EPA's Monitoring Proposal for Manufacturing, Processing, and Formulating Sites
                                   8/02/2012

Charge:  To develop an understanding of the sources of and pathways to environmental concentrations of D4/D5 in environmental media and biota associated with industrial releases from siloxane manufacturing (M), processing (P), and formulating (F) sites.

Monitoring Objective:  A sampling strategy should collect monitoring data from the appropriate media at appropriate locations in order to characterize the range of environmental concentrations of D4/D5 around the M, P, F sites.  This sampling should also provide information on the effects of several variables on these concentrations.  These variables include production and/or throughput volumes of D4/D5, separation technologies, configuration of on-site WWTP and their various treatment efficiencies, plant activity (M, P, F) and geographical location.  With these data, an understanding can be developed of the environmental concentrations of D4/D5 around M, P, F sites to support a national risk assessment for D4 and D5.  

EPA's Proposal:   Four of the thirteen M, P, F sites associated with the SEHSC directly discharge their wastewater from the site into rivers (see Table 1 below).   Seven of the thirteen sites indirectly discharge (via a POTW) their wastewater into various water bodies (see Table 2 below).   EPA agrees with the SEHSC that the four direct discharge sites should be monitored.  Additionally, EPA proposes that all the indirect discharge sites be monitored in order to accomplish the stated charge unless there is a scientific basis for excluding monitoring at a facility.

Tables 1 and 2 below identify the direct and indirect discharge sites EPA proposes to monitor.    

                       Table 1.  Direct Discharge Sites

 
 
                                   Activity
 
 
Company
Facility
City, State
D4
D5
Discharge
Receiving Water Body
Dow Corning
Carrollton Plant
Carrollton, KY
M,F
M,F
Direct
Ohio River
Momentive
Waterford Plant
Waterford, NY
M,F,P
M,F,P
Direct
Hudson River

Sistersville Plant
Friendly, WV
P
P
Direct
Ohio River
Wacker Chemical
Wacker Chemical
Adrian, MI
P
P
Direct
River Raisin







	
                      Table 2.  Indirect Discharge Sites
 
 
 
                                   Activity
 


 
Company
Facility
City, State
D4
D5
Discharge

On-site WWTP Configuration



POTW
Location & Configuration
Receiving Water Body
Bluestar
Silicones
Ventura Plant
Ventura, CA
P
F,P
Indirect
TBD

TBD
TBD
Dow Corning
Greensboro Plant
Greensboro, NC
F,P
F
Indirect
                                       
TBD

TBD
TBD

Auburn Plant
Auburn, MI
F
F
Indirect
TBD
TBD
TBD

Healthcare
Industries Mtrls
Hemlock, MI
F
F
Indirect


TBD


TBD
TBD

Midland Plant
Midland, MI
P
P
Indirect
TBD
TBD
TBD

Elizabethtown Plant
Elizabethtown, KY
P
P
Indirect

TBD

TBD
TBD
Evonik Goldschmidt
Hopewell Plant
Hopewell, VA
P
P
Indirect

TBD

TBD
TBD
Shin-Etsu Silicones
Shin-Etsu Silicones
Akron, OH
--
F
None

TBD

TBD
TBD

Shincor Silicones
Akron, OH
P
--
None

TBD

 TBD
TBD


Rationale for EPA's Proposal to Include the Thirteen Direct and Indirect Discharge Sites:   The environmental releases of D4/D5 from both these direct and indirect discharge M, P, F sites depend upon a number of factors as stated in the monitoring objective.  In order to accomplish the charge stated above, the effect of these factors on the sites' releases of D4/D5 to a POTW and/or to a water body need to be understood, and this is only feasible if all the thirteen direct and indirect discharge sites are monitored.   
 


