release to a direct environmental compartment.

25 MS. FEHRENBACHER: There's a pipe.
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 75

1 MS. PLOTZKE: There's a pipe, so when

2 we talk about biota--

3 MR. PENBERTHY: Look are you saying that

4 100 percent of it that goes to the POTW is treated and

5 nothing goes out the effluent of the POTW?

6 MR. THOMAS: Well, whatever comes out,

7 you can monitor the POTW to know what comes out. You

8 don't need to monitor what comes out of the facility

9 to know what comes out of the POTW.

10 MS. PLOTZKE: You can't monitor the

11 indirect site to know exactly what's coming out of the

12 POTW.

13 MR. PENBERTHY: We want to understand

14 what's going in and what's coming out because then you

15 get to understand how that POTW is actually operating

16 and its effectiveness.

17 MR. THOMAS: And I think you understand

18 the point, we won't continue to debate it, but I think

19 the philosophical differences, we don't believe the

20 releases going into that POTW are of any consequence

21 from an environmental release perspective. You're

22 absolutely right, well, you may be right in your

23 suggestion that not all of it is treated. We don't

24 know that, but we feel like you can figure that out if

25 you monitor the POTW. You don't need to know what
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 76

1 goes into the POTW to get a sense for what the

2 potential environmental releases are, so again, I

3 think that's just a -- we'll just agree that there's a

4 philosophical difference there with respect to our

5 approach for this risk assessment.

6 MS. FEHRENBACHER: I would also like to

7 comment that one of your suggestions was to maintain

8 consistency between new chemical and existing chemical

9 assessments and this is, indeed, the way that we

10 perform an assessment for both new chemicals and

11 existing chemicals where there are industrial

12 manufacturing, processing, and formulating releases

13 from facilities. We assess those releases through

14 discharge to the environment and treatment. That is

15 our standard process.

16 MR. THOMAS: Well, I guess I was going

17 to make--

18 MS. FEHRENBACHER: And it's consistent

19 with what you asked us to do.

20 MR. THOMAS: I guess I would make a

21 distinction between regulatory reporting requirements

22 and what's necessary for a risk assessment. So while

23 that may be true, what you just mentioned in terms of

24 reporting requirements, I'm not sure that's

25 necessarily consistent with what you'd use for a risk
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 77

1 assessment.

2 MS. FEHRENBACHER: No, that's not

3 reporting requirements. I was describing the approach

4 that we use for generating an assessment of exposure.

5 MS. PLOTZKE: But it's a calculated

6 exposure. It's not a monitoring program.

7 MR. PENBERTHY: It doesn't have to be

8 if we have data. We would use it.

9 MS. FEHRENBACHER: And the reason that

10 we were so interested in obtaining release information

11 from you on all of the member facilities.

12 MR. PENBERTHY: So you need to know the

13 number or you can't do an assessment.

14 MR. THOMAS: Right, I guess again, we

15 would suggest that you could sufficiently understand

16 the loadings for monitoring around the POTWs because

17 that's where the release into the environment occurs

18 potentially.

19 MR. PENBERTHY: Okay. But you

20 understand where we're getting at, we just disagree.

21 MR. THOMAS: The other clarification I

22 wanted to make was around D5 and the agency's goals

23 with respect to what the agency is going to do with

24 the D5 data. Is there a view that the D5 data is as

25 essential as the D4 data?
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 78

1 MR. PENBERTHY: No.

2 MR. THOMAS: All right. I think that's

3 all of the questions that I have. Do others around the

4 table or on the phone have questions?

5 MR. LEWIS: Any questions from the

6 phone? Any final comments from the agency?

7 MR. PENBERTHY: No. I'm okay.

8 MR. LEWIS: Are we talking to our

9 management and letting them know in terms of where we

10 are in the discussion today? I think we all recognize

11 and appreciate in terms of that there's only a few

12 weeks remaining in terms of this process. So we want

13 to make sure that they're aware of this and I know

14 Karluss and your parties are also aware of that and

15 we'll go from there.

16 MR. THOMAS: Okay. Well, thank you

17 again for the time for this meeting. Thanks again for

18 the previous meetings. I know some of the

19 conversations have been difficult, but I do want to,

20 again, express our commitment to moving forward with

21 this. One final comment, I guess I'm just kind of

22 curious. Notwithstanding data that is generated for

23 this program or not, would the agency use data that

24 came in for a risk assessment just in general? If you

25 got data in that would inform a risk assessment for D4
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 79

1 or D5 or any thing else outside of the context of a

2 program like this, would the agency use that

3 information for the work plan assessments?

4 MR. PENBERTHY: Well, we would

5 certainly consider it. I don't know if we would use

6 it, but certainly we would pay attention to it.

7 MR. THOMAS: Okay.

8 MR. PENBERTHY: I would say thank you

9 for all of your participation. I know you've put a

10 lot of time and effort into all of this, so thanks for

11 meeting with us today. It's been very enlightening,

12 the whole process. Thank you.

13 (WHEREUPON, the Meeting was concluded

14 at 3:23 p.m.)

15

16

17

18

19

20

21

22

23

24

25
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 80

1 STIPULATION

2

3 The foregoing matter was taken on the date, and

4 at the time and place set out on the title page

5 hereof.

6

7 It was requested that the matter be taken by the

8 reporter and that the same be reduced to typewritten

9 form.

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 81

1 CERTIFICATE OF REPORTER AND FOR SECURE ENCRYPTED

2 SIGNATURE AND DELIVERY OF CERTIFIED TRANSCRIPT

3 I, JASON ALAN LEES, Notary Public, do hereby

4 certify that the forgoing matter was reported by

5 stenographic and/or mechanical means, that same was

6 reduced to written form, that the transcript prepared

7 by me or under my direction, is a true and accurate

8 record of same to the best of my knowledge and

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13 This transcript and certificate have been

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22

23 /s/JASON ALAN LEES

24 COURT REPORTER / NOTARY

25 My Commission Expires: October 2, 2016
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 82

$

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Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 83

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Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 84

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Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 85

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Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 86

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Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 87

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complexity

35:15

component

10:23 31:11

48:19

components

10:22

14:2 24:9

40:3

compository

25:4

compounds

63:9 64:17

comprehensive

41:10

concentration

s 9:8

9:19

43:16

44:8

56:25

62:3 62:4

62:12 62:24

63:4

63:20 63:22

64:10 64:20

65:1

65:12 65:18

conceptual

11:23 21:12

44:16 46:10

50:25 51:12

65:7

concern 21:20

41:15 43:17

65:9

71:15 72:14

concerned

14:16

concerns

20:23

46:2 72:8

72:11 72:11

conclude

43:24

concluded
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 88

64:8 79:13

conclusions

60:5 63:19

conditions

9:25

conduct 32:17

conducted

56:22 65:15

conducting

18:3 18:6

58:10 60:16

conference

10:18 10:20

62:15

configuration

s 12:2

confirm 51:22

confirmation

73:17 73:20

confront

45:11

connected

12:4

consequence

75:20

consider 15:5

17:12

44:3

48:14

68:7 79:5

consideration

12:5

31:20 37:1

consideration

s 17:21

considered

12:9

28:15

49:4

57:20 59:22

considering

52:14 70:14

consistency

76:8

consistent

52:15

53:2 53:7

58:16

65:6

67:14 76:18

76:25

construct

37:10

constructed

36:24

constructive

36:18

consultants

51:11 51:11

consumer

34:19

40:5

41:18 42:10

contamination

32:5 52:2

content 61:10

context 30:24

39:14 79:1

continue

60:21 72:24

75:18

continues

40:23

contract

23:14

26:5

32:14 35:5

contracts

23:10

contribute

43:7

control 19:22

19:25

20:4

27:22

38:2

51:25 56:7

controlled

26:18 26:20

controlling

52:1

conversation

30:16

conversations

78:19

cooperation

52:18

copies 7:20

49:7

copy 49:10

Corning

3:11 4:10

4:23 5:8

5:10 5:11

Corporation

3:20

correct 28:19

38:7 43:1

55:1

56:17 74:14

74:18 74:22

cost 22:4

22:6 22:8

22:16 25:16

26:8

26:11 29:23

30:3

30:25 31:22

31:24 31:25

32:8

32:19 34:22

35:19 35:25

38:14 51:19

51:21 51:24

costing 38:18

costly 23:6

costs 6:6

21:24 22:12

24:8

24:10 24:11

24:12 24:16

24:19 24:21

25:20 25:25

25:25 29:10

30:1 35:5

35:10 35:20

36:6

36:10 36:11

36:13 36:19

37:13 38:10

38:21 40:11

40:17 40:17

40:18 52:6

Council 3:9

Counsel
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 89

5:18 5:20

countries

44:18

60:6

61:15

67:5 67:7

67:11

country 22:22

59:10

County 5:14

21:5

couple 7:6

10:12 20:16

28:23

38:7

40:10 49:18

52:9

60:12 69:17

course 8:8

21:16 42:14

45:3

cover 60:14

Craft 4:20

4:20

create 22:4

25:15

creating 22:6

criteria 13:3

13:8 16:3

16:7

16:14 16:17

17:1 17:7

17:12 31:21

42:2 61:18

critical

31:10 31:15

32:12

37:8

40:16 49:20

60:23

61:9 65:11

cross 39:3

cumulative

41:17

curious 78:22

current 25:22

41:21 48:2

cut 29:6

cycle 9:13

10:22

cyclical 40:3

D

D4 6:6 6:8

9:5 15:10

15:22 39:25

41:4 41:7

41:25

42:5

42:16 43:16

45:16 45:18

46:3 46:6

46:9

46:19 46:24

47:9

47:10 47:13

48:22 58:24

60:14 60:14

60:19 61:23

62:8

62:22

63:8

64:21 64:22

64:23 64:24

65:15 66:16

72:3 72:6

72:8 72:8

77:25 78:25

D4/D5 56:21

D5 9:5

15:10 15:22

39:25 45:16

45:18 45:21

46:2 46:4

46:7 46:9

46:10 46:14

46:19

47:5 47:7

47:11 57:25

58:24 60:15

60:19 61:23

62:7 63:8

63:15

64:8

64:12 64:21

64:24 66:14

72:3 72:4

77:22 77:24

77:24 79:1

D6 39:25

data 10:25

13:7

13:19 13:22

13:25

14:5 14:8

14:10 14:11

15:4 15:6

15:20 15:24

16:3 16:8

16:10 16:15

16:23

17:2 17:8

17:13 17:20

17:20

18:1 18:4

20:11

22:3

36:21

37:5

37:11 42:20

43:6

43:14 43:20

44:5

44:24 45:17

45:21 46:15

47:2

47:14

48:3 50:6

50:8

52:22 53:20

58:13 58:23

59:2 59:4

59:22 59:25

60:4

60:18 61:16

63:17 64:18

67:4 67:6

67:6

67:10 67:14

67:19 67:22

68:7

68:11 71:11

77:8

77:24 77:24

77:25 78:22

78:23 78:25

databases

67:12

Dave 28:14

32:20 35:23

38:19 39:18

49:17 52:24

David 4:5

22:2
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 90

23:19 29:15

30:5 31:19

dealing 6:2

33:15

debate 46:3

75:18

Deborah 5:7

decades 70:23

71:8

December

3:3 8:23

8:24

decent 71:19

decision

57:15 69:20

71:25

deep 49:23

defensible

18:18

19:5 71:19

defiantly

19:20

define 13:9

defined 16:2

definitely

40:1

degradation

64:16 64:23

degrade 64:1

degraded

47:10

DeLeo 3:23

3:23

29:14 29:14

29:20

67:1 67:1

deleted 21:7

deletion

18:21 18:22

deliberations

6:12

demonstrate

40:23 65:17

depending

34:4

described

10:15

11:9

17:17

31:6 34:13

describing

77:3

design 61:2

designed 43:9

58:5

desires 67:15

detailed

51:14 71:14

details 23:15

23:24

28:4

40:12 42:1

detected

41:18

determination

13:20 13:23

58:6

determine

28:11 48:15

65:22

determined

21:16

determining

17:12

develop 9:7

36:14 36:16

43:12 49:21

51:12 61:17

71:14

developed

18:8

50:24 50:25

developing

50:6

development

11:1 52:7

59:23

dialogue

62:16

difference

22:24 24:14

27:23 36:23

76:4

differences

33:11 61:25

75:19

different

14:18 14:22

24:9 25:3

28:23 34:17

35:14 35:18

40:2

53:16 61:12

63:1 68:4

68:5 68:5

74:8

differently

61:24

63:8 70:4

difficult

17:18 78:19

difficulty

17:16

direct 19:9

20:1 33:9

43:10

56:7

58:21

59:3 74:3

74:24

directly

26:18 26:19

disagree

38:11 77:20

discharge

9:24 10:3

43:11 55:11

55:12

56:7

58:22

59:3 73:6

73:8

73:13 73:16

73:18 73:20

74:1 76:14

discharged

63:25

dischargers

56:6 74:2

74:3

discharges

19:10 20:1

discharging

59:14 59:15
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 91

74:11

discovered

38:16

discuss 23:25

24:19 69:4

discussed

24:1

discussing

22:3 28:7

29:7 34:15

discussion

6:17 6:19

11:23 25:17

36:18 37:13

37:13 38:15

54:20

55:2 55:6

56:23

57:5

57:13

67:3

70:13 72:24

78:10

discussions

6:10

10:17 10:19

11:20

12:1

17:10 17:25

19:4 20:8

20:18

21:8

21:16

29:2 40:6

45:15 50:17

54:16 54:22

56:12 59:21

68:15

69:8 73:22

dismiss 59:25

disposal 9:15

15:12 15:13

disservice

59:25

dissimilar

60:3

distant 10:2

distinction

54:1 54:1

56:24 76:21

distributions

63:13

Districts

5:14 21:5

ditches 15:15

dive 49:23

divide 6:11

Division 5:25

Doa 20:16

docket 6:15

8:10

dockett 49:11

document 8:10

42:23

documentation

23:24 59:2

Don 48:12

done 27:20

30:22 39:19

40:7

47:17 50:9

50:10

52:9

56:20

62:2 63:1

64:15 65:14

65:15 68:19

68:20 68:20

68:21 69:19

71:7

Dow 3:10 4:10

4:22 5:7

5:9 5:11

44:15

downstream

10:2

down-stream

18:22

Dr 20:16

drafts 21:10

driven 57:12

driver

37:15 38:10

50:16

dropped 19:13

due 28:23

Dumars 3:13

3:13

dumps 15:14

duplicate

23:25

during 6:21

6:22 8:7

9:1 18:16

19:3

20:20 22:13

38:15 41:24

70:7

E

earlier

49:7

49:25 51:18

56:12 67:18

early 9:4

11:4

11:19 67:3

easier

49:15 54:8

ECA 6:2

6:10 9:2

10:13

18:8

18:17

19:3 28:4

29:21 39:15

42:15

43:4

43:24

49:1

68:15 71:10

71:14

eco-systems

64:17

edges 46:1

effectively

43:21

effectiveness

75:16

effects 41:15

60:18 65:20

efficent 56:9

efficiencies

57:8
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 92

efficiency

57:7

efficient

43:17 58:5

effluent

26:21 75:5

effort 47:3

62:6 79:10

efforts

23:6 44:17

eight 26:1

Eisenreich

4:12 4:12

67:23 67:24

either 32:9

34:1 51:9

66:22

elaborate

38:16

42:3 53:1

53:8

elements 9:16

19:2 21:1

37:8

47:13 49:20

56:17 59:13

elevated 65:1

Ellen 3:25

else 5:21

25:13 69:12

74:16 79:1

Elzenreich

14:7 14:8

14:21

55:9 55:20

email 7:25

8:23

emphasize

34:11

50:4

50:15 58:19

employed

40:22 51:10

employee 26:9

encompass

9:22

encountered

22:13

encourage

47:2

encouraged

15:21

encouragement

47:14

enfluent/

affluent

55:3

engaged 63:15

engineer

33:23

engineering

51:11

enhance 15:21

41:10 44:10

enhanced 42:2

enlightening

79:11

enormous

46:11

ensuring

32:10

entire 26:5

environment

15:22 22:12

24:5

24:15 59:14

60:19

61:1 61:4

62:5

62:13

63:2

63:13 63:23

63:25

64:7

68:11 76:14

77:17

environmental

3:1 3:9

8:18 8:21

9:6 9:8 9:9

11:1

12:23

27:6

30:22

31:3

43:16

44:8

46:15

50:8

50:12 51:10

51:11 56:25

57:16 60:18

62:10 67:11

74:10 74:24

75:21 76:2

environments

18:2 18:4

42:13 68:5

EPA 4:3 4:4

4:5 4:6

4:11 4:12

4:13 4:14

4:15 4:16

4:17 4:24

5:25 8:17

11:10 12:16

14:8 15:3

18:16 21:13

22:3

22:16

23:9 24:2

26:4

28:25 30:22

34:13 34:23

35:21 41:11

41:23

45:4

49:25 54:23

56:20 61:14

67:24

EPA's 6:4 6:6

8:15

22:18 41:4

epidemic 67:5

ER 3:25

especially

47:21 68:2

essential

9:16

45:20

52:1 77:25

essentially

11:2 20:1

37:6 56:16

establish

30:16 32:17

estimate

22:17 25:16
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 93

30:4

30:24 30:25

34:23

36:2

38:10 38:11

38:12

44:8

51:21 73:15

estimated 6:6

21:24 24:10

26:11

36:6 36:7

estimates

22:4 22:7

24:8

28:24 29:23

31:23 35:19

38:14 50:24

51:6

estimating

44:5

et 12:3

Europe 46:5

50:10 60:7

evaluate 16:8

16:24 53:11

evaluated

13:6 57:17

evaluating

17:1 65:4

evaluation

12:17 32:12

71:12 71:20

71:24

event 28:16

28:18 28:21

30:6

30:10

36:3 43:23

events

28:15 34:16

55:8 56:10

everybody

7:12 64:2

65:3

everyone 5:15

6:1

everything

48:10

Evonik 3:12

4:21

exact 73:25

exactly 65:13

75:11

examining

10:4

example 42:24

68:12

excerpt 20:15

excerpted 9:2

exclude 10:22

exclusively

10:25

exercise 47:1

51:1 57:3

exist 62:5

existence

55:19

existing

13:22

15:4 15:5

15:20 41:10

42:2 42:4

44:4

52:16

53:2 53:8

53:13 53:19

76:8 76:11

expansive

19:19

expect

46:15 48:22

expectation

69:15

experience

27:12 28:12

35:1 35:9

35:20 40:13

57:21 60:1

expertise

62:8

experts 63:14

64:7

64:12 66:14

explain 63:13

explained

35:18

explanation

42:3

exposure

21:13

43:7

43:12 58:10

58:18

65:3 77:4

77:6

express 78:20

expressed

20:23

extension

47:7

extensive

34:25

extent 45:6

48:23 71:3

externally

23:10

extra 7:19

extremly

47:16

F

facilitate

11:1

facilitates

58:6

facilities

11:25 12:13

14:9

15:13 15:19

17:7 45:1

59:3

59:13 73:10

76:13 77:11

facility 12:5

15:10 50:24

51:6 57:7

75:8

fact 18:1

18:17 47:10

71:15

factor 21:9

40:16

factored 13:2
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 94

31:8 32:8

32:19

factors 41:14

facts 37:21

fair 34:20

37:17

fairly 16:7

fall 68:24

faster 64:22

feel 50:1

59:11 59:24

75:24

Fehrenbacher

4:2 4:2

8:14 8:15

11:17

13:6

13:13

15:2 16:6

16:22

17:5

17:24 18:12

29:24 31:17

48:14 52:25

53:6

69:21

70:1 70:5

74:25

76:6

76:18

77:2 77:9

fewer 18:21

19:8 19:16

field 27:22

31:3

31:13 31:14

32:4 32:6

48:7 51:25

figure 75:24

fills 15:14

final 71:25

78:6 78:21

finalizing

66:17

finally 12:10

15:3

finding 62:12

first 8:4

10:9

19:16 20:15

22:7

25:17 26:17

50:7

56:22 57:12

58:6

fish 12:20

26:23 26:24

26:25

27:1 33:7

34:3 55:4

56:9

five 26:18

43:11 54:18

58:21 72:21

73:15 73:19

fixed 24:12

Fjord 63:3

68:19

Flack 3:19

3:19

flame 23:4

flexible

20:25

floor 41:6

66:21

flow 9:19

flow-rate

15:17

fluent

26:21 34:1

fluent/

affluent

25:5

focus 10:25

18:17

20:3

20:18 21:17

36:14 36:24

42:16

46:6 46:23

focused 41:13

45:15

focusing

12:15

folks 21:18

follow-up

8:24

food 12:21

13:3

14:11 14:18

67:4

68:19 68:20

68:20 68:25

forceful

67:21

foreign 15:24

form 39:22

formal 10:13

19:4 46:19

format 6:17

formulating

19:19 73:12

76:12

formulation

9:11 9:14

11:21

formulator

11:25

formulators

19:23 55:17

59:6 59:9

forth 43:19

50:3 70:15

forthcoming

41:22

fortunate

34:17

forums 67:13

forward 32:25

39:15

40:5

48:23

62:6 78:20

foster 52:17

fourth 54:21

free 50:1

fresh 18:4

freshwater

68:4 69:1

69:2

full 9:13

52:20 59:5

fully 74:3
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 95

fullyloaded 26:8

fundamental

61:18 70:9

future

54:10 57:24

72:2

G

gain 73:6

Gary 4:22

gathered

22:22

Gene 3:17

general 49:23

54:3 78:24

generally

48:17 52:11

53:21

generate

36:21

generated

14:20 45:21

47:3 50:8

51:5

64:19 78:22

generating

13:4 51:9

77:4

generation

15:11 51:4

gentleman

39:19

geographic

12:8

geographies

67:6

geologic 12:8

geology 15:16

gets 56:11

59:12

getting 38:25

39:8

39:10

46:9 57:6

59:4 77:20

Giffith 5:13

gist 60:9

given 12:12

23:17 30:17

31:11 44:15

64:4 71:2

gives 50:19

goals 77:22

gone 37:4

44:17

gotten 50:17

govermentor

35:5

govern 65:22

government

23:9 26:8

67:12 67:20

graduate

24:17

great 49:12

66:19

greater 52:17

52:18 53:21

63:21 64:23

greatest 65:2

Greg 5:9

Griffin

21:4 21:4

GRIFFITH 5:13

group 61:5

72:25

GROUP/POTW

3:2

guarantee

46:21

guess 13:16

16:11

20:5

20:13 35:22

35:25 36:11

36:16 43:23

46:25 49:16

66:11 68:16

70:11 70:17

76:16 76:20

77:14 78:21

guidance 16:4

47:12 56:19

71:1

guys 21:7

33:24 36:20

50:1 51:6

55:1

72:18 73:3

H

handled 58:17

handling 9:23

15:12 23:13

40:18

happen 44:2

46:21 48:20

happens 69:15

74:16

hard 71:5

having 6:4

8:8 31:14

37:12 37:13

49:6 52:8

55:6

56:22 57:11

74:5

hazard

46:14 53:17

53:18

hazards 46:4

head 73:10

health 3:9

41:15

hear 70:3

heard 44:23

57:13 66:9

hearing

36:2 66:24

held 10:19

help 7:13

7:17 7:25

46:15 46:17

46:17 52:5

helped

51:12 51:13

helpful 13:11

53:1 59:4

60:7

helps 35:24

61:2
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 96

high 9:11

9:14

12:22 15:23

16:9

16:13 33:14

42:6

higher 43:20

high-flow

9:25

highlight

11:11 51:15

57:21

Hiley 5:3 5:3

hold 66:7

holidays 51:8

honest

29:22 30:11

37:14

hopeful 69:8

hopefully

70:25

hoping 67:18

Hopkins

4:17 4:17

hour 26:6

hours 6:2

house 24:15

huge 37:15

40:20

Hugh 3:19

human 21:13

hurts 52:23

hydrocarbons

23:4

hydrology

15:16

I

idea 22:8

30:13 59:21

identified

9:5 9:16

32:10 41:11

41:19 41:24

54:18 57:20

identify

5:1 6:10

66:25

identifying

8:20

I'll 68:16

I'm 3:8

58:3

60:11 67:18

69:8

76:24

78:7 78:21

impact

36:10 51:24

61:12 61:13

63:3 64:23

impacted

48:23

implementing

58:7

implications

36:6

important

23:7

31:22 52:4

53:12

70:2 73:14

impression

55:5

inadequacies

14:3

incentive

52:19

incinerated

33:10

include

9:13 9:17

10:1 15:9

29:25 31:19

included

9:3 21:17

23:20

42:5 48:19

including

12:3

12:18 24:10

46:7 58:1

60:18

inclusion

27:21

31:3 48:1

48:11

inclusive

23:12

incorrect

30:12

increase

29:11 31:22

increased

29:9

increment

46:11

incremental

31:24

indeed 11:3

76:9

indicated

28:10 72:1

indicates

22:15

indicating

27:15 37:23

indirect

55:11 55:12

56:6 73:5

73:8 74:2

75:11

indoor 42:13

indulge 73:3

industrial

9:10 9:11

9:14 9:18

10:23 11:20

14:9

18:24

29:5

44:25

57:2 76:11

industry 51:2

67:17

inflammatory

56:15

influent 9:20

24:25

inform 52:5

58:1 78:25

informal 6:22
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 97

8:25

information

10:12

13:5 17:9

17:22

18:9

31:18 42:10

44:4

44:14 44:16

44:20

45:6 46:9

47:4 47:6

49:3

50:22 51:10

51:20 52:20

57:7

59:11 71:15

77:10 79:3

informed

43:12

informing

59:23

informs 74:10

initial 10:16

19:9 19:18

initially

41:19 54:19

55:2

initiating

10:13

innovation

52:19 52:24

input 6:11

inside 15:6

inspection

6:16

instance

17:25

44:6

44:18 68:1

instead 24:20

Institute

3:24

29:15 67:2

instrument

58:3 58:8

insufficient

43:11

integrity

52:3

intend

60:14 73:6

intended

9:6 18:17

56:14

intends 37:6

intent 9:12

interest

11:16

55:6 57:5

interested

6:10 6:25

10:4

21:19

23:1

66:22

72:6 77:10

interim 44:10

internal 23:9

international

67:13 67:21

interrupted

62:15

intimations

44:25

involved

30:20

IRIS 42:16

isn't 13:9

13:10 33:16

67:20

isotope 24:13

it's 38:12

50:12

56:1 60:1

61:1 64:5

65:6

67:16 70:24

71:5

73:14

74:7 74:8

74:17 74:21

76:18

77:5 77:6

79:11

IUR 42:11

I've 20:2

29:22

30:3 66:13

J

Japan 67:9

Jason 5:11

Jessica 4:11

Jin 5:11 5:11

job 71:18

Joe 4:15

John 5:17

judgment

71:21

June 41:23

justification

51:14 58:9

K

Karen 4:12

4:18 14:5

14:7

67:23 68:9

Karluss 3:6

3:8 10:8

18:13 38:23

41:1

54:10 55:25

62:18 72:24

78:14

Kathy 3:10

16:1

24:22 26:12

31:1 35:8

40:9

47:22 49:22

51:18 60:11

68:17

Kevin 3:14

39:17

key 61:4

61:24 64:11

kick-off 6:18

knowledge

62:20

known 13:10

13:11 14:25

17:22
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 98

Koger 5:17

5:17

Kozerski 4:22

4:22

Kristan 5:5

L

lab 24:13

31:3

31:15

32:4 32:6

32:16 51:24

51:25

labor 23:13

24:8

24:10 24:16

24:19 25:20

25:21 25:25

25:25

26:5

29:10 30:17

34:22

35:4

38:10 40:17

40:17

laboratories

32:14

laboratory

25:23

29:8

32:18 64:16

65:21

labs 23:11

32:15

lack 63:14

lagoons 12:3

laid 36:25

Lake 27:13

68:20 68:21

68:23

land 9:21

15:14 15:15

large 12:12

larger 29:7

last 12:25

13:15 18:13

20:20 21:18

22:15 35:12

51:9

54:20

55:2 55:5

56:3 57:5

57:13 59:20

66:11 69:22

70:7

later 11:14

15:1

lay 16:13

33:12 50:19

56:16

laying 41:7

45:10

lead 64:25

70:22

leads 24:6

learn 47:8

learned 60:20

learnings

62:2

least 12:18

12:20

36:8 37:9

41:3

46:10 54:13

57:24 69:7

leave 8:2

legal 53:25

lengths 40:3

lengthy 17:10

less 46:2

let's 40:25

letter 8:24

20:16

letting 78:9

level 33:14

34:5 37:5

39:1

46:11

49:1

58:15 58:20

59:19 61:9

levels

12:21 12:21

63:21

Lewis 4:6 4:6

5:24 5:25

7:8 7:18

8:1 8:12

21:22

22:1

30:13 39:13

40:25 47:20

65:25

66:6

66:20

68:8 69:3

69:11 72:21

72:23 72:23

73:7 78:5

78:8

life 9:13

10:22

likely 43:14

limit 69:7

limited 18:23

43:13

44:4

51:19 71:10

line 35:10

linear 40:1

lipid 61:10

lipids 61:13

Lisa 3:13

list 23:2

listed

23:13 42:23

lists 11:14

little

16:12 21:14

34:23

46:2 70:11

load 15:18

loadings

77:16

locations

10:1 40:8

logical 43:25

45:3

Los 5:14 21:5

loss 31:13

32:5 52:1

lot 11:23

16:16 18:1
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 99

19:19 30:15

43:4

44:24

47:6

49:24 50:16

51:8 54:2

56:5 58:3

60:1

60:20

66:2 69:1

79:10

low 9:25

12:21

lower 24:16

35:4

M

MacKay 48:12

macro 36:1

magnification

12:18

magnitude

36:9 57:25

main 21:17

22:6 46:6

maintain 76:7

Mait 3:12

3:12 17:3

28:14 28:14

28:17

30:5 30:5

32:20 32:20

33:1 33:4

33:14 33:19

33:23

34:6 34:9

38:19 38:19

39:7

major 11:15

MALE 7:5

management

23:15

37:2

52:23 56:21

57:4

57:11 57:19

57:19

58:1 58:2

58:7 58:8

59:13 78:9

mandatory

72:7

manufacturer

11:25

manufacturing

9:10 9:13

11:21 14:14

15:19 55:17

73:11 76:12

Marcus 4:14

7:18

margins 65:18

marine 18:2

68:18 68:22

massive 67:11

material

57:17 59:14

59:15

materials 5:4

5:6 6:14

14:25 31:11

31:15

32:7

32:16 40:14

40:21 49:21

59:6

60:17 60:21

61:6

61:10 61:22

62:10 64:15

65:3 65:4

65:20

math 32:21

matrices

32:18

matrix 27:7

27:25 31:3

matter 34:5

63:24 64:15

matters 58:17

maximum

62:4

62:11 62:24

may 12:13

29:24 37:22

46:5

51:21 53:17

64:1 68:2

75:22 76:23

maybe 12:25

13:14 13:16

19:21

20:9 71:20

maybe-not

71:20

McNett 5:7

5:7

mean 17:5

17:24 19:22

21:15

32:2

36:12 36:13

37:17

46:6

56:15 70:15

74:7

means 62:4

media 9:9

22:24 34:17

43:16

medium 27:5

meeting 6:1

6:3 6:8

6:13 7:9

8:8 20:21

39:4 39:8

39:12 49:10

55:21 69:23

70:8

78:17 79:11

79:13

meetings 5:22

6:14 8:25

38:20 39:10

68:10 78:18

meets 16:16

Mehran 25:21

Meltran 24:5

member 59:3

77:11

mentioned

21:6

38:23

67:3 68:9

76:23

mentioning

39:11

merits 70:13
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 100

message 34:11

met 13:21

metabolism

64:18 64:22

metabolized

47:11

metals 23:4

method 32:13

methodologies

52:14 53:5

methods 32:15

44:6 53:2

53:6

meti 33:11

metropolitan

12:12

microorganism

s 65:10

migration

9:21

Mihaich

3:25 3:25

milk 42:12

million 23:12

29:13 37:19

38:1 51:3

minimizing

67:15

minimum 18:18

19:5

minus 34:7

minute 73:3

minutes 72:21

missed

51:21 51:23

misstated

38:8

mix 20:21

70:8

model 21:12

44:16

modeled 44:13

modeling

44:11

models

11:23

44:7

47:23 47:25

48:12 50:25

51:13 65:7

moderated

70:7

modification

69:9

modifications

18:14 18:15

19:3 54:15

modified

20:14

molecular

63:9

Momentive

3:13 3:14

5:4 5:6

39:18

monitor 54:24

65:19

75:7 75:8

75:10 75:25

monitored

16:15 19:10

54:19

55:7 56:8

73:14 73:22

74:4 74:5

monitoring

3:2 6:5 6:6

8:18 8:21

9:6 9:17

9:19 10:7

11:18 12:15

12:16

13:1 15:4

15:6

15:20 15:24

16:15 17:17

18:7

18:11 18:16

18:18 18:18

18:20 18:21

18:22 18:23

18:23

19:2 19:8

19:16

21:7

21:11

22:5 22:9

22:13 22:18

22:25

24:2 24:7

24:9

27:13 30:23

33:8 35:1

38:9

38:22 40:13

43:6

43:13

44:4

44:24 44:25

45:12 45:23

46:7

46:15

50:8

51:13 54:25

55:8

55:10 55:11

55:14 55:15

55:22

56:8

56:10

58:5

59:22

60:5

60:18

61:2 61:8

61:20 62:19

62:25

69:2

70:13

71:4 77:6

77:16

month 26:2

26:3 26:5

26:6

months 26:1

30:10 30:14

30:17 30:19

54:16

morphologies

15:17

motivated

35:25

move 7:5

10:10 39:15

40:11 40:25

41:3

48:23 58:24

60:10 67:20

70:11

moved 64:2
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 101

64:3 65:4

65:5 65:5

moving

11:17 12:14

67:5 78:20

MPF 12:7 17:7

18:20

19:8 19:16

multiple 67:6

70:22

multiplied

25:19 33:12

municipal

9:18 12:6

59:15

municipality

12:12

music 62:15

mutual

11:16 67:13

67:22 70:17

N

NACWA 21:6

narrow 11:8

narrowed

10:16 10:21

10:25

narrowing

20:10

national 19:6

22:10 43:12

58:10 58:18

nature

40:20 57:25

nearby 9:24

necessarily

21:21

59:7 76:25

necessary

37:2 71:1

76:22

negotiation

10:13 18:17

19:4

neurotoxic

41:15

nine 25:19

55:12 73:19

73:19

none 34:12

56:14 66:21

Non-related

62:16

non-U.S

16:3 16:5

16:8

16:10 17:20

nor 59:10

72:2

notably 8:23

nothing 75:5

notion 59:1

notwithstandi

ng 47:1

78:22

nutrient

15:17

O

objective 6:5

71:5

objectives

6:4 8:17

8:20 9:1

12:16

15:3

18:15 18:16

observations

49:23

obtain 23:16

obtaining

77:10

obviously

31:8 43:4

43:5

43:24

52:4

66:13 69:17

72:8

occurrence

12:23

occurs 77:17

offered

20:1 20:21

office 8:15

22:10 22:20

okay 3:5 5:21

6:21 7:2

8:13 8:14

11:17 12:14

13:13

15:2

18:12

20:5 21:3

21:23 25:15

27:2 27:9

28:2

28:13 29:20

31:9 34:6

34:9

35:12

44:1

45:20 46:25

47:18 49:13

54:5

55:23

56:4

66:19

72:5 72:9

72:17 74:19

77:19

78:7

78:16 79:7

Olso 63:3

ones 61:4

ongoing 46:5

on-hold 62:15

on-site

9:18 9:23

10:23 15:12

15:13

Ontario 68:21

onto 58:25

60:10

open 66:21

operating

71:2 75:15

opportunity

6:7 6:9

opposed 72:18

74:2

opposite

35:16
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 102

ORD 23:8

order 36:9

62:7

63:15

64:8 64:12

organic

61:6 61:7

61:9 64:25

organisms

10:6

61:11 64:18

original

20:14

originally

20:8 62:19

Oslo 68:19

others 33:7

33:9 41:1

52:13 59:10

78:3

ours 21:21

31:8 72:11

outcome 47:1

out-of-hand

59:25

outside

15:6

23:11 26:19

57:8

61:21

62:8 79:1

outstanding

46:13

overall

20:7

47:13 56:13

60:9

overlooked

14:14

OW 24:14

35:16

P

p.m 79:14

page 23:17

25:20

parameters

12:8 55:1

56:8

participating

21:19

participation

79:9

particular

14:2

19:23

47:5 47:9

60:7 73:5

parties

6:10 6:25

21:19 66:22

78:14

partition

63:24

partitioning

64:24

pass 7:21

past 29:8

37:7

38:13 38:23

44:25

45:1 52:9

54:16 68:10

pasted 29:6

pathways

9:8 21:13

Patrick

5:13 21:4

Paul 3:23 4:6

5:22 5:25

29:14 39:11

56:12

67:1 72:23

pay 24:12

26:4 79:6

peer 48:19

PENBERHTY

74:19

Penberthy 3:4

3:6 4:4 4:4

4:7 4:25

5:15 5:21

6:25 7:3

7:19 8:3

8:13

11:12 13:16

13:24

14:4

16:18 16:21

18:7

19:12 19:17

20:2 21:3

21:15

24:2

37:17 37:25

38:4 41:9

42:22

43:1

45:18 45:23

45:25 46:17

46:20 47:18

48:5 48:7

48:17 48:25

53:15 53:23

54:5 66:1

66:19

69:5

69:16 69:24

70:3

70:20

71:9 72:3

72:5

72:10 72:17

72:20

73:8 74:7

74:12 74:15

74:22

75:3

75:13

77:7

77:12 77:19

78:1 78:7

79:4 79:8

people 4:25

7:15

21:22 30:20

30:21 30:22

38:3 43:3

69:18 69:25

Pepin 68:20

per 12:19

23:7

24:11

26:1 26:3

27:3 27:6

31:2 32:18

percent 75:4

perform 22:18

76:10
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 103

Performance

5:4 5:6

performed

23:8 24:1

24:15 34:18

38:9

performing

24:6

perhaps 34:3

period

41:25 46:22

69:20

persistence

44:9

persistent

41:16 42:7

Personal 5:17

5:19

perspective

17:19 20:20

20:24

35:8 36:5

36:17 49:19

60:13

74:6 75:21

perspectives

6:8 49:19

pharmaceutica

ls 23:5

phase 41:3

philosophical

36:23

37:8

38:24 56:13

56:17 70:12

75:19 76:4

phone 5:1

5:16

21:23 25:14

34:12 47:21

62:16

66:5 66:8

66:23

78:4 78:6

Phonetic 4:9

physical

31:12

48:2

60:21 60:23

60:25

piece 73:6

73:9

piles 15:14

pipe 74:25

75:1

pits 15:14

plan 6:6

18:25

19:3 23:6

26:16 28:25

30:17 38:22

41:12

42:6 43:5

43:5

45:19 48:19

70:23 79:3

planned 21:11

38:21 48:18

planning

46:18

plans 41:4

41:7 43:24

45:8 45:16

plant 9:19

12:7 31:6

40:4

plants 12:2

14:13 22:14

22:21 40:8

playing 62:16

please 7:12

7:16 53:8

66:25

Plotzke

3:10 3:10

12:24

13:8

13:14 14:16

14:23

16:1 16:1

16:11 16:20

23:19 24:22

25:2 25:7

25:10 26:12

26:12 26:25

27:2 27:6

27:9

27:17

28:2 28:9

31:1 31:2

31:7

31:10

32:1 35:7

40:9 40:9

42:19 42:24

47:22

48:6 48:9

49:14

54:6

55:15 55:24

60:12 66:11

68:16 74:21

74:23

75:1

75:10 77:5

plus 26:23

34:7 40:14

point 10:3

10:11 10:14

10:18 13:20

14:2

19:16 20:12

22:15

28:5 35:3

43:9

50:13 52:12

54:3

58:18 59:20

64:12

69:6 75:18

points 10:2

38:7 39:6

58:19

policy

67:17 67:20

pollution

8:16 72:7

ponds 15:14

popular 37:18

population

9:25 12:4

portion

32:3 54:17

position

34:25 69:22

70:7

positions

11:13 69:9
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 104

possibilities

45:11

possible 23:1

35:5

44:21

47:4 47:15

post 49:11

post-docs

24:17

potential

9:20

15:11 41:14

42:8 57:6

57:16 62:22

70:19 76:2

potentially

14:21

45:5 59:9

77:18

POTW 18:21

21:11 54:17

55:10 55:20

59:15 73:18

73:20

74:1

74:11 74:13

74:21

75:4 75:5

75:7 75:9

75:12 75:15

75:20 75:25

76:1

POTWs 58:21

73:13 77:16

POTW's

12:11 19:14

34:19 43:11

55:7

Powell 5:9

5:9

power 27:20

28:10

practical

58:2

practically

58:5

practices

9:24 60:2

preaching

58:3

precipitate

70:19

predict 63:5

pre-ECA 8:25

prefer 6:23

pre-field

32:12

preliminary

25:16 29:23

30:3 30:25

present 42:11

53:17 53:18

63:23 64:20

65:13

presentation

6:4 7:20

8:4 8:7

8:16 8:19

9:4 41:1

47:21

49:6 66:21

presentations

6:21 6:23

presented

6:14

31:19 49:17

press 37:18

38:3

presumes

56:21

pretty

10:16 20:14

21:16

23:3

23:11 34:25

36:5 49:2

49:14 51:14

57:22

prevent 64:20

prevention

8:16 72:7

previous

25:20 34:18

44:15 55:21

56:19

59:2 78:18

pre-work 32:9

price 23:12

prices 35:15

primary 50:16

print 49:15

prior 10:13

10:19

30:7

38:20

39:9

48:18 58:11

probabilistic

65:16

probably

10:23 11:11

16:12 24:16

36:17 37:12

47:10

51:2 54:2

57:3

problem 28:3

process

8:25 9:2

10:14

11:5 17:4

21:20 53:11

53:13

54:8

55:17 57:15

57:18 66:17

69:14

71:8

71:13 76:15

78:12 79:12

processing

9:10 9:14

11:21 19:19

73:11 76:12

processor

11:25

processors

19:23

59:6 59:8

product

9:13

10:22 52:19

52:24

production

15:10 42:7

products 5:18

5:20 34:19
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 105

40:5

41:18 41:18

42:10

professor

34:14

profitable

71:17

program 9:6

9:17 10:8

10:21

11:7 18:8

21:1 22:9

22:13 22:19

23:20

24:3 24:7

24:9 25:9

25:22 27:19

29:7

29:16 33:11

34:13 35:11

36:15 36:20

36:24 36:25

38:9

41:11

42:4 44:7

45:12 45:22

45:23

46:7

48:24

50:5

51:13 52:13

56:18 58:14

59:17 59:23

60:22

61:2

61:11 62:19

63:5

70:13 70:16

77:6

78:23 79:2

programs 22:5

22:7 25:3

32:3

35:14 40:15

40:20 41:19

45:4 62:1

63:16

progressively

10:2

projection

45:9

projects

30:23

properties

14:24 31:12

44:12 60:21

61:19 63:1

property 48:3

proportional

29:12

proposal 11:3

11:5 19:9

20:14 20:17

21:18 22:16

25:18 25:19

26:11 26:15

29:6

29:19 34:14

34:23 35:21

36:3 36:4

36:13

37:6

43:10 43:19

50:16 50:19

50:23

51:4

51:15 54:9

54:14 54:17

56:5

56:21

58:6 70:9

70:19

71:3 73:5

proposals

25:17 52:7

proposed 9:16

17:17

55:3 56:3

62:18

PROTECTION

3:1

protracted

71:13

protractive

36:18

provide

8:10 18:9

20:11

37:6 43:6

47:12 49:10

50:21 51:14

58:22

59:4

59:17 66:23

provided 15:7

40:11

48:6

48:11 58:10

58:14 64:19

65:16

provides

6:9 42:15

47:6 50:22

providing

31:23

provocative

56:15

public 6:16

49:11

publication

40:3 40:21

publications

30:21 40:24

published

35:2

39:19 48:12

64:19

purpose 30:12

41:2

purposes

18:19

pursue 44:2

pursued 43:17

pursuing

43:13

putting 35:23

Q

QA 40:19

QAQC 23:20

24:1

29:25 40:22

51:23

QAQC's 31:20

QC 40:19

QCQA 34:24

QC's 31:4

31:14 31:15

32:4
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 106

QC-specify

31:5

qualitity

53:19

quality 27:22

43:20 51:25

61:17

quantitative

17:4 17:19

question 6:20

12:24

16:2 21:6

23:19 24:23

26:13 39:17

42:20 43:25

47:23 52:24

66:5

72:13 72:15

questions

6:16 6:22

6:22 7:1

7:9 25:13

35:6

39:16 46:14

47:20

50:2

58:24 60:10

65:25 71:22

78:3 78:4

78:5

quick 6:20

23:19 42:19

quickly 39:22

64:2 64:13

quite 32:1

32:16 60:17

quote 22:17

34:20 34:21

35:20

R

range 9:23

rapidly 47:10

rates 9:19

Raymond 5:3

reached 66:15

readily 47:11

64:1

real 65:8

70:15

really 7:13

7:16 8:21

35:24 36:13

36:14 36:19

38:15 40:20

41:5 48:9

50:5

52:15 52:18

58:17 59:22

59:24 60:19

60:23 61:15

61:21 61:23

62:1 63:6

64:11

65:2

65:21

69:6 70:1

reason

37:18 56:22

61:23 77:9

recall

19:12 38:20

39:9

39:11 73:15

recalling

21:8

recap 54:13

received

38:13 38:17

44:14

receiving

12:10 15:16

recent 11:6

22:9

22:13

35:9

40:21 64:21

71:24 73:4

recently

27:13

41:9

41:11 48:11

66:15

67:8 68:22

recess 72:22

reckoning

36:8

recognize

78:10

recognized

20:3

recognizing

21:18

recollection

28:17

re-continue

72:24

recorded

42:25

recycles

70:22

red 28:24

reduce 43:8

43:14

reduction

29:4

reference

68:18

references

42:21

referred

66:13

regard 45:9

67:3

regarding

46:14

regulators

61:15

regulatory

53:16

69:7 71:1

76:21

rehash 73:9

related

35:1

46:14 65:21

relationship

60:24 61:3

relative

35:13 35:14

64:6 64:6

release

44:5

50:24

51:6

74:10 74:16

74:24 75:21
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 107

77:10 77:17

released 44:5

releases 9:10

11:24 15:10

75:20

76:2

76:12 76:13

releasing

74:12

relevance

43:4

relevant 18:5

18:9 45:5

47:16

48:2 52:12

remaining

78:12

remember 7:15

28:6 51:7

51:7 73:25

remind 7:11

replicate

12:19

report

23:14 38:3

reported

42:11

reporting

76:21 76:24

77:3

represent

12:20

14:9

14:13 59:8

representatio

n 68:2

representativ

e 9:17 9:23

11:20 11:22

14:12

15:8

16:24 59:9

representativ

eness 15:25

16:9 17:6

17:20

represented

14:15

representing

3:18 4:20

7:24

represents

18:2

20:19 28:18

reproductive

42:8

requesting

67:6

require 22:18

71:8

required 24:3

requirement

72:7

requirements

34:15 76:21

76:24 77:3

research 23:9

60:16 60:17

researcher

35:21

residential

57:1

resources

43:18 43:18

respect

15:4

20:25 47:12

51:20 52:21

54:25 70:12

76:4 77:23

respective

67:10

response

20:17 71:22

responsive

11:5 36:15

rest 58:19

result

20:22 43:14

63:12 63:17

resulting

71:25

results 23:16

60:6

retardants

23:4

review 47:5

48:19

62:7 62:8

63:15

64:8

64:12 64:21

66:15 66:16

67:25 72:1

rightthey

25:8

rigor 50:20

53:20

risk 6:6

6:8 11:1

18:2

18:19

19:6

20:11

21:2

36:16 36:21

37:2 37:4

37:10

41:4 41:7

41:20

43:5

43:22 43:25

44:2

45:12 45:15

46:19

47:6 47:8

47:13 48:18

49:4

49:21

50:6 50:9

50:20 52:15

52:23

53:7

53:10 53:17

56:17 56:21

56:22

57:4 57:4

57:9

57:11 57:12

57:16 57:18

57:19 57:20

57:23 57:25

58:1 58:2

58:7 58:8

58:11 58:12

58:15 58:20

58:23 59:11

59:12 59:19

60:14 62:22
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 108

63:14 63:20

63:23 64:14

64:20 65:13

65:16

66:2

66:12 70:10

70:24

72:1 74:5

74:11

76:5

76:22 76:25

78:24 78:25

risk-based

57:15

risks 62:22

road 67:8

67:9

room 4:8

21:23 66:23

rough 38:12

rule 44:21

run 5:23

run-off 15:11

run-on 15:11

Russell

3:12

28:14

30:5

32:20 38:19

S

safe 64:5

safety 3:9

65:18 67:11

salary 26:8

saltwater

68:3

sample

17:10

23:7

23:14 24:11

27:2

27:24

31:2 32:5

32:11 32:11

34:22 40:18

52:3

samples 12:19

17:11 22:23

23:2

23:25 24:24

25:22 26:13

26:15 26:22

27:18 27:22

28:22

29:2

29:17 29:25

30:8

30:11 31:13

31:20 31:21

32:3

34:16

36:7 38:8

51:25

sampling 10:1

12:23 14:12

23:13 27:19

28:15 28:16

28:20

30:6

30:10 34:16

36:3 38:22

Sanitation

5:14 21:5

satisfaction

29:17

saw 27:23

scaled 29:9

scenario

62:14 62:21

scheduled 6:3

46:22

SCHSC 56:6

59:3

science 49:24

50:5

scientific

18:25 44:10

50:20 51:14

54:1 58:9

61:23

scientificall

y 19:6

71:18

scope 10:15

10:21 10:24

11:7

20:10 57:9

screen 7:7

screening

37:1 37:4

58:15 58:20

58:23 59:18

second 10:10

Section 44:23

44:23 44:23

sections

44:22

sectors 35:3

secure 45:2

sediment

15:17

25:5 25:5

26:21

34:3

35:17 42:13

55:4 56:9

61:17

64:4 65:1

65:2

65:19 65:23

sediments

10:5 65:9

seeing 64:13

seen 31:12

31:14

32:8 59:2

60:6 67:5

SEHSC 3:22

4:18 4:19

6:7 19:24

25:18 25:18

25:22 26:11

36:3

43:10 44:15

66:20 69:22

70:6 73:10

selected

11:22 12:20

selecting

12:11

selection

10:7

11:19

12:5

41:13 58:2

selections

9:22
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 109

sence 45:6

sense 48:15

76:1

sent 21:10

34:14 49:7

separate

57:18

serious 51:24

sets 64:18

seven 41:20

several 50:21

54:16 71:11

71:16

sewage

22:10 22:22

sewer 35:16

share 49:18

66:18 73:1

shed 15:9

15:10

sheet 7:23

Shin-Etsu

3:18

shown 15:7

shows 35:18

significant

32:7 62:6

65:17

significantly

35:4

sign-in 7:22

Silicones

3:16 3:18

71:24

Silicone's

3:9

siloxane

3:2 6:5

8:17 8:21

18:16 24:6

siloxanes

22:14 34:19

35:2

39:24

40:2

44:11 48:1

Siloxane's

6:2

similar

6:13 15:7

24:16 27:19

40:15 49:17

63:9

similarities

60:2

single

28:18 30:6

site 9:21

10:7

11:18 11:23

12:19

15:8

15:15

16:3 16:5

17:18 21:12

32:9 34:4

43:11 44:16

50:25 51:12

54:21 55:25

65:7 75:11

sites 11:21

11:22

12:6 12:7

12:7 15:6

15:25 16:14

17:23 18:20

18:21 18:24

19:9

19:16 19:20

19:24 19:25

20:4

25:19 25:21

26:17 26:17

26:19 26:19

26:22 26:23

29:1 29:1

29:5

29:11 32:22

33:7 33:8

33:10

46:8

50:15 50:18

50:18 54:18

54:19 54:24

55:10 55:11

55:12 55:12

55:20

56:6 56:7

58:22

70:8

70:14 73:14

73:16 73:17

73:19 74:5

sitting 54:9

situation

35:6

six 26:1

six-month

69:19

size 17:10

63:10

sizes 12:13

35:13

sledge

15:15 22:11

22:23

slide 10:10

10:16 11:14

11:18 12:15

13:1

13:15 13:17

18:13 20:15

21:7 22:5

23:18 25:14

25:18

30:7

34:12

35:6

35:13 52:10

56:11 58:25

63:7

slides 9:4

24:20 49:17

50:1

60:13 65:24

sludge 12:3

22:25

33:8

33:10

34:2

35:16 54:19

54:22

56:1 56:2

small 49:14

smaller 18:20

smarter 33:24

Smith 5:5 5:5

soil 15:16
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 110

solid 55:3

solids 10:5

solubility

62:3 62:9

63:21 64:11

65:23

someone 34:18

34:25

somewhat

36:22

somewhere

38:5

sooner 8:9

sorry 19:14

24:22

39:6 53:17

sort 14:24

36:11 38:17

39:3

46:10

54:3

56:11 58:19

sought 62:8

sound 19:6

sounds 66:1

66:7

sources 9:7

11:24

22:4 22:6

42:20

57:1 57:2

68:11

speaker

4:13 4:16

5:2 5:12

5:19 62:16

species 12:19

12:20 12:22

14:10

34:3

42:12

55:4

56:10 67:10

67:20

68:3 68:4

69:1 69:2

specific

12:19 13:21

14:1 17:7

39:6

50:14 67:7

specifically

13:18

specifics

18:10

spectrum 23:1

spend 54:2

spent 51:8

spoke 41:1

49:24

spread 22:22

spring 68:14

Squared 3:25

stability

32:6 52:3

staff 26:9

stance 67:22

standard

53:18 76:15

standards

24:13

29:9 53:16

standpoint

17:21 19:24

20:13 52:23

52:24 59:18

Staples

3:21 3:21

Star 3:15 4:1

start 3:7 8:5

19:2

38:25 42:17

70:21

started 19:13

38:16 63:16

65:4

starting

57:11

state 7:12

64:7

stated 5:16

10:1 10:8

12:4

statement

40:16 57:10

statements

56:14

States 63:6

68:24 69:1

stating 9:22

stats 22:23

statute 53:24

statutes 45:4

steady 64:6

step 22:11

36:11 65:11

steps 69:14

steroids 23:5

Steve 4:24

stewardship

50:13 67:16

stop 50:1

straight

32:25 37:22

73:9

strategy

43:13

stream 15:17

stretch 42:17

stricken

54:25

strong 67:12

students

24:18

studied 57:22

studies

46:4

68:21 68:25

71:10

submission

15:20

subsequent

10:17 11:10

24:20

substantial

20:19

32:2 36:5

44:14

substantially

10:17 20:14

substantive
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 111

70:15

substitution

15:24

sufficient

58:9

58:12 58:21

58:23

sufficiently

77:15

suggest 77:15

suggested

10:20 54:18

54:21

suggesting

54:23

suggestion

53:1 75:23

suggestions

76:7

summarize

35:23 66:12

summary 35:13

SUNY 34:14

supplement

44:20

supplies

24:13 25:23

29:8

support 12:16

20:11 37:11

50:6 50:9

70:25

71:4 72:11

supporting

59:18

sure 5:24 7:1

7:8 7:14

7:16

21:25

25:3

25:11 25:15

28:5

72:20 76:24

78:13

surface

10:4

42:14

55:3 56:9

survey

22:11 35:16

suspended

10:4

systematicall

y 57:17

systems 64:10

T

table 7:6

51:5 78:4

tables 35:18

taking

26:10 29:17

33:21 65:11

talk 21:24

22:11 38:21

38:22 40:13

41:3

64:24

66:2 75:2

talked 24:5

30:19 30:21

39:9

39:10 44:21

46:1

47:23 51:17

51:18

61:5 70:8

talking 19:15

39:2

55:13

68:3 78:8

Target 22:10

targeted 20:3

TECHNICAL 3:2

tens 59:9

terms 6:11

6:17 7:9

10:7

12:16

14:3 15:3

16:7 17:5

18:12 36:23

37:15

41:2 41:7

44:12 49:19

49:23

51:3

51:18 54:13

55:19 56:13

56:19 68:10

69:13 69:14

69:15 70:18

76:23

78:9

78:11 78:12

test 26:24

44:21

testing 64:15

67:15

text 9:2

thank 5:24

7:2 7:8

7:18 8:12

15:2 22:1

24:4

66:19 72:16

78:16

79:8 79:12

thanks 22:5

22:19 35:23

47:18

56:4

78:17 79:10

that's

16:11 16:12

28:20 32:11

59:7

59:17

60:9 61:1

62:1

63:23

64:1

64:13 64:23

64:25 65:13

65:23 67:14

69:23 69:24

70:1

70:18 70:22

71:1

71:19 71:20

73:21 74:19

76:3

76:24

77:2

77:17 78:2

themselves

5:1 6:11

ther 22:5
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 112

there'll 69:8

there's

14:4 60:1

60:19 64:14

66:4

68:18 73:18

74:9

74:23 74:25

75:1 76:3

78:11

they're 59:14

62:4

63:25

64:6 64:6

65:13

66:5 66:8

67:9 68:4

78:13

they've 66:24

third-party

66:16

Thomas 3:5

3:8 3:8

6:20 7:2

8:6 10:9

13:18

14:1

17:15

19:7

19:15 19:21

20:5

35:22 37:23

38:2

45:14 45:20

45:24 46:13

46:18 46:25

48:21

49:5

49:13 49:16

53:4

53:10 53:22

53:25 54:12

55:13 55:16

55:23

56:4

69:13

70:6 71:6

72:18

73:2

73:24

74:9

74:14 74:18

75:6

75:17 76:16

76:20 77:14

77:21

78:2

78:16 79:7

thoroughly

57:22

thoughts

8:4 49:18

thousands

59:10

threshold

61:16

throughout

59:20

timeline

71:17

Tobias 4:5

4:5 21:23

21:25

22:2 22:2

23:23

24:4 25:1

25:4 25:8

25:12 25:13

26:16

27:1 27:4

27:8

27:15

28:1 28:3

28:13 28:16

28:20 29:18

29:21

30:1 30:8

30:15

31:5 31:9

31:16 32:24

33:2 33:6

33:17 33:21

33:25

34:7

34:10 35:12

38:6 39:5

39:20 39:25

66:4 66:9

today 6:1

6:12 6:15

6:17 6:19

7:10 54:9

67:3

78:10 79:11

Tokyo 68:22

top 29:23

total 23:3

27:19 73:19

totaled 55:12

totally 37:14

touch 21:14

43:3

touched 59:19

tough 7:7

toxic 41:17

62:3 62:4

toxicity 42:9

42:9

61:16 63:14

toxicologist

33:24 33:25

toxics 8:16

Tracey 4:19

transcribed

62:17

transcript

7:14

transferred

31:13

transparency

52:17

transport

32:6

travel

23:13 24:10

25:20 34:22

traveling

25:21

treated 61:24

74:17 74:21

75:4 75:23

treatment

9:18 9:23

12:1 12:2

12:6

14:13 15:13

20:22 22:14

22:21

40:4 40:8

57:6 57:7
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 113

60:2 76:14

TRI 74:15

tried 36:14

36:19 39:21

tries 14:23

trivial 51:1

trophic 12:21

true 28:20

31:16

46:4 76:23

try 7:16

30:23 50:19

50:21

trying 33:4

33:19 34:10

39:13

41:5

54:10 56:16

56:24 70:16

TSCA 41:12

44:22

turn 6:18

28:7 41:6

twice 38:9

two-tier

57:15

type 13:1

13:4

15:16

17:4

24:24 32:17

40:22

61:8 71:20

types 20:22

typically

5:23 37:3

42:17

57:9

58:16 71:7

U

U.S 3:1 14:10

14:13

15:7

15:24 16:25

17:8

17:18 17:20

17:22 47:17

50:11 59:24

60:3

61:21 61:21

63:2 67:4

67:12 67:17

67:19 67:20

U.S.-specific

67:19

Uh 8:3

Uh-huh

27:15 37:23

UK 44:18

ultimate

52:22

uncertainty

43:8 43:15

unclear 13:17

20:6

underpinning

70:9

understand

16:13 17:18

35:24

39:7 54:4

54:7

61:18 61:21

62:23 62:25

63:18

67:8

74:20 75:13

75:15 75:17

77:15 77:20

understanding

9:7 10:15

11:6 11:8

13:11 15:21

37:3 37:9

41:21 43:15

52:6

54:14 54:23

57:14

59:5 61:1

61:7 61:8

61:24 62:21

63:7

63:11

72:6 73:21

understood

18:11 62:23

undertake

53:11

underway

61:11

unfortunately

29:6

32:25 33:6

UNIDENTIFIED

4:13 4:16

5:2 5:12

5:19 7:5

unique 32:4

44:11 63:11

63:12 63:18

65:21

uniqueness

61:25

unit 15:13

United 63:6

68:24 68:25

universe

19:25 59:5

university

24:17 27:18

35:8

35:10 35:20

Unless 70:3

unreasonable

53:17

update

28:22 47:25

updated 30:9

upon 29:10

30:18

34:4

35:19 69:18

upstream 10:2

useful 20:11

users 9:12

usual 5:23

utilize 17:13

61:16

V

valid 71:18

validates

63:6

validation

32:13 52:3
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 114

valuable 43:6

value 40:23

41:5

59:18 74:4

varying 12:13

Vermont 27:18

35:10 68:24

version 73:4

versus

50:18

57:1

64:21 68:3

view 10:20

10:24 38:18

70:11 77:24

volatile

39:24

volatility

31:12

volume 9:11

9:14 42:7

W

Wacker 3:19

wait 6:23

walking 8:19

Ward 4:4 5:24

6:18 8:1

41:7

42:19

69:3 73:7

warrant 60:4

waste 9:18

9:24

10:23

12:2 12:6

14:12 15:11

15:12 15:13

15:14 20:21

22:14 22:21

40:4 40:7

57:6

water 9:18

10:23

12:2 12:6

12:10 14:13

15:9

15:12 15:18

18:4

20:22 22:10

22:14 22:20

22:21

25:5

26:21

34:2

35:16 35:16

40:4 40:7

42:14

47:5 55:3

56:9 57:6

61:17 73:16

73:20

waters 9:24

10:4 23:17

watersheds

11:20

ways 44:19

web 12:21

14:18 23:17

68:19 68:20

68:21 68:25

webs 13:3

14:11 67:4

website 23:22

42:4 42:23

we'd 66:17

69:24 71:12

week 69:9

weeks 69:17

78:12

weight 63:9

welcome 6:1

16:23

we'll 4:7

66:1

69:10 69:17

69:18

76:3 78:15

we're 14:12

55:16 56:15

58:13

60:9

66:16 67:25

69:6 71:2

72:5 77:20

West 3:14

3:14

39:17 39:18

39:21

we've 11:15

19:20 37:18

59:1

59:19

60:6

60:16

61:4 62:1

62:7 62:8

63:15 64:15

64:21

65:7

65:14 65:15

65:15 65:16

66:13 66:15

67:4 68:9

68:14 68:19

68:19 68:20

68:21

whatever 75:6

WHEREUPON

62:14 72:22

79:13

whether 16:24

17:13 33:21

34:7

37:15

47:2

48:15

54:8 58:7

61:20

63:2 63:2

63:3 65:12

whole 30:24

59:21 79:12

wider 23:1

willing 50:11

66:17

winding 69:6

wondering

63:17

work 34:18

34:21 34:21

35:1 35:2

39:18

40:4 40:7

41:11

42:6 43:4

43:5 44:1

44:10 45:19

65:14 66:17
Siloxane Technical Working Group December 6, 2012 CCR # 16194-7 Page 115

79:3

worked 66:14

workers

26:1

30:10 30:19

working 3:2

26:1

30:10 30:19

52:5 54:9

world 61:17

worried 33:3

worse 37:5

worst-case

58:12 62:14

62:21 70:21

wrap-up 72:19

write 7:23

writing

8:22 23:14

written 9:3

19:18

wrong 55:1

Y

yesterday

39:22

yet 30:18

71:14

you'll 12:25

yours 21:20

yourself

66:25

you've

72:15 79:9