Meeting Time /Date /Location
Date
9/6/2017
Time/Location
11:00am  -  12:00 pm (EST) 
Dial In
1-855-564-1700, Conference Extension:  1107547, Code: 234567

Agenda
Introductions 
Previous Meeting with SI on 2,4,6-TTBP
Existing uses
Recycling, waste, recovery 
Imports and imported articles
Critical uses
Available substitutes
Next steps and follow up

Meeting Attendees:
SI Group:
Kevin Kransler
Peter Miranda
Peter Vanderhook
Cary Mavean

EPA:
Todd Coleman, OPPT
Doug Parsons, CCD
Erik Winchester, OPPT
Peter Gimlin, OPPT
Stephanie Suazo, Chemistry Economics and Sustainable Strategies Division

Previous Meeting with SI on 2,4,6-TTBP:
Kevin Kransler, SI Group: SI Group would like to reestablish a communication channel with EPA. We would like to get more information on how the assessment for TTBP will likely occur, what type of information SI Group can provide, and how that information can be passed along. It may be useful to start with a discussion of the roles and responsibilities.
Doug Parsons, EPA: As an overview, EPA released the use documents in early August, which are now open for public comment. EPA would like people to submit use and exposure information as well. The docket is open until December 9, 2017. EPA would like to know if there are any errors, incomplete information, or missing uses or exposure scenarios. This information is useful as EPA continues the exposure assessments for these compounds. 
Kevin Kransler, SI Group: How will EPA utilize this use and exposure information? Will the data be incorporated into exposure models?
Doug Parsons, EPA: This is the first time EPA has done this, so risk evaluations for these PBT chemicals are not required. The standard EPA must meet is to reduce exposures to the extent practicable. Section 6(h) of TSCA requires EPA to determine the exposure under the conditions of use, either to the general population, susceptible subpopulations, or the environment. To do this, EPA is starting with the use documents to figure out what the exposures are and whether there are exposures under these very specific conditions of use that EPA has identified. The next step will be to conduct an exposure assessment and put it out for public review and comment. That might not occur until the proposed rule is done, which is set for June 2019. 
Todd Coleman, EPA: That is a good overview of the key steps of the process. Of course, there are a variety of paths to get to the point of understanding exposures. 
Erik Winchester, EPA: The more information EPA has, the more certain we are about what we are doing, and the more certain the information is that is being provided to the public. EPA seeks ways to reduce the uncertainty in our understanding of exposure, which is why EPA is always asking for data on exposure or documentation that there is no exposure. 
Doug Parsons, EPA: During my career at EPA, I have done a lot of work on pesticides in food and residential exposure assessments for pesticides. Sometimes through that process, EPA would come out with its best estimate of what the exposure might be, and then the companies would do the same. Or, before EPA came up with the assessment, the companies would gather exposure information to figure out what the exposures were. This exposure information really helps EPA tailor restrictions on the pesticides. As Erik said, the exposure information results in much more realistic regulations, if that is what is needed in the process. Following the chemical throughout the process will help to really understand what and where the exposures are.
Kevin Kransler, SI Group: This is valuable feedback and helps define the type of data to gather. SI Group is interested in being a willing stakeholder. Is there a method to submit confidential information to the public docket?
Doug Parsons, EPA: In the Federal Register notice, there are guidelines on how to submit information as Confidential Business Information (CBI).
Todd Coleman, EPA: The information can be found in the memo of the Federal Register notice. If the information is CBI, we encourage you not to hesitate to send it. There are procedures for submitting CBI, and the information is still very useful to what EPA is doing.
Cary Mavean, SI Group: Are there other ways EPA is gathering information on TTBP? Are there other companies EPA is reaching out to? 
Doug Parsons, EPA: EPA talked to Afton Chemical, the Department of Defense, NASA, and other federal partners like OSHA, NIOSH, and CPSC. DoD has interest in this chemical and has identified some uses. They have been asked to go through their supply chain again. EPA welcomes additional contacts to reach out to if SI Group has suggestions. 
Cary Mavean, SI Group: SI Group has started reaching out to its customers, gathering some information, and verifying uses. We have been doing our own analyses of exposure as we both use and manufacture the substance. We are putting this together and can provide the information to EPA. 
Doug Parsons, EPA: That would be very useful.
Kevin Kransler, SI Group: In November 2016, SI Group visited EPA to discuss TTBP, providing some basic information on the manufacture of TTBP. Is this information available to the team now? I believe we left sanitized information.
Cary Mavean, SI Group: The information never made it into the docket. Should any information provided from this point be submitted into the docket?
Doug Parsons, EPA: Yes, it would be best to resubmit that information. The team has evolved on these TTBP chemicals.
Peter Gimlin, EPA: There are a lot of people involved in this project, for the 5 PBT chemicals and the other first 10 chemicals. There are people from two divisions and economists supporting this work. Todd Coleman and I have been working on TTBP. Erik Winchester is our immediate supervisor. Cindy Wheeler will be making the general presentation for the webinar, and Doug Parsons has been working on coordinating all the work.
Doug Parsons, EPA: Stephanie Suazo is also on the line, as our economist.
Kevin Kransler, SI Group: This is very helpful. SI Group has had our own internal shuffling as well. We appreciate the time today in helping us understand the process and learn how to be a good partner.
Doug Parsons, EPA: It may be useful to mention what we are doing for the first 10 chemicals, as it may spill into this. For these chemicals, EPA completed use documents in February, scoping documents in June, and now EPA is in the process of doing problem formulation. This essentially scopes out exactly which uses will undergo risk evaluations. Through this process, EPA is trying to better understand what other statutes, like the Clean Water Act, Safe Drinking Water Act, and other environmental laws, may regulate these chemicals. It may be useful for SI Group to start looking at what other environmental laws are regulating TTBP as well.
Kevin Kransler, SI Group: That is a good comment.
Existing Uses:
Todd Coleman, EPA: SI Group took over the manufacture of the chemical for Albemarle, correct? SI Group and Albemarle both reported in 2012, but in 2016, only SI Group reported. 
Cary Mavean, SI Group: Yes, that is correct.
Todd Coleman, EPA: Is there any more guidance on which customers are sourcing this chemical directly from SI Group? Is there any idea if and when this data is going to be made available?
Kevin Kransler, SI Group: SI Group will provide this information to EPA as it becomes available. We are still gathering information on customers and use conditions.
Cary Mavean, SI Group: SI Group is working on how to best present the confidential information and provide it to EPA. We have reached out to our customers.
Todd Coleman, EPA: In the use document, fuel additives and lubricants have been identified. Is SI Group aware of anything else TTBP is being integrated into, based on what you know about your downstream entities?
Kevin Kransler, SI Group: SI Group is not aware of any other uses.
Recycling, Waste, Recovery:
Doug Parsons, EPA: The uptick in the CDR information is because SI Group took over Albemarle's volume, correct?
Kevin Kransler, SI Group: Yes.
Doug Parsons, EPA: So, the poundage every year isn't really going up; it is pretty stable.
Kevin Kransler, SI Group: Comparing 2012 and 2016 CDR data, the numbers are similar. It may be useful to point out that, while we are still looking through the data, a significant portion of the chemical is recovered through our processes. 
Todd Coleman, EPA: EPA would like information on how much is recovered in the process and what happens to it, whether it is recycled, turned into something else, used as a reactant, etc.
Kevin Kransler, SI Group: Understood.
Imports and Imported Articles:
Todd Coleman, EPA: Does SI Group import or export? Do you foresee any changes to this?
Kevin Kransler, SI Group: I think there is some export, but there is no import.
Critical Uses:
Todd Coleman, EPA: Is SI Group aware of any critical uses in commerce or anything that cannot be replaced?
Kevin Kransler, SI Group: The DoD uses may be an example.
Doug Parsons, EPA: Section 6(g) in TSCA allows critical uses. These uses of TTBP are regulated under Section 6(h). Section 6(g) is a way the agency can give exemptions for critical or essential uses. It also includes the defense waiver. It would be useful for SI Group to look at this. So, are there any critical uses other than the ones DoD would identify?
Kevin Kransler, SI Group: SI Group is also aware of commercial operations in jet fuel. So, commercial airlines would be another use.
Todd Coleman, EPA: Afton Chemical also mentioned commercial airlines. EPA is also looking into its uses in antioxidants. It sounds like TTBP is mainly in the fuel and fuel additive market. 
Kevin Kransler, SI Group: Yes, it is a pretty small market.
Todd Coleman, EPA: Environment Canada, European Chemicals Agency (ECHA), Japan, and Australia have all done some work on this. Has SI Group worked with any of these governments in trying to develop their chemical regulation programs?
Kevin Kransler, SI Group: SI Group had some interaction with Environment Canada when they were developing the SNAc (Significant New Activity) back in 2011. There was some correspondence between Albemarle and Japan. We are not sure of any interaction with Australia.
Cary Mavean, SI Group: Europe is just starting their review, so that will be starting next year.
Kevin Kransler, SI Group: Right. They are probably a year behind where EPA would be.
Doug Parsons, EPA: On the initial 10 chemicals, EPA did outreach with Environment Canada and ECHA. EPA will likely do more international outreach with all the PBTs at some point. 
Todd Coleman, EPA: The only reported use in the 2016 CDR was as an intermediate in all other basic organic chemical manufacturing. EPA did not find a lot of publicly available information about the chemicals used as an intermediate in basic organic chemical manufacturing or the plastics and resin industry. The plastics and resin industry use was reported in 2012 but not in 2016.
SI Group: SI Group cannot attest to the 2012 CDR information provided by Albemarle. With respect to the use of this chemical intermediate, SI Group is now developing more specific data. TTBP is recycled back into the processing stream. Greater than 95% goes back in for reconversion into a mono-substituted phenol. It is intentionally re-equilibrated and some of the butyl groups are removed. These are relatively volatile materials.
Kevin Kransler, SI Group: A more simple answer is that SI Group is coming up with a manufacturing process, which will be part of the information provided to EPA.
Doug Parsons, EPA: For some other PBT chemicals, companies have provided flowcharts on the manufacturing process.
Stephanie Suazo, EPA: EPA would like to have information on uses and downstream processers for which TTBP is used as an intermediate.
Kevin Kransler, SI Group: We will look into that.
Available Substitutes:
Todd Coleman, EPA: Is SI Group aware of any direct substitutes for TTBP? I know it is spec'd into a lot of standards as fuel additives and antioxidants.
Kevin Kransler, SI Group: SI Group is unaware of any substitutes.
Doug Parsons, EPA: The chemicals are put in the fuel at the refining facility, then shipped, and then burned. Is this correct?
SI Group: The chemical may not be put in at the refining facility. It is more likely put in at a terminal location.
Doug Parsons, EPA: Has anyone done any emissions testing to see if the chemicals are destroyed in the combustion process and if there are any environmental releases?
Kevin Kransler, SI Group: SI Group will have to look into that. Environment Canada may have some data on this, as they did an assessment 6-7 years ago.
Doug Parsons, EPA: EPA will contact Environment Canada, and we can share the information with SI Group as well if it is useful.
Next steps and follow-up:
Kevin Kransler, SI Group: EPA has provided some great questions. SI Group will try to address them in our submissions to the docket. Please reach out to me if there are any other questions. 
Doug Parsons, EPA: This is the first group of chemicals EPA has done this way, where risk evaluations are not needed. It is a learning process for everyone. 
Peter Gimlin, EPA: Are any of you intending to make comments at the webinar tomorrow?
Kevin Kransler, SI Group: We will be listening tomorrow. That is why we wanted to have this call, to reintroduce ourselves and get reestablished with what you are looking for and how we can be a good partner.
Doug Parsons, EPA: We appreciate that. Thank you all.
