DR. DANIEL SCHLENK:  Thanks, George.  Yeah, I think that probably might fit with C a little bit when we get into some of the other sources that weren't considered.  But thanks for bringing that up.
                  DR. GEORGE COBB:  Yeah.  And I don't feel a need to say this again, and we'll put this wherever it goes in the report.
                  DR. DANIEL SCHLENK:  Gotcha.  I think your point's very clear.  Okay.  Any other comments from the Committee on 4b?  Okay, not hearing any, let me go to Dr. Choudhary and see if he has any questions or clarification regarding the Committee's response.
                  DR. REHAN CHOUDHARY:  Afternoon, Rehan Choudhary here.  If you just give me a moment, I'm going to confer with the team to see if they have any questions they'd like to bring forth with respect to clarification.
                  DR. DANIEL SCHLENK:  Sure.  No worries.  Actually, would you like to take a break?  We can -- we're actually due for a break if you want to take a ten-minute break to interact with them.  Would that be appropriate?
                  DR. REHAN CHOUDHARY:  I think that would work out well.  It'll give us ten minutes to clarify whether there are any follow-ups from our end.
                  DR. DANIEL SCHLENK:  Great.
                  DR. REHAN CHOUDHARY:  And everyone can take a brief break as well.
                  DR. DANIEL SCHLENK:  Yeah.  Let's go for a ten-minute break and be back at 30 minutes past the hour.  That's actually a 12-minute break, but let's go to 30 minutes past the hour.

                  [BREAK]

                  DR. DANIEL SCHLENK:  Okay.  I have 30 past the hour.  Let's check and make sure everybody is back.  Looks like it so far, at least enough for a quorum.  Okay.  So let's go to Dr. Choudhary again.  Having convened with your affiliates, do you have any questions or clarification for the comments made by the Committee?
                  DR. REHAN CHOUDHARY:  Afternoon everybody.  Rehan from the EPA.  No.  We've conferred together and at the time there are no clarifications that we need for 4b.
                  DR. DANIEL SCHLENK:  Great.  Thank you, very much.  So at this point in time, we are scheduled to do 4c, but after getting a few comments back from several members of the Committee I think what we'll do is this.  I think c, particularly, might be a bit lengthy, and I don't think we'll be able to get d, for sure, today.
                  So I think at this point, let's go ahead and defer c until tomorrow morning and adjourn for this afternoon.  It's 3:30 Eastern which -- yeah, I don't think we'll be able to get both in in an hour and a half.  So let's go ahead and adjourn for today, and then we'll start 4c first thing in the morning.  Dr. Kissel, you have your hand up.
                  DR. JOHN KISSEL:  Yeah, John Kissel.  I wanted to say, since this is a kind of a loose end might as well do it now instead of waiting until tomorrow.  But yesterday I asked about the permeability coefficient for NMP, and EPA said they would get back to us offline.  By email, they have shared the origin story for that number, and it turns out it's an optimization from a PBPK model which raises additional questions.
                  So it's from a human trial, and normally human data for a specific compound trumps what you would get from animal studies or from an algorithm that describes regression through a bunch of data.
                  The problem with multi-parameter PBPK models is that you can get a really nice fit by getting a half a dozen or so parameters wrong because you're compensating errors can make the thing look really, really good when, in fact, some of the underlying assumptions are wrong.  Among the underlying assumptions that they made was to get the number that they're ultimately using was that only 25 percent of the skin is exposed to vapor, which means that you're assuming that clothing is a vapor barrier which is certainly not true.
                  Cotton weave shirts are not vapor impermeable, and basically, whole bodies are exposed.  It might be that there's a little bit of additional mass transfer resistance because of a stagnant air layer under the clothing.  But certainly, clothing does not hermetically seal skin.
                  So if you start with some bad assumptions and then do multi-parameter fitting, you can get a number.  But I think that the assumption that human trial data trumps other options goes away if there's enough questions about the human trial data and how it was derived.
                  And this gets back to a question that somebody else raised is EPA has multiple estimators for many parameters.  And, you know, how do they choose them?  In this case, this is supposed to be a screening tool, but it's being applied to specific cases.  And you have a specific case where you had some human data that's been interpreted in one particular way.  And maybe that's a plus and maybe it's not.
                  I would think a screening tool -- you know, we've been through this now those of us who are veterans of this process know that the whole process is way too slow to actually deal with the need.  The throughput of the number of compounds we have to deal with, or EPA has to deal with, and the amount of time it takes to do these one at a time kind of analyses, well, you know, conceptually you can say, gee, it's good if we've got some compound-specific data for this compound.
                  Ultimately, EPA's going to have to resort to some type of a machine learning or automated process, and they're going to want to use the same algorithm for 200 compounds and then just start cranking out results.  And so I'm not sure in this case that the permeability coefficient is preferable to another value of the permeability coefficient that could come from a different direction.  And I'm not sure that that strategy is workable in the long run, especially for a screening tool.
                  DR. DANIEL SCHLENK:  So which question would this be more pertinent toward, would you say?
                  DR. JOHN KISSEL:  The original question was Question 1.
                  DR. DANIEL SCHLENK:  Okay.
                  DR. JOHN KISSEL:  Because it was the question of clarity.  And I wanted to know where the permeability coefficient came from.
                  DR. DANIEL SCHLENK:  Okay.
                  DR. JOHN KISSEL:  So I think that's where it should be added.
                  DR. DANIEL SCHLENK:  Okay.  So if you could, please send those to George.  I think he's lead on Question 1.
                  DR. JOHN KISSEL:  Right.
                  DR. DANIEL SCHLENK:  Perfect.  Okay, thanks.  All right, so let's -- oh, do you have a question, Dr. Choudhary?
                  DR. REHAN CHOUDHARY:  Just a clarification, Dr. Schlenk.  The clarification, the follow-ups we had sent you, those were sent to the SACC Committee members.  I think one of them was that KP question, and the other had to do with adjustment factors.  So those have been relayed?
                  DR. DANIEL SCHLENK:  Yeah.
                  DR. REHAN CHOUDHARY:  Okay.
                  DR. DANIEL SCHLENK:  Yes, those were sent.  Alaa sent those out to the appropriate individual.  So, yeah, we got that.  Okay.  Well, thanks, everybody, for a full day of discussion.  Had a lot of information going back and forth amongst folks.  We'll be ready for tomorrow morning and, hopefully, finish this up.  So thanks again and have a great afternoon and evening on the east coast.
                  DR. ALAA KAMEL:  Thank you, very much, Dr. Schlenk, for chairing today's session as well.  And I would like to thank all of the SACC members for contributing to the charge Questions 2 and 3 and 4a and b.  And we will meet again tomorrow morning.  So today's meeting is adjourned.  Thank you.
                  DR. DANIEL SCHLENK:  Bye.
                  DR. ALAA KAMEL:  Bye.

                  [MEETING ADJOURNED FOR THE DAY]

OPENING OF MEETING - DAY 3

                  DR. ALAA KAMEL:  Good morning, everyone.  My name is Alaa Kamel, and I am serving as the Designated Federal Official to this U.S. EPA Science Advisory Committee on Chemicals.  For this meeting, and in my role, I will be opening the third, and last day, of the public meeting on EPA's Draft TSCA Screening Level Approach for Assessing Ambient Air and Water Exposures to Fenceline Communities Version 1.0.
                  I'd like to repeat that SACC meetings are subject to all FACA requirements.  These include open meetings, timely public notice of meetings, and document availability of the public.  All documents are available to the public in the docket at regulations.gov.  And as a reminder, this meeting is being webcasted, transcribed, and recorded.
                  The live stream of today's meeting is available on YouTube as well.  See the link on the meeting website.  The website also has links to the meetings that we had yesterday and the day before on March 15 and 16th of 2022.
                  I'd like to thank Dr. Daniel Schlenk, the chair, for chairing yesterday's session, and to the Committee members and ad hoc reviewers for responding to Charge Questions 2, 3, 4a, and 4b.  Thanks, are also due to the EPA's Office of Pollution Prevention on Toxics team for their responses to all the questions submitted by the SACC.  And now I'd like to hand the meeting over to the chair, Dr. Daniel Schlenk.  Dr. Schlenk.
                  DR. DANIEL SCHLENK:  Thanks, Alaa.  Good morning, everybody.  Welcome to our last day and happy St. Patrick's Day.  We begin by taking a roll call of the Committee.  So, I'll begin in alphabetical order.  Dr. Apte.
                  DR. UDAYAN APTE:  Present.
                  DR. DANIEL SCHLENK:  Dr. Baker.
                  DR. MARISSA BAKER:  Present.
                  DR. DANIEL SCHLENK:  Dr. Blystone.
                  DR. SHERI BLYSTONE:  Present.
                  DR. DANIEL SCHLENK:  Dr. Calder.
                  DR. RYAN CALDER:  Present.  Sorry.
                  DR. DANIEL SCHLENK:  No worries.  Dr. Chaisson.
                  DR. CHRISTINE CHAISSON:  Present.
                  DR. DANIEL SCHLENK:  Dr. Cobb.  Dr. Cobb?  Got your mute button?  Okay.  Dr. Davies.
                  DR. HOLLY DAVIES:  Present.
                  DR. DANIEL SCHLENK:  Dr. Doucette?
                  DR. WILLIAM DOUCETTE:  Present.
                  DR. DANIEL SCHLENK:  Not virtually present?
                  DR. WILLIAM DOUCETTE:  Not virtually present.  I'm present.
                  DR. DANIEL SCHLENK:  Okay.  Dr. Ferry.
                  DR. JOHN FERRY:  Present.
                  DR. DANIEL SCHLENK:  Dr. Gribble.
                  DR. MATTHEW GRIBBLE:  Present.
                  DR. DANIEL SCHLENK:  Dr. Heiger-Bernays.
                  DR. WENDY HEIGER-BERNAYS:  Present.
                  DR. DANIEL SCHLENK:  Dr. Henneman.
                  DR. LUCAS HENNEMAN:  Present.
                  DR. DANIEL SCHLENK:  Dr. Johnson.
                  DR. MARK JOHNSON:  Present.
                  DR. DANIEL SCHLENK:  Dr. Kissel.
                  DR. JOHN KISSEL:  Present.
                  DR. DANIEL SCHLENK:  Dr. Li.  Dr. Li?  Okay, no Dr. Li.  Dr. Messerlian.
                  DR. CARMEN MESSERLIAN:  Present.
                  DR. DANIEL SCHLENK:  Dr. PRZYBYLA.
                  DR. JENNIFER PRZYBYLA:  Present.
                  DR. DANIEL SCHLENK:  Dr. Reif.
                  DR. DAVID REIF:  Present.
                  DR. DANIEL SCHLENK:  Dr. Reiss.
                  DR. RICK REISS:  Present.
                  DR. DANIEL SCHLENK:  Dr. Sathyanarayana.
                  DR. SHEELA SATHYANARAYANA:  Present.
                  DR. DANIEL SCHLENK:  Dr. Unseld.
                  DR. MONICA UNSELD:  Present.
                  DR. DANIEL SCHLENK:  And Dr. Vorhees.
                  DR. CHARLES VORHEES:  Present.
                  DR. DANIEL SCHLENK: Great.  Let me go back.  Dr. Cobb?  Okay.  And Dr. Li?
                  DR. LI LI:  Here.
                  DR. DANIEL SCHLENK:  Okay, got you.

PANEL MEMBERS: FOLLOW-UP ON PREVIOUS DAY PRESENTATIONS

                  DR. DANIEL SCHLENK:  All right, let's go ahead and move forward.  We've got a lot of discussion in the last couple days on the questions.  Again, thanks to the Committee and participants there.  Seems to be a lot of consensuses, at least on some of the components regarding uncertainty and issues related to model development and assessment as well as data quality discussions.  So hopefully that will be coming out in the minutes for the Agency to peruse.  Today, what we hope to do is finish up Question 4 and start with 4c and then with 4d.
                  Before that, we have a couple announcements.  I believe, Dr. Henneman, you had something you wanted to state just for the record.
                  DR. LUCAS HENNEMAN:  Yeah, thanks, Dr. Schlenk.  This is Lucas Henneman.  This is thinking about communicating uncertainties relevant way to back to Question 1.  I just wanted to note that in Section 2.4, which is the section that goes into depth about uncertainties, I thought it would be useful to include explicit qualitative uncertainty statements indicating most likely direction and magnitude for each assumption or uncertainty.
                  So, for each source of uncertainty identified, do we expect that to be large or small?  And in which direction do we expect that to push the results to the extent possible?  And that's my comment, thanks.
                  DR. DANIEL SCHLENK:  Great.  Thanks, and yeah, just get that to Dr. Cobb.  I think he's the lead for Number 1.  Yep.  Dr. Johnson.
                  DR. MARK JOHNSON:  Yeah, I just want to agree with Dr. Henneman.  In fact, I was constructing the same statement for 4c when we get to it, but basically, just to acknowledge that there's a difference between uncertainty and variability.  I mean, variability can be reduced by collecting additional data; uncertainty cannot.  And I think we need to be candid, and we need to be honest that in some cases we have no idea what the magnitude of uncertainty is.
                  And so, we just need to honestly state that, that there's some things we just don't know.  And to just arbitrarily slop an order of magnitude of uncertainty factor on it I think is a bit irresponsible.  We need to be careful on how we do that.
                  DR. DANIEL SCHLENK:  Okay, thanks for that comment.  I guess we'll wait to see here for that in a couple minutes.  Okay, so let's go ahead and get rolling.  At this point, let me go to the Agency to ask if they have any further questions of clarification before we move on to 4c.  Dr. Choudhary.  Yep.
                  DR. REHAN CHOUDHARY:  Good morning, everybody.  This is Rehan Choudhary from the EPA.  Yes, Kevin and I have been discussing some items, and I'm going to pivot to Kevin Vuilleumier.  I believe there's a clarification that he's seeking.  Go ahead, Kevin.
                  DR. KEVIN VUILLEUMIER:  Thank you, Rehan.  This is Kevin Vuilleumier with the EPA.  We actually had two clarifications that we wanted to kind of mention.
                  The first relates to a comment, I believe, that Dr. Davies may have raised yesterday on Charge Question 3 about the receptor height we used for the modeling.  We chose 1.8 meters as the average adult receptor, and the discussions yesterday indicated that may not be representative of adult females or children.
                  So, for clarification, the recommendations, we're hopeful that if the SACC has some recommendations for considering the adult female height and children height for receptor height that would be great to have as well as the basis for choosing that as the receptor height can further inform the modeling.
                  In relation to Charge Questions 4a and 4b, we believe we heard during deliberations yesterday that in some aspects, our geospatial approach to modeling exposures may not precisely align with the way certain data is collected or available.  For example, the census block group set that was mentioned yesterday.
                  To better inform EPA on the pathways for which we currently have and the proposed methodology for the ambient air and the ambient water pathway, we're hopeful that the written recommendations from the Committee will include suggestions on how we may better align the geospatially modeled exposures to such available data.  And those are the two clarifications that we're seeking.
                  DR. DANIEL SCHLENK:  Okay, so, Dr. Johnson, did you want to address that since that was 4a?
                  DR. MARK JOHNSON:  It wasn't specifically my comment, so I would be uncomfortable doing so.  But the individual who did provide that comment, if they want to step forward?
                  DR. DANIEL SCHLENK:  I didn't catch the notes to who actually made the comment.
                  DR. RICK REISS:  If you're talking about the latter one, about the geospatial, how to use the census block data given the geospatial resolution of the modeling?  That was my comment.  And I believe that we did provide -- that Monica read it into the record, some recommendations on how to use that.  I mean, the basic idea would be to not do it at the census block level but rather just do it at a broader geospatial level.  The 10,000 meters because then some of those errors would cancel out.
                  So, that I think, we can have that certainly in the record.  I think it was already read into the comments.
                  DR. DANIEL SCHLENK:  Great.  Thanks, Dr. Reiss.  Sheri, do you have a comment?
                  DR. SHERI BLYSTONE:  Yeah.  I think the first part of the question about the 1.8 meters was in our comment.  I'm pretty sure it was Dr. Cobb that said that.  We'll clarify exactly what the question is.  I think there was just an observation perhaps that might be high.  But it either will say we need more clarity of where that came from or a recommendation on how that should be changed.  Is that what you're looking for?
                  DR. DANIEL SCHLENK:  It sounds like it, yeah.
                  DR. KEVIN VUILLEUMIER:  Yes, or if they have suggested additional heights to represent other age groups or something like that. That's where we'd look for the input from SACC.
                  DR. SHERI BLYSTONE:  Okay, thank you.
                  DR. KEVIN VUILLEUMIER:  Thank you.
                  DR. DANIEL SCHLENK:  Great.  Okay.  No other comments in play here.  Let's go ahead and move forward then.  If we can put Charge Question 4c up on the board and read that into the record.  Choudhary.

CHARGE QUESTION 4C

                  DR. REHAN CHOUDHARY:  Yes, this is Rehan Choudhary from the EPA.  Charge Question 4 to the SACC Committee, subpart c: "Please propose and describe approaches that EPA can take into consideration for the purposes of expanding the capacity of the proposed screening methodology, Version 1.0, presented in this work.  Some possible examples may include but are not limited to, subpart c, how the proposed screening-level approach may be expanded to evaluate exposures from additional pathways such as land disposal or groundwater contamination."
                  DR. DANIEL SCHLENK:  Thanks.  The discussant for this one is Dr. Davies.
                  DR. HOLLY DAVIES:  Good morning.  So, I have responses from the associates, and I have been making notes during the meeting whenever someone has mentioned other pathways, and I've incorporated these together for a summary.
                  But first, I wanted to start by thanking EPA for proposing a method to such risk to fenceline communities, especially with all of our critical suggestions last couple of days.
                  So, one thing I've heard from the Committee is the importance of including more pathways to sufficiently characterize exposures and risk.  I've also heard or gotten comments from several people about mentioning the idea of this tiered approach perhaps with different data, different pathways in higher tiers.  And we're going to talk about data evaluation in the systematic review method.
                  I just wanted to mention this is an opportunity to include information from communities that we've been talking about.  And EPA needs to continue to facilitate charge to protect the public and also providing guidance to communities that they may wish to pursue and submit their independent data and being able to include this in the methodologies for getting data.
                  One idea is to merge emissions data with available activity data.  So public and private well locations, for instance, to aid in prioritizing sources and communities for more in-depth risk assessment, part of this tiered approach, including targeted monitoring campaigns.
                  We should incorporate observational data to assess exposure as much as possible for communities mentioned the NATTS network, available groundwater samples.
                  A notice that AERMODs can be applied to estimate deposition of the chemical of interest and the spatial pattern of deposition.  And this air deposition pattern could be used to quantify total chemicals deposited to soil from the facility.
                  And longer-term abuse would have epi studies to inform this expanded view of the pathways and the data.
                  So, I believe there's a consensus of including more pathways, the importance of including more pathways, and this does depend both on the chemical characteristics and the relevance of the pathway.  One example is fish consumption is a really important pathway for persistent bio-cumulative toxic chemicals, which are not the case studies we've been looking at here.
                  Groundwater was mentioned by several people, a very important pathway to groundwater, both vapor intrusion and private well.  Chemical emissions, multiple media may influence groundwater.  And one starting point would be to classify facilities by their total emissions to all media.
                  As mentioned earlier, TRI data isn't just air and water, it also includes other pathways.  And given also that these pathways can be much further, like air deposition can be farther and the groundwater pathway because of the way groundwater moves, it could move long distances.  So, the definition of fenceline communities might need to be expanded to fit that.
                  So, the movement of chemicals in groundwater is very dependent on the characteristics that would have to be characterized in the higher tiers when looking more specifically at risk and including the chemical transformations that are different in soil and the volatilizations in soil that may be relevant and important for certain chemicals and areas.
                  We need more groundwater monitoring.  And, of course, just pointing out in terms of protecting fenceline populations, that private wells tend not to be monitored.  We've talked about municipal water systems that are monitored -- not specifically monitored -- but looked at for chemicals and concerns.  So, a lot of people don't know what chemicals that are in their private wells.
                  There's other pathways, one mentioned the comments from the National Tribal Toxics Coalition about both drinking water, and they mentioned hygienic water for bathing.  This is also mentioned by Committee members.  And also, the ceremonial use to a steam bath and emersion.  And we have to take into account the different cultural practices of different communities.  Not only for fish consumption is important for many chemicals but also game consumption.  EPA should not look at the average person but at specific communities and their consumption practices, especially the communities that have high consumption.
                  We also have the pathway through biosolids, wastewater treatment plants, and then biosolids that are spread on the fields, which may be important for some chemicals but should at least be looked at.  And related to biosolids is also plant uptakes, both from spreading biosolids and plant uptake from aerial deposition and other ways that chemicals have gotten onto the soil.
                  Another pathway is spills, accidental releases.  We know that these happen and that they should be dealt with in the exposure pathway assessment.  Also, the combined sewer outfall which I put in with these accidental releases in that category.
                  We also have exposures from household products, whether that's taking into account specifically with household products or with the background factor of we know that people are being exposed to household products also.
                  And disposals and landfills and, again, something mentioned by the tribes -- especially, in Alaska -- they've given us lots of details.  Both in the comments of this meeting and comments from previous meetings about people's exposures through landfills.
                   Also I wanted to mention the aggregate and cumulative exposures that we've been talking about.  Rather than looking at specific one at a time, one pathway at a time, one chemical at a time, looking at exposures together.  Occupational exposure, people who get occupational exposure also then live in fenceline communities and the multiple facilities.
                  And then two comments about hazard assessment.  Looking at the traditional -- not expecting a traditional dose-response curve because that might underestimate risk, especially for chemicals that are endocrine disruptors.  I think these comments are partly because we're looking at a general method that EPA has said they want to use for the chemicals that are currently on the table and in the future.  So, talking about possible future chemicals they'd be looking at.
                  And so, looking at the dose-response relationships with the real-life context and uncertainty and reflecting the missing data.  And also, the non-cancer outcomes, including outcomes from long-term low-dose exposure, must be included in the analysis before the regulatory outcomes are decided.  And we know we have exposures in certain places in the country with multiple facilities and multiple chemicals.
                  At this point, I'll turn back to Dan to ask the associates.
                  DR. WILLIAM DOUCETTE:  Dan, you're muted.
                  DR. DANIEL SCHLENK:  I'm muted.  I was telling her she was muted.  Dr. Unseld, please.
                  DR. MONICA UNSELD:  I think Holly did a better job explaining my comments than I did, so I have nothing to add.  Thank you.
                  DR. DANIEL SCHLENK:  Great.  Dr. Henneman.
                  DR. LUCAS HENNEMAN:  Thank you, Holly.  I have nothing to add.
                  DR. DANIEL SCHLENK:  And, Dr. Cobb.
                  DR. GEORGE COBB:  Nothing to add.  Thank you, Holly.
                  DR. DANIEL SCHLENK:  Wow.  Fantastic job.  Okay, any other Committee members for this one?  Yeah, Dr. Gribble?
                  DR. MATTHEW GRIBBLE:  Thank you.  This is Matthew Gribble, a temporary member of the SACC.  And I am just wanting to respond to one part of Charge Question C.  How the proposed screening-level approach can be expanded to evaluate exposures from additional pathways?  I agree with all of Dr. Davies' summary of the multiple exposure pathways that may require consideration and the need for a tiered approach or the value of a tiered approach.
                  One thing that I did not hear in this summary, which I had sent in a written comment to Dr. Davies, is the potential availability of data sources to help support the inclusion of additional pathways.
                  And for water, the EPA six-year review data set referenced in the draft screening policy is not something that they can use as a methodology for all water contaminants.  There's only a couple of regulated drinking water contaminants that are measured with the EPA six-year review.
                  So, I thought that if Agency staff could brainstorm a bit about other resources.  There's the UCMR data set.  There are potentially local or state-level water monitoring programs.  There are non-regulatory data sets from the U.S. Geological Survey and some other sources.  And so, I thought that casting a wider net for water data might be helpful, and I thought it might be helpful to discuss as a Committee if there's any other resources that come to mind that we can point EPA to now.
                  DR. DANIEL SCHLENK:  Great, thanks.  Dr. Johnson.
                  DR. MARK JOHNSON:  Yeah, when you think about maybe integrating other pathways as part of the conceptual site model that we talked about earlier, you can begin to think about this.  And Holly mentioned chemical/physical properties as parameters whether to look at certain pathways.  And so, for things that are unlikely to volatilize that do come out of the stack, then those things may be more important to look at wet and dry deposition to make it to ground water.
                  We also may want to think about affinity to organic carbon, right, and maybe octanol/water partition coefficients to make some generalizations regarding the affinity or probability for bioaccumulation.  I think, if the EPA consults some of the earlier guidance documents on incinerator permitting, a lot of these parameters are already there.  And so I would recommend that maybe TSCA go look at those documents and see what could be gleaned from them to kind of prioritize which chemicals and which pathways to look at given the chemical/physical properties.
                  DR. DANIEL SCHLENK:  Thank you.  Dr. Heiger-Bernays.
                  DR. WENDY HEIGER-BERNAYS:  Yes.  Dr. Davies, that was very, very comprehensive.  I have two comments.  Actually, one is the previous request from Dr. Johnson, I think, about additional sources for water information and data.
                  CCR [sic] actually went through this process many, many years ago.  I was on that committee, and we went through what are the data sources that are available, and I think that that is another possible -- another location to find some additional data other than UCMR data and the six-year review.
                  DR. HOLLY DAVIES:  Great.  Could I ask a quick question?  What is CCR?
                  DR. WENDY HEIGER-BERNAYS:  Oh, the Criteria Contaminants Rule.  So, I can send you the specifics and the year that process was revisited.  I'll get that information and put it into the record.
                  The other thing is this question does focus on additional pathways and sources that may be missing.  And I think that it is useful for us to provide as much specific as possible, and I do like an approach that's been proposed that could be used to determine which pathways are likely, I'll say, necessary.  And that wouldn't be the case for all of them.  And I'll just leave it at that, and I'll come back to this point in the next question.  Thank you.
                  DR. DANIEL SCHLENK:  Great.  Anyone else?  I know Dr. Kissel brought up several other components on earlier questions, so I don't know if you want to add anything more to this.  We just may move some of that information from Question 1, I believe it was, to this.  We talked about some of the other pathways.  John, do you have some other comments?
                  DR. JOHN KISSEL:  Yeah, so earlier I noted that the regional screening levels calculator that's online already has a soil to groundwater track in it.  The guidance document for that doesn't seem to be available as a standalone PDF.  You can read it online, but you can't download a copy of it, so it's not as accessible as it should be.  So, I don't know.  I haven't studied the assumptions that went into that pathway, but it's there and EPA has already done it.
                  I've also looked and there's all manner of regulatory implications of this, but we've had this problem all along is that the environmental regulation in the United States, especially at the federal level, is reactive rather than preemptive for the most part.  And TSCA's supposed to be different in that way.  That was part of the point of Lautenberg was that we would stop waiting until there was a mess.  We would try to incentivize not making a mess in the first place.
                  And in the RCRA world, way back when, when the transition was made from dumping waste willy-nilly to, we're going to do this professionally, a lot of businesses were given the opportunity to either shut down or to go forward as licensed hazardous waste handlers.  And that meant that they had to -- in order to take that next step, which meant they could generate a lot more revenue because all of the sudden the disposal cost per ton went up dramatically once things were specifically legally designated as hazardous waste, that meant that you could charge a lot more to get rid of those things.  And people that were getting rid of them haphazardly were subject to a great deal of financial distress potentially.
                  But there's a Corrective Actions Plan from 1994, so we're not talking recent history here.  And the 1994 Corrective Action Plan goes through a whole list of things that you want to assess at your facility if you're going to keep it operating.
                  So, to become a permanent hazardous waste handling facility, you had to do an inventory of things like spills, and among the pathways that are specifically highlighted are soil, gas, and groundwater.  So that's 1994.  And now we're here.  We're looking at this compartmentalization that if we clean up air, if we restrict air releases, then somehow, we've protected everybody when we know damn well from experience that that isn't true.
                  But currently, the regulatory process for legal businesses and groundwater is that you wait until there's a problem, and then you sue them, which is an extremely ugly and painful and expensive and inefficient process.  This is maybe beyond the scope of the beleaguered EPA employees that we're talking to, but TRI should include some manner of accounting for spills and discharges to groundwater.
                  They do have to account for discharges to waste handling facilities, but there is no inherent moral right to sit on a piece of property, load up the groundwater underneath it, and then walk away 50 years later having extracted profits and then left a big cleanup for the taxpayer to cover.  That's explicitly stated in the hazardous waste world through the RCRA Corrective Action Plan.
                  But, so far as I know there is nothing equivalent to that in the -- we're a normal chemical manufacturing facility and we have our permitting requirements and we have to report how much goes to the air and how much goes to the sewers.  But we don't have to report if we're doing casual dumping outside the back door of the facility, for instance.
                  The one famous example is Woburn, Massachusetts.  It was really just a warehouse.  It wasn't even a manufacturing facility, but they had a paint shop and they used solvents for cleaning and for degreasing.  And they had employees that were just basically walking out the back door with a quart or so at a time of solvent, and then they just pitched it out on the ground.  And over decades that wound up to be a groundwater plume.
                  They also did some shady disposal on the lot where somebody once -- they only admit to this once -- but there was a case in which an employee dug a trench with a backhoe, and they dumped six barrels of solvents into the trump, and then covered it up.  Well, many years later, that contamination reached wells G&H which became a Superfund site.  And somehow normal operating non-hazardous waste facilities have to be held to account because it's inefficient as hell for society to pay for the cleanup after the fact.
                  The ounce of prevention is worth a pound of cure rule still holds, and it holds, really obviously, in the hazardous waste world.  The evidence is overwhelming, and there should be no inherent right to just discharge the -- to load up the groundwater under your facility and then let people deal with it later.
                  Ignoring groundwater and soil gas given the history, which is just case, after case, after case in which groundwater and soil gas have been contaminated, we just need to raise our hand and say, okay, this is a tough nut to crack, but you've got to take a stab at it.
                  DR. DANIEL SCHLENK:  Okay.  Well, thanks for the comments.  You initiated four hands coming up straight away.  So, we'll go down the line.  Dr. Chaisson, you are next.
                  DR. CHRISTINE CHAISSON:  Thanks for that commentary, Dr. Kissel.  I think it's particularly important for in the discussion we're going to have in the next question, 4d, but I also wanted to point out that John's examples that he gave here, I think should be a matter of record, and also ones that he has given on previous days of the conversation because it is relevant to the very definition of what is fenceline community.
                  And, once again, going back to this idea about proximity, groundwater contamination is a direct consequence, as Dr. Kissel has pointed out in these examples and previous ones that he talked about, where the concentration and the consequence of that contamination could be far distant from the source.
                  And especially if it's redundant, and it accumulates someplace else, or the people who are suffering directly from that contamination might not be defined within an X amount of proximity to the source of the exposure.  So, I really would urge EPA to completely rethink the definition of fenceline so that it accurately encompasses, or let me say, that it thoroughly encompasses all of the points of damage, let's call it, that are consequential to the point of the emission.
                  So, thanks again for that, Dr. Kissel.
                  DR. DANIEL SCHLENK:  Dr. Heiger-Bernays.
                  DR. WENDY HEIGER-BERNAYS:  Yes, thank you.  Dr. Wendy Heiger-Bernays.  I have two points.  One is to support the discussion that has just been made and the data sources that are available that Dr. Kissel points out.  And also, to bring to the attention the 2016 Vapor Intrusions Screening Level calculator that EPA has made available.  There are great efforts that are going on right now on vapor intrusion that are tied directly to those releases that have been in discussion.  So, another source.
                  I also, for the record, stand corrected.  Maybe it's not enough caffeine, it was not CCR; it's CCL, which is why Dr. Davies probably had no idea.  It is the Contaminant Criteria List.  It was specifically CCL3, in which the data sources and information with regard to contaminants in drinking water could be accessed, and I'll provide that.  But I wanted to correct the record.  Thank you.
                  DR. DANIEL SCHLENK:  Yeah, I actually should've caught that myself.  The CCL3 through Office of Water, actually.  Yeah.  Dr. Blystone?
                  DR. SHERI BLYSTONE:  Yeah, as usual I want to correct the record at least a little bit that spills and excursions and related are required to be reported.  I can't answer for any facility that may be doing that illegally, but there are regulations in place.  We track everything on the site that I am currently working on for every time something escapes a piece of equipment, and if it's a reporting requirement, they get reported.
                  I also want to recognize that industry in general, and I'm sure it isn't static in time.  Things change over time, and things that maybe were common 30 years ago, may not be any longer and that should be recognized as well.
                  DR. DANIEL SCHLENK:  Thanks.  Look forward to reading the question.
                  DR. HOLLY DAVIES:  I have a quick question.
                  DR. DANIEL SCHLENK:  Hold on, please.  Actually, can we please just go on just a bit?  Yeah.  Just raise your hand.  That'd be great.  Thanks.  Yeah, I'll look forward to the -- obviously, there's some discussion both ways on this point.  So, yeah, if we can get that into the written record that would be very, very helpful.  Yeah.  Dr. Davies?
                  DR. HOLLY DAVIES:  Oh, thank you.  I just wanted to ask Dr. Blystone where those reports go to.  I think the earlier comment that I was taking notes on was about reports to the TRI and if those spill reports were to the TRI or to a different place?  Thank you for letting me ask that clarifying question.
                  DR. DANIEL SCHLENK:  Thanks.
                  DR. SHERI BLYSTONE:  You know, that's not my particular responsibility.  I believe it goes to an office in EPA.  I will clarify that and send it to you.
                  DR. DANIEL SCHLENK:  Okay, Dr. Ferry.
                  DR. JOHN FERRY:  Just sort of an interesting point to further justify adding groundwater in case we need further justification for that is two of our future targets for this process, tetrachloroethylene and carbon tetrachloride both in groundwater, undergo partial hydrogenation to make another one of the future products, trichloroethylene, and one of the one's we're talking about today, methylene chloride.  And I will send you, Dr. Davies, some references for that.  But just pointing out those can't be untangled.
                  DR. DANIEL SCHLENK:  Great, thank you.  Dr. Gribble?
                  DR. MATTHEW GRIBBLE:  Thank you.  This is a comment -- sorry, this is Matthew Gribble, temporary member of the SACC.  This is partially in response to 4b and also in response to 4c.  But coming to the issue of environmental justice and community awareness of the problems, for drinking water contaminants that can be odorless, tasteless, and colorless, communities may have no way of knowing there's a problem until kids start getting sick.
                  And I think that it's really important that we not treat humans as the canary in the coal mine for there being a pollution problem.  So, for contaminants that would have potential for harm and a limited plausibility of people being aware before they start getting sick, I think that might be something EPA, if they're considering a tiered approach, might consider kind of the visibility or lack thereof of the chemical as a consideration.
                  If it's a chemical that people would not easily be able to report to EPA that they were having an odor problem, for example, then that's something that EPA should be very attentive to when they're doing the screening assessment.
                  DR. DANIEL SCHLENK:  Thank you.  Dr. Reiss.
                  DR. RICK REISS:  Yeah, just dissent on the idea of including spills in this.  I think that's covered by a lot of other EPA programs.  And you talk about what's out in the groundwater, I mean, a lot of those originate from things that have been 50 years ago.  I mean, we still deal with litigation for contaminated sites with the spills.  Some serious spills have happened many, many years ago, and I just worry about this whole thing getting bogged down.
                  Considering a spill is different because with the air emissions you have an emissions number; there's uncertainty for sure about those numbers.  But for spills, you're going to have to make some supposition about what might happen, scenarios about accidental releases.  I just think it's ultimately EPA's policy call here, but I just don't think that that should be the focus of this.
                  DR. DANIEL SCHLENK:  Great.  Thanks for getting that on the record.  Dr. Unseld.
                  DR. MONICA UNSELD:  Yes.  I wanted to, I guess, support or thank Dr. Gribble for bringing up the point about not being able to taste or smell.  I have a question, and maybe this is just for the Agency.  I'm not sure.  And if we're looking for recommendations, should we already have something prepared to say this is a way to account for chemicals that are not visible, or is it okay that we flag that?  Because I do think that's a very important issue.  I am just not currently aware of a specific recommendation to give to the Agency.
                  DR. DANIEL SCHLENK:  Yeah.  This is Dan Schlenk.  I think as long as you -- I think they would appreciate as much information as you can provide in terms of if you have a recommendation to follow it up with information.  But we can go to them at the end, and they can make that comment themselves.  But it's been my approach, at least through the 30 some odd Panel meetings I've been on, that they would appreciate the recommendations as well as some information that would help them with that recommendation.  But I'll let them get there when we get to that point.
                  Dr. Reiss.  Your hand's still up.  Did you --
                  DR. RICK REISS:  Sorry, I'll take my hand down.
                  DR. DANIEL SCHLENK:  Oh, no worries.  Okay.  Anybody else want to weigh in on this one?  Okay, Dr. Davies -- oh, Dr. Kissel, you're back.  Go ahead.
                  DR. JOHN KISSEL:  Yeah, I just want to respond to the spills are the old days, and everyone can be trusted and nothing bad happens now argument, which is simply not true.  I taught hazardous waste management for 35 years and recently stopped.  This is the first year in 35 that I haven't taught a hazardous waste management course.  But there are the historical cases like Russell Bliss in Missouri spreading dioxin and oil all over the countryside to make a small profit for himself and make a huge problem for the larger society.  And I use that example in class.
                  But as recent as 2010 -- and it takes a little while for these cases to get through the judicial process, so we don't find out about them immediately.  So, if somebody is doing something illicit today, it's not going to show up in the newspapers for a little while.  So, I don't have absolutely current numbers, but when I last taught, I brought up a case of a waste hauler in Ohio, who at night, he was getting fracking waste.
                  There was a fracking boom, which meant his business was going up leaps and bounds.  And he found that the waste disposal wells were overscheduled, and so he was having a mass balance problem.  That stuff was coming in his front gate faster than he was able to dispose of it through legal wells.  And so, he just ran a line from his -- one of his storage tanks to the Mahoning River and dumped into the river at night when no one was paying attention.  And that was in the 2010s that that occurred.
                  So, the notion that everybody's above board now and we've learned our lesson and everything is swell is a nice fairy tale, but it isn't true.
                  DR. DANIEL SCHLENK:  Okay, thanks.  Dr. Reiss.
                  DR. RICK REISS:  Hi, so my comment certainly didn't mean to imply that everything is above board now.  I just think that from the standpoint of TSCA and fenceline monitoring or fenceline exposures, we've been in a situation where not a lot has gotten done for a long time.  And there's a frustration about getting more done with TSCA, getting more of these issues addressed.
                  It's just a reality in life that you have to focus on something, and I think focusing on the air exposures is a good thing.  Focusing on water exposure from direct discharges is a good thing.  I just think dealing with spills under this program is not the right way.  Again, you talk about these dumping scenarios.  I mean, you'd have to make some sort of scenario for intentional dumping to address that and I just think that's going to bog this whole process down.  I'd like to see it move forward.
                  DR. DANIEL SCHLENK:  Okie doke.  Dr. Davies.
                  DR. HOLLY DAVIES:  On the spills topic, in my experience, some chemicals and uses do have regular spills, whether they're called historical spills or not.  And I know in talking to all the people in Washington state that have PCB-containing electrical equipment, all of them, the first thing they said was, "It's an enclosed system."  And the second thing they said was, "We clean up all spills promptly."
                  So, I think there are sometimes, some chemicals where spills is an important pathway, and so I would argue for including it at least for consideration in the first tier.
                  DR. DANIEL SCHLENK:  Okay, so obviously have some lack of consensus on this issue.  So, look forward to seeing -- oh, Dr. Kissel, you have another comment.
                  DR. JOHN KISSEL:  Yeah, so I mentioned the RCRA Corrective Action Plans.  Among the things that the RCRA Corrective Action Plan requires is a groundwater survey.  So, you have to monitor your groundwater to continue to operate as a hazardous waste facility.  It seems to me that that is a strategy that, as a matter of doing business, if you have to report what's going out in your air and you have to report what you're discharging to a sewer, why don't you have to report what's leaving your facility through groundwater underneath your plant regardless of whether it's a current-day spill or an old spill?
                  This notion that we protect these communities that ultimately -- we're trying to do a screening tool here to protect people that live close to these facilities because there is a history of people who live close to facilities being victimized by higher levels of pollution than people that live further away.
                  And there's screening for one of the questions that I'm still kind of unclear on.  Maybe somebody addressed it, and I wasn't paying attention.  But so what does it mean to have screened these facilities for fenceline exposures if groundwater is excluded?  Have we checked the box?  If one of these chemicals passes this test today, which is based upon TRI releases, and we say they don't have a problem so this industry is clean, is there any requirement that at some point in the future -- Version 2 or whatever is coming up -- that groundwater is assessed?
                  Or are those industries that are cleared in this initial -- if we do the first or the second in ten chemicals or if it's the first 10 or first 20 or whatever it is, if they pass this muster or they pass this screen, are they then grandfathered in?  Or are they still subject to further evaluation, investigation at some future date?  And it's not clear to me what the follow-up here is.  I think it's misleading to say we found a screening and you've passed, and so you get a little star on your forehead and things are good.  I don't think the world works that way.
                  And Sheri mentioned spills.  Spills, you have to report spills of certain quantities if you are transporting material by truck or rail, and one of your railcars or your trucks overturns and there's a spill.  The kind of spill that I talked about at Woburn, which was the paint shop farm and walking out back and tossing a quart of solvent onto the ground, that doesn't have to be reported.
                  Fugitive emissions have to be estimated and reported, but I don't think liquid spills fall into the fugitive emissions world.  And so, I think there's lots of loopholes that are not adequately reported, and I'm concerned that we created a false sense of security if we say we screen for air emissions and the air emissions are okay.
                  The air is much better mixed than groundwater is, and so you get dilution much faster.  The epidemiology usually turns out to be kind of equivocal because epidemiology's such a weak took anyway.  Basically, it has extraordinarily high limits of detection.  And epidemiological studies around specific facilities are often a boon to the polluter because they tend to involve 200 people, and with 200 people you don't have power to find anything anyway.  And so, the epi study then announces that everything is swell when, in fact, everything is not swell.
                  And groundwater tends to be less well dispersed, and so people can get bigger doses.  The system just is protective of the lower threat and unprotective of the greater threat, and that's kind of failing the mission of TSCA.  Thanks.
                  DR. DANIEL SCHLENK:  Sure.  I'd like to wrap this up if we can.  Dr. Blystone, if you could -- again, there's obviously some lack of consensus here in terms of spills.  And I would say also that, Dr. Kissel, if you could provide the Agency -- I mean, it's pretty clear that groundwater should be evaluated.  If you could, again, provide the Agency with some concrete mechanisms to evaluate those smaller spills, I think that would be very useful to them as well.
                  But, Sheri, did you want to comment?  I saw you put your hand down.
                  DR. SHERI BLYSTONE:  Yeah, I'll just be very quick just to clarify.  Certainly, at facilities that I have worked at, there is a great deal of effort to contain spills.  That's why there's diking and all this stuff.  And, absolutely, if something makes it to the ground, that's a whole level of response different than what happens when it's in a dike.  So, spills to the ground, absolutely, are reviewed.  Things happen as a result of those types of spills.
                  Again, I can't answer for commercial operations, that sort of thing.  But absolutely, at the chemical manufacture side, spills to the ground are important.
                  DR. DANIEL SCHLENK:  Okay, so we've talked a lot about -- obviously, spills are important, and again, we definitely need to make that point known.  It's just a matter now of how the EPA actually deals with those spills, I think, is kind of what they're interested in.  In fact, I just got a message from Dr. Choudhary that he is interested in that.  Dr. Li?
                  DR. LI LI:  So, this is Li Li speaking.  So, I'm not making a comment, but I have a question.  So, does EPA have tools or models ready to perform like a site-specific evaluation for groundwater at this moment?  I mean, site-specific evaluation just like what they did for air and water exposure because they do the evaluation based on site-specific environmental data.  So, I'm not sure whether we have a model or tools that support such refining evaluation for each individual facilities or sites.
                  DR. DANIEL SCHLENK:  Okay, I guess we can ask Dr. Choudhary that question.
                  DR. REHAN CHOUDHARY:  Yes, good morning, everybody.  Rehan Choudhary from EPA.  So, your question is a pointed one and a relevant one.  We had methodologies for the air pathway and the water pathway to start things off.  And this is why, also, the project has been scoped the way it has as a starting point, Version 1.0.  There are other pathways for which we do not have established methods and approaches, and that is why we came to the SACC asking how we might address those data gaps.
                  So, I think that addresses your question.  We don't have readily available approaches for all these other pathways, but we would not be in a good position if we had readily available approaches and still did not include them in Version 1.0.  So, we have air.  We have the water that we presented to you.  We have gaps on the other pathways we're identifying.
                  DR. LI LI:  Okay, so that means, if you must do some evaluation for groundwater, you must rely on some generic approach instead of site-specific evaluations.  Right?
                  DR. REHAN CHOUDHARY:  Again, I think that depends on the recommendations the SACC Committee provides us.  If, in your written comments and even if you're in your verbal dialog, you're able to prescribe certain things the Agency can focus on, that would give us some focus to go evaluate, whether it's monitoring database, whether it's site-specific models, whether it's generic models.
                  DR. LI LI:  Okay.  Thanks.
                  DR. DANIEL SCHLENK:  Dr. Johnson.
                  DR. MARK JOHNSON:  Yeah, when we think about spills, I guess spills, to me, are accidents by definition, right?  And I think it's really important that we provide EPA with comments that'll be actionable.  It'll be usable for them to make a decision because that's why you do a risk assessment, to help you make a decision.  And so, I don't know what we're actually asking the EPA to do when we say consider spills.
                  Unless we have some empirical understanding of the frequency of spills and the volume and the nature to quantitate something, I don't know how you do it.  I really don't.  I think we need to provide them something more concrete if we're going to say, okay, we've got to look at spills.  I know states do.  I know our state does.  And then maybe handle different jurisdictions when those sorts of things happen.
                  But to be able to make the sort of decision I think that the EPA is trying to make in this case, I don't know how helpful it is to say, okay, we've got to consider spills, without some kind of empirical understanding of the frequency and the volume.
                  DR. DANIEL SCHLENK:  Okay.  Dr. Kissel.
                  DR. JOHN KISSEL:  Yeah.  As I pointed out, there is a method in the regional screening levels calculator.  I don't know the merits of it, but it exists for evaluating the soil to groundwater pathway.  So, it's not true that EPA has no method and has nothing to do there.  And also, within the air pathway, this current screening tool doesn't have the vapor to skin, and the consumer exposure model that EPA has already published has got that method in it.  And so, that method is available to EPA, and they could've used it, but they just chose not to.
                  With respect to prediction of spills, again there's some industrial/commercial specificity here.  The historical use of dry-cleaning solvents is that most dry-cleaning sites ultimately have a groundwater problem.  So, this is not some weird thing that, oh, gee, it only happens -- it's only been recorded in Oklahoma in 1953, and so we don't really need to worry about it.
                  It's basically if you have a dry-cleaning facility with underground storage tanks, those solvents are going to wind up in the ground, and that property is going to become contaminated commercial property and maybe a brownfield.  And its contamination may spread well beyond the surface limits of the actual property from which the activity's occurring.  And it's occurred with such frequency, in fact, it's routine for dry-cleaning establishments to leak.  So the notion that we couldn't possibly predict what might happen is, again, kind of a convenient excuse but just not in touch with reality.
                  I talked earlier about truck spills.  Insurance companies have a pretty good idea how often -- if you're running 500 trucks from your facility a day, an insurance company can tell you with a reasonable probability how many of those trucks are going to be in accidents.  And so, you can get a handle on that sort of stuff.
                  And for some types of spill releases, they occur with such frequency that, in fact, they can be quantified.  We could estimate.  We could require simply mass balances as part of the TRI reporting, which is, okay, we know how much is going out in the sewer, and we know how much is going out in the air.  How much was poured into the facility in the first place, and how much went out as commercial product.  And what's the difference?  What's the unaccounted-for portion?  And that would be a logical way to behave?  But humans are not good at logical behavior.  So, I don't know if we'll ever get there.
                  But there is missing mass all over the place, and that should be taken into account.  Sorry, but I taught this for 35 years and didn't see nearly as much progress in 35 years as I would like to see in 35 years, so I get all worked up.
                  DR. DANIEL SCHLENK:  Understandable.  I'll say it again.  If you can please make specific recommendations on, perhaps, mass balance calculations or those types of endpoints, which I think you've done in past SACCs.  But if you could provide that information again for the Agency specifically addressing the charge question of other sources, I think that would be very useful to them.  Dr. Heiger-Bernays.
                  DR. WENDY HEIGER-BERNAYS:  Yes.  So, I was going to wait until Question 4d, but I think that it's right to make this comment and then revisit specifics in 4d based on the discussion that we're having now.  Thinking about the discussion yesterday and specifically about Dr. Li's statements yesterday and for today about the need for a tool or a method that's capable of answering the important questions and yet is not so specific or site specific and so unwieldy that decisions can't be made, and in my brain, I'm thinking about really two categories of chemicals.
                  First, the ones we're dealing with here, the three even extended to the TSCA 20.  Those chemicals that are listed and well documented in lists that have been made available in the docket yesterday and today on hazardous waste, toxics dockets, releases to air and groundwater.  And the second is those chemicals for which there is less environmental release data or better yet those perhaps in the future that have not been omitted from the stacks yet.
                  So listening, or better yet, hearing fenceline communities is imperative, but I'm thinking specifically about two communities with whom my group works.  These folks live and work within what would be the AERMOD predicted zone described, yet their air, their groundwater, their surface water is contaminated by a single facility: one is in manufacturing, the other is a hazardous waste transfer facility.  And these facilities are not required to report all the stuff that's in their emissions.
                  And that gets me to the fact that the first category, those chemicals, those 20 for example, those solvents for which Dr. Kissel is referring that we've got data for the past 25 years if not 30, those real bad actors that we know about where the data are good, the emissions haven't continued to result in unacceptable health outcomes.  I don't mean even in a pejorative sense, but to workers themselves, let alone the fenceline communities.
                  So, for this category of chemicals, I think what we've been asked to think about is what's needed by us for EPA to move forward to risk management for these really bad actors.  And so, I wonder if -- I'll make the recommendation that maybe we have two sets of recommendations:  what's needed now to take action on these known bad actors and what's needed to develop or make the screening more comprehensive for those chemicals for which that first tier -- I'll say tier -- isn't met.  And thank you.
                  DR. DANIEL SCHLENK:  Thanks.  Again, specific comments on how would be much appreciated, I think.
                  DR. WENDY HEIGER-BERNAYS:  4d.
                  DR. DANIEL SCHLENK:  Okay, well we'll get to that one, I guess.  Dr. Cobb.
                  DR. GEORGE COBB:  Just briefly I'd like to echo what Dr. Kissel said, and that mass balance.  If you look back at our early review of these first ten chemicals, I made these same comments.  The masses that are unaccounted for are quite large in most cases and are the majority of the chemical under consideration in some cases.  So, I really think that's an essential aspect of trying to get a handle on this, and that's all I'll have to say.
                  DR. DANIEL SCHLENK:  Thanks, George.  Now we've made that comment several times if I recall.
                  Okay, at this point, let's take a break, actually.  It's been a very intense discussion.  Before I go back to the Agency to ask for questions of clarification, I think it'd be wise to take about a ten-minute break.  So, let's reconvene after -- say, 20 minutes after the hour if that'll be okay with everybody.  And we'll come back, and then I'll go to the Agency to ask for their questions or clarification.  Thanks.

                                    [BREAK]

                  DR. DANIEL SCHLENK:  Okay, at this point in time -- okay.  Dr. Gribble, did you have a last comment before we go to the Agency?  I saw your hand up.  Nope.  Okay.
                  DR. MATTHEW GRIBBLE:  This is just a logistical question, but will we be getting a copy of the closed caption provided to us at the end of this meeting?
                  DR. DANIEL SCHLENK:  It's accessible.  I think you just need to contact Alaa to get it.
                  DR. MATTHEW GRIBBLE:  Okay.  Cool.
                  DR. ALAA KAMEL:  Sure, if you go on the YouTube site also, you will have the recording of all this session, and it has closed captions.  But if you want a transcript of the closed captions, I guess, there is a way to get that.
                  DR. MATTHEW GRIBBLE:  Yeah, it automatically makes it.  I just wasn't sure who had it.
                  DR. DANIEL SCHLENK:  Yeah.
                  DR. CHRISTINE CHAISSON:  Alaa, could you send us the link just to make sure we can get that?
                  DR. ALAA KAMEL:  Sure.
                  DR. CHRISTINE CHAISSON:  Thank you for that.
                  DR. DANIEL SCHLENK:  Okay, so let's go ahead and get started.  Reconvene.  Unless anyone has any more comments, we'll go to the Agency.  We've had a bit of time to deliberate in terms of questions or clarification for the Committee.  You've heard quite a bit of discussion about certain new pathways.  Do you have any particular specific questions or clarification?
                  DR. REHAN CHOUDHARY:  Yes, good morning.  This is Rehan Choudhary from the EPA.  I believe during the deliberations, someone has posed a question that they wanted to ask us.  And I think, Dr. Schlenk, you had suggested what your understanding was, would the Agency appreciate specific prescriptions on how to proceed?  And in that line, we've listened to the deliberations.
                  We noticed in the last 20 minutes that there was more of a focus on how.  To the extent the Committee members can prescribe generic nationwide kind of approaches that our program can implement because our focus is nationwide and not very site specific, that would be helpful to us.
                  And when identifying very program or site-specific methodologies or models in your prescriptions and how you're highlighting them in the written record, it will be helpful to us to understand how that program-specific or site-specific could be extended and integrated into the Version 1.0 we've communicated to you.
                  So, I think that's the big takeaway; that we have a Version 1.0 framework.  What pathways we can include is one aspect of it.  Then how to incorporate them into that Version 1.0 is another aspect to help us operationalize it.
                  DR. DANIEL SCHLENK:  Great.  Dr. Davies, well, everybody, I guess all the leads for Question 4, it seems this is kind of a consistent theme for all subcomponents of Question 4.  If we can, again, use that as our focusing component in the minutes, that, I think, would be very useful.
                  Okay.  Let's go ahead and move forward with our last question.  If we can get that up on the screen, and, Dr. Choudhary, if you could read that into the record, that'd be great.

CHARGE QUESTION 4D

                  DR. REHAN CHOUDHARY:  Yes, good afternoon.  Rehan Choudhary from the EPA.  Charge Question 4, subpart d to the SACC Committee:  "Please propose and describe approaches that EPA can take into consideration for the purposes of expanding the capacity of the proposed screening methodology, Version 1.0, presented in this work.  Some possible examples may include, but are not limited to, subpart d, how the proposed screening level approach may be expanded to evaluate exposures relevant to tribes, indigenous populations, subsistent lifestyles, cultural practices, and other unique circumstances."
                  DR. DANIEL SCHLENK:  Great.  The lead discussant on this is Dr. Chaisson.
                  DR. CHRISTINE CHAISSON:  Thank you.  I'm going to read this summation, and many of the parts of this refer back to previous discussions.  If I've missed any, please make sure to chime in.
                  First of all, "EPA is to be commended for its policy and actions focused to protection of millions of Americans in all 50 states, D.C., and all U.S. territories whose lifestyles and living conditions create unique opportunities for exposure to toxic chemicals.
                  "Dr. Freedhoff pointedly acknowledged this goal in her address, Tuesday, to this Committee.  It's remarkable and appreciated that EPA architects of the fenceline screening tool have invited guidance, as articulated in Question 4d, so they can make Dr. Freedhoff's aspirational goals a reality, at least, for this EPA tool.
                  "Question 4d is well fashioned, recognizing that tribal communities are iconic to the challenge at hand, but not alone in needing attention for constructing appropriate exposure and risk paradigms.  The issue extends to a broad swath of living conditions and lifestyles such as ethnically defined communities, other indigenous communities, border communities, non-tribal communities relying on subsistence practices, et cetera, which place them or their foods, their air, their water, at the fenceline.
                  "Assuring the screening process and tool embraces the realities of this will require some additional features," which we'll talk about.  "It is more important than ever to assure that these exposure and risk paradigms are as inclusive as possible.  Over the past two days, there have been repeated discussions for the need for a broader scope of exposure sources in this model.  Perhaps that's the issue of greatest consensus so far, and it is the critical issue for inclusion of people living in unique communities.
                  "This is summarized in the letter from the National Tribal Toxics Councils with examples and illustrations of exposure factor values representative of tribal communities but significantly differing from those assumed for the general U.S. population.
                  "I will note there are much more data available, some of which developed with EPA funding, to inform the fenceline screen algorithms and are available presently from NTTC; some from even NRDC, and several other sources.
                  "Many of those have been provided to EPA during comments on individual chemical assessments, and some are available from other sources.  Surely, those can be accrued, and we can briefly illustrate the issues about exposure opportunities relevant to the fenceline community.  I'd like to show four slides to summarize this."  Great.
                  This is just sort of an overview of the kinds of things that happen at fenceline communities, or the kinds of communities that we've talked about, including tribal.  For most of these communities, the diet is both commercial and traditional.  The blending of those two, however, infer very different possibilities of the sources of the things that are eaten, which is the point here for this kind of thing.
                  Even where commercial diets are, quote, the thing that all of us buy in the store, frequently their sources for some of these commercial items are far more restricted than one would assume, meaning that if there is a contamination anywhere in that process or in the waters that are used to also make the finished product before eating it, that can be contaminated.  And it's a durable contamination because frequently we have the source be the same time after time.
                  That also includes traditional diets, which we'll talk about more in a moment.  And even thinking about this in a broader sense, this includes home gardens, community gardens, et cetera, that may be in contaminated soil or irrigated with contaminated water.  In addition, many of these communities, whether they're tribal per se or ethnically defined, have traditional therapies which are taken from the environment.
                  Their occupational and family role are frequently blended.  Children participate in the occupations.  Some of the classic examples of this are the skill sets and the use of environmental sources where the whole family can be gathering and learning how to do these kinds of things.  So, it's not the idea of you go off to an office when you're 21 years old, et cetera.  These occupational exposures start right at very, very young ages.
                  Arts and crafts, the same thing, and frequently, this is home-based.  This is becoming more integrated into our quote general population thinking as our much, much more of our day-to-day activities begin to be home centered.  And so, I think that some of the lessons learned here will become more and more applicable to quote general population thinking, and this screening tool is a good place to start that.
                  Can we go to the next slide?  The same could be said, by the way, about homeschooling.
                  This is just an illustration that I've frequently used in classes I've taught to just illustrate many of the component parts which make the potential for contaminant to reach the consumer in the quote general population as it is virtually hard-wired into the dietary exposure software that's used not only by EPA but FDA and most globally, which starts with farm gate or port.
                  The odds that, for example, if you buy grapes today or citrus today and then you return to your store a month later to buy think of the same thing, the source of that, it may be coming from a completely different country or whatever.  Nonetheless, that is all taken into account in considering the probability of contamination as well as the potential levels for those.
                  What it means to you as a consumer is that in the commercial world, there's far less possibility that your exposure is durable time, after time, after time, because your source is not durable.  That's not true on the right-hand side.  If you're in a community which is harvesting its food, storing it, and your seasonal source for that food is the same moose or the same whale or the same fish or whatever that you harvested at a certain point, if that's contaminated, you're going to be seeing a repetition of exposure day after day.
                  Obviously, the kinds of foods that are going to be eaten are very different, and I'll show you more detail about things like that.
                  Processing industries.  The processing factors are well known and utilized so that as you go from an orange to orange juice or as you go from wheat to Cheerios, we know what the effect of that processing is on the contaminants that might be in there.
                  That is not well applied to indigenous foods or community foods or, for that matter, the foods coming in from your home gardens, community gardens, or other environmental sources of foods.  Seasonality is a very big deal with subsistence living, not so much you.  You expect to get oranges 12 months a year.  The foods that are eaten here, the dietary profiles of people change dramatically with seasonality and the economics of supplementing their subsistence foods with the commercial foods.
                  So, you have very different profile of exposure, a significant profile of exposure for these kinds of communities which more and more include non-tribal communities, as I said, that really need to be -- or it's critical because many of these people, because of the economics that's implied in fenceline communities, will be at the front, if you will.
                  Next slide.  This is just a screenshot of the kinds of foods.  It is no more appropriate to say, to represent the diet of a tribal community by saying, let's look at fish than it would be for the commercial regular general population to say, well, we'll just look at beef.  The diets that could contain particularly water-borne or airborne contaminants are dramatic, and it has something to do also with not just where the people are, but where their foods went.
                  So, for example, these are just a listing from the sub-arctic data set, a very extensive data set about the kinds of foods that are eaten and the amounts eaten at different ages.  And these are foods that are eaten as part of a normal diet in the sub-arctic freshwater communities.  They are beaver, deer, moose, muskrat.  Now maybe you and I don't eat all this stuff, but I assure you they do.  Sea mammals are broken down, and there are different parts of these animals are preferentially served to different age groups within the community in keeping with, not just their traditions, but their nutritional needs.
                  And it's also true for those things that are highlighted in the darker blue.  Those are expanded just like sea mammals are or game mammals in this illustration.  These kinds of data in great detail -- and by the way, peer reviewed by outstanding groups of professionals and community members, including the people who distribute these kinds of foods -- have been developed with EPA funding and are freely available and being used certainly in those communities and in research groups.
                  The data sets, as well as the tools that read the data sets, can be supplied to this group at EPA.  And just like using other kinds of assessment tools that they have already depended on, I suggest that they take a look at this and be able to at least use these data.  Next slide.
                  This is also true for activity profiles that are non-dietary.  This is just a picture of what's called sweat lodges.  This is very much like the steam baths that we go to in the city at the clubs.  There's water poured over hot -- in this case -- stones to create a very humid and hot condition inside.  Well water's being used.  Surface water is being used here.  You've got incredible conditions for whole-body exposures, increased uptake.  Obviously, inhalation and oral exposure.  They're drinking the water as well as pouring it over.
                  There aren't many swimming pools in these communities, but there are a lot of these.  And if we can publicly talk about exposure sources, I think it would be necessary to include realistic exposure sources such as these, where literally thousands of people across the country have this kind.  And it's directly, I think, applicable to the same issue in the general population.  So, thank you for that help.  Let's go back.
                  I'm done with the slides.  "A brief listing of the issues raised by our Committee, our discussant group actually, will be expanded and organized after the discussion today.  Our discussants joined the previous frequent Committee opinions including concern that diet must be included along with cultural work in other sources.
                  "Routes of exposure.  Routes, not just sources of exposure, consequential to the sources of contaminants should include important routes such as below for which much information has already been supplied to EPA by NTDC, individual tribes, and others.  And these can likely be collected again to assist this development team.
                  "One, hand to mouth exposures, which are age dependent and culturally dependent."  It has something to do with cultural practices of, do you put your kids on the floor?  We have incorporated work like this in looking at the risks to fire retardants in carpeting, where children are obviously going to get exposed because they're crawling around on it a lot less than the adults that are walking across it, especially with shoes on.
                  "It should include, number two, dermal, and oral, and inhalation exposure consequential to deposition from air to dust."  This may be particularly important for vast areas of the U.S. in the southwest and the west because these contaminations are taken into the household.
                  "Whole body exposures by recreation and work in surface waters and use of water in bathing and steam baths such as in the pictures I've already shown."  This is not just a cultural practice; this is hygienic practices frequently in these communities.
                  "Regarding aggregate, also there's been consensus on the need for aggregate and cumulative exposure opportunities at least in acknowledging these exist, especially considering people who live and work in the affected area, or who take their food from the affected areas.
                  "There's been concern raised in our committee, in our discussant group, including over the last two days in the definition of the zone to be considered.  This is particularly important for rural areas where the contaminant source may be distant from areas suffering from the accrued contamination or where food services near the fenceline are harvested distant from there."  The deer don't stay put; they certainly migrate, and they may be captured after they've been contaminated.
                  "The definition of fenceline; perhaps the concept should include communities with higher than national averages that expressed health problems and are subject to exposure sources suspected to originate from pollution sources of interest for this screen.
                  "There's also been quite a bit of discussion and apparent consensus is where there are inadequate understandings of the exposure opportunity in terms of how it affects these unique communities where special data on key factors in the exposure calculation, a safety factor could be considered until such time that the information is available and formally recalculated using it.
                  "The use of the safety factors where the understanding of exposure or missing data are evident."  For example, I picked up Dr. Gribble's comments in Question 3 regarding chemicals hard to note by the public, "Odorless, tasteless, and colorless in groundwater and potentially very dangerous to vulnerable populations or the application to the population of wide safety factors where evidence of community health problems, which could be related to chemical exposures and the non-chemical underlying health disparity issues."
                  "Next, the screening procedure should include processes whereby" -- now, this is not speaking to the mechanics of the screening.  Here I'm talking about pairing use of the screen with the required process.  "EPA could explicitly reach out to unique communities, especially those who have already made their interest known such as the NNTC, other tribal/indigenous groups, for information and assurance that its information will be applied.
                  "Establishing a pre-calculation" or before the screening tool is taken out of its case, "problem formulation step and practice -- a required practice -- required to accrue needed information and definition of the exposure opportunity scenarios to be considered.
                  "Number three, establish policies for acceptable use of information for a screen as different from the formalized risk assessments on which regulatory decisions are made require that tribal and other community profiles are included."
                  Next, "Consideration of accidental and/or durable emissions now not considered in the screen and presentation of the events include representation of emission spikes and repeated events."  Dr. Kissel might be able to help me define that a tad better than that.  It's a little clumsy.  "For unique communities, it's especially important to include pathways such as land disposal and groundwater contamination."  This comment was similar and supported by discussions on Question 4c.  Likewise, dust and water contamination from the air should be included."
                  It's unclear to me if there's consensus, but there were several discussions previously and have been raised again in this discussion.  "Number one, consideration of non-chemical stressors for the screen and how specifically would that work.
                  Number two, "If Version 1.0 is indeed utilized now, without the expansions and where no problem comes out the answer, how would these amendments that would be included in the future be revisited on those decisions?"  Once you get a clean bill of health as an industry, you just walk away and put that in your pocket from a limited version, Version 1?  And along with that, what would be the message?  Utilizing Version 1, what message would you be sending to these tribal communities as to the worthiness, if you will, of their perspective in any screen that is used for EPA for this?
                  Deciding there is, quote, no issue or no risk is, in fact, a regulatory decision because revisiting that after such an edict is made by EPA will be legally complicated.  Some Committee members also have added the additional items I'm going to list here, which may be points for further discussion now, and I invite the people who have brought these up to elaborate after I'm done, the effect of climate change.
                  Number two, "To include the products database, CPDat, into this process, into the screen.  To consider the disposal of personal care products that may contaminate groundwater and land.  While these chemicals may not fall under TSCA, they may have an impact as they mix with chemicals that do fall under TSCA, including this would route all methodology to a daily reality of fenceline communities."  I'll invite the person who sent that in to elaborate and explain.
                  Next, "The need for a way to handle chemicals for which there are little data about emissions and contamination is evident but hard to link to the emission source."  This point was initiated in 4c by Dr. Heiger-Bernays.  "The need for practical ways to use information and practical ways for communities and community advisors to participate."  This also was a common theme on other charge questions.
                  And, finally, "The need for quick action now for the bad actors."  This was brought up as a discussion initiated in 4c by Dr. Li and Dr. Heiger-Bernays, and I would welcome their comments and extension on those thoughts.  If I've missed any points from the discussions or for others interested in this, please add to the record.  I'm going to try to keep a list of people participating in the discussion to follow and make sure that, when I write this summary up, that I'll try to send it to you.  Thank you.
                  DR. DANIEL SCHLENK:  Thank you, Dr. Chaisson.  Okay, next on the list are our associate discussants.  And that will be Dr. Calder.
                  DR. RYAN CALDER:  Hi, thank you, Christine, for summarizing.  My apologies for not sending you this comment for you to aggregate in the global discussion, but I'll just read it into the record now.  "I just wanted to suggest that to the extent that the EPA's engagement with indigenous populations communicates risk associated with traditional activities and especially traditional diets, that could be either explicitly in terms of the output from risks screening model or even implicitly in terms of targeted data collection."
                  EPA should be mindful about the possibility for reduced intake of traditional foods or other loss of traditional lifestyles to lead to net health harms even if you're avoiding contaminate exposure.  Given the food insecurity in indigenous populations, the loss of nutritional sufficiency can have serious adverse effects and that needs to be considered much, in my opinion, quite strongly alongside the benefits of reduced chemical intake, which given the uncertainties in this model might be quite speculative.  So that's just qualitative consideration to keep in mind.  Thank you.
                  DR. CHRISTINE CHAISSON:  Just for clarification, Dr. Calder, are you concerned that inclusion of the consideration or announcement that you are including that would deter consumption of those foods.  Is that what you're saying?
                  DR. DANIEL SCHLENK:  That was Dr. Chaisson.
                  DR. RYAN CALDER:  Right, yeah.  Ryan Calder, again.  Yeah, I'm concerned about risk perception among indigenous populations leading to reduced intake of traditional foods.  And then the alternatives to those traditional foods can be much worse for overall health given the alternatives in indigenous populations.
                  DR. DANIEL SCHLENK:  Please state your name, Chris, please each time when you do that.
                  DR. CHRISTINE CHAISSON:  Oh, I'm sorry.  I apologize.  That's hard for me to remember.  This is Christine Chaisson.  I'm not sure.  I mean, I understand you're talking about caution, but could you expand that to give guidance here on -- I'm not sure what you're advising them -- not to reveal it, or how would that be?
                  DR. RYAN CALDER:  Well, when, for instance, information is related to indigenous populations about risks of exposure to chemical contaminants, so that should be paired with guidance, for instance, on how best to respond.  We can't say, don't eat this fish, or don't eat this or that because that might lead to -- depending on the level of risk from chemical exposures, that might not be health-protective advice.
                  And so, I would say that risk communication should be paired with advice that is likely to lead to positive health outcomes.  Like from the indigenous diet -- their traditional diet -- should they eat instead.  Positive messaging around how to maintain nutritional sufficiency without -- while also minimizing exposure to contaminants.
                  DR. CHRISTINE CHAISSON:  This is Dr. Chaisson, again.  Dr. Calder, would you mind writing that up in the context of how it should be applied to the screen?
                  DR. RYAN CALDER:  Yep.
                  DR. CHRISTINE CHAISSON:  Okay, so that I'll include your comments, but I want to make sure that they're articulated correctly.
                  DR. RYAN CALDER:  Okay.  I'll send you an email.
                  DR. CHRISTINE CHAISSON:  Thank you.
                  DR. RYAN CALDER:  Okay, thank you.
                  DR. DANIEL SCHLENK:  Okay, thanks.  Next on the list is Dr. Unseld.
                  DR. MONICA UNSELD:  Yes, this is Monica Unseld.  Thank you for that summary.  I was the one who made the comment about the disposal of personal care products, and that was really in relation to the fact that the screening, at least in the methodology presented, was used to determine that a chemical was not a reasonable risk -- or an unreasonable risk, sorry.
                  We know in a lot of these communities that are disproportionately impacted, they have a lot of dollar stores, and there's research that shows that these products in the dollar stores tend to have higher levels of toxic chemical contamination than what you may find in a Target or Walmart, which already has personal care products that have chemicals of concern.  And I'm just worried that, if they mix with a chemical under TSCA and we've used the methodology to say it's not a risk, what if there's a synergistic effect that's going to knock this into the potential risk category?
                  And also for Dr. Calder, maybe an asset framework may help you get your ideas together.  So any time, like, I call them doomsday talks where I'm just telling people all the toxic chemicals that they're exposed to, I always try to lead them with something they can do about it.  And sometimes that something can be as simple as, share this on social media or that the EPA needs to provide more education on how -- other recipes or something.  But an asset-framing concept may help you gather your thoughts.  And that's all.
                  DR. DANIEL SCHLENK:  Great.  Okay, our next associate is Dr. Gribble.
                  DR. MATTHEW GRIBBLE:  Great.  So, first I'd like to respond to some of the previous discussion between Dr. Calder and then Dr. Chaisson, and then I'd like to read into the record my prepared comment.
                  So, I fully appreciate Dr. Calder's point that communicating risks and benefits and affirming traditional lifeways can be challenging in environmental health.  And that the EPA, as an authority, entering into dialog with communities about the risk of fugitive emissions and the potential harm to their local seafood, for example, might be a stimulus for anxiety in the community.
                  But I think there's a difference between the question of what advice you give an individual consumer about which fish or which parts of the seal are safer to harvest, versus conversation with the polluter about, this is an acceptable threshold or not for you to be discharging into the environment.
                  And so, I think individual behavioral decisions might be outside the scope of what the screening tool is seeking to do, and I think that, as long as the communication with the local community were managed in a way that it was clear that this is not providing individual dietary guidance, it might be less of an issue.  But, Dr. Calder, later please elaborate on your thoughts.
                  What I wanted to note in my comment was that I thought that seafood was a very notable omission.  Seafood is a class of subsistence diet, and I include in that also shellfish, different contaminants of different bioaccumulation/biomagnification properties.  Different game species may have different migration patterns.
                  So, for example, Pacific Northwest and Southeast Alaska communities relying on subsistent shellfish harvest might have different contaminants that are of greater concern than communities that are relying on migratory hunted species, for example.  And like Dr. Chaisson was saying, I think we need a place-based approach to what is the emissions profile from the site and then what are the things happening with people around the site.
                  I think having a blanket approach will be challenging and that having an approach that allows for site-specific considerations will be very valuable for EPA.  And I think that those considerations should include social norms of what people's practices are in a local setting.  And the other thing which came up briefly in 4b, is this idea that whether or not a community is engaged in the water body should be viewed in a holistic, potentially counterfactual way of would they engage if they had greater trust that the water body weren't polluted?
                  I really don't think we should be excluding communities who have chosen to rely on a bottled water supply or on something like that because they're worried about their surface or groundwater being contaminated as a drinking water source.  To me, those are fenceline communities for the pollution entering that water body that they are not partaking of because of their concerns.
                  So, I think some consideration of but/for causation -- for thinking about would they be involved with the water body but for the pollution -- might be something EPA could take into consideration as they consider locally tailored guidance on what a safe level or not of discharge might be for a local community.  I'll stop.
                  DR. DANIEL SCHLENK:  Okay.  Thank you, Dr. Gribble.  Dr. Blystone, your hand is up.
                  DR. SHERI BLYSTONE:  Yeah, I just wanted to react to something that Dr. Unseld said about synergistic effects.  I am, by no means, up to date on the science of that but I know that's a really complex issue, and I would be interested if there are specifics that Dr. Unseld has that could be practically applied in the screening approach.  It's aggregate and accumulative exposures are already very complex and now synergistic.  I don't even know that we're close to have something that would be practical to apply.
                  DR. DANIEL SCHLENK:  Yeah, thanks.  Dr. Unseld?
                  DR. MONICA UNSELD:  Monica Unseld.  To answer your question, I do not have specifics because I am not aware of any methodology that's currently available, but it doesn't mean it's not there.  I just don't know of it.  But my concern was that, if we're going to prematurely, perhaps, classify a chemical as not a risk, that that could be potentially hazardous to public health.
                  And then, lastly, I just wanted to state for the record, if we are going to engage environmental justice communities, disproportionately impacted communities, the Agency really needs to take a look at the language.  Referring to people as receptors is not very welcoming.  And also, I know reality is there will be risk, but we must realize that when we're engaging with these communities if we talk about reasonable risk, that's someone's loved one.
                  So, I just want to get on the record that the EPA should consider this as they look for ways to further engage with these communities.
                  DR. DANIEL SCHLENK:  Dr. Heiger-Bernays.
                  DR. WENDY HEIGER-BERNAYS:  Yes, Dr. Heiger-Bernays.  I want to respond to some of the comments that have suggested that under this screening program -- or a screening program -- that EPA would or might make recommendations to modify people's behaviors.  It's my understanding that what we've been asked to look at is what should we be considering or recommend for considering in a screening assessment?
                  And so, these are all really great points, but I think the objective here is to identify what's bad and not to necessarily go that additional step.  The other thing I believe is that this is a national assessment.  Right, and so the challenges to make sure that the data, the inputs, in the screen reflect national considerations.
                  And we know that there are plenty of fenceline communities across this country.  They have different characteristics and what's the best way to reflect those characteristics and to provide that kind of specific information to the Agency.  Thank you.
                  DR. DANIEL SCHLENK:  Thanks.  Dr. Johnson.
                  DR. MARK JOHNSON:  Just a couple suggestions.  I know one was to mention food/wet transfer and, as I mentioned before in some of the guidance of the Clean Air Act folks have for incinerator permitting, what they do is they use a log Kow of 3.5 as sort of a cutoff to begin to look at free web transfers by magnification, by accumulation for organics.  So that's just one suggestion.  It doesn't work so well for metals, but it does work fairly well with organics.
                  They also consider persistence, of course as well, so any housing inorganic would be potentially treated differently but also would conform to that log Kow 3.5 rule.
                  Regarding synergies of potentiation, it doesn't happen all that often, but it does happen.  And it happens on a kinetic basis, happens on a dynamic basis.  And sometimes some new approach methods such as adverse outcome pathways may help inform that.
                  And the only other suggestion I have is for safety factors.  I'm not opposed to using safety factors.  I think it's a good idea.  I just think they should have some sort of empirical basis.  I am sensitive to the comment of compounding conservatism.  I understand this is a screen, but we need to be able to support them scientifically.  And that's all I have, thanks.
                  DR. CHRISTINE CHAISSON:  This is Chris Chaisson.  Dr. Johnson, would you mind sending me a paragraph to include about your cutoff limits.  I wasn't able to capture those all in my notes.
                  DR. MARK JOHNSON:  Sure, will do.
                  DR. CHRISTINE CHAISSON:  Thank you.
                  DR. DANIEL SCHLENK:  Okay.  Any other comments from the Committee?  Dr. Apte?
                  DR. UDAYAN APTE:  Yeah, I just wanted to bring up the issue of double exposure that I think I brought up a little and was mentioned a couple of times later in the discussion as well, where a lot of the fenceline communities, the people will work in the same factory or facility where they might get an occupational exposure and they will have a second dose -- so to speak -- at their homes or park or whatever they are doing later.
                  And so, I know that in this 1.0 version that has not been addressed, and EPA commented on that.  But we should strongly encourage to look at that as they go forward modifying this as something they could put it on their to-do list for the future, which would probably improve the risk assessment a lot.
                  DR. DANIEL SCHLENK:  Thank you.  Any other comments?  Okay.  Just to summarize it, it appears that, yeah, there's a fine line between a screening conceptual model and a risk assessment.  Conceptual model in trying to put those two together, yeah, might be a bit difficult.  Dr. Gribble, yes.
                  DR. MATTHEW GRIBBLE:  This is Dr. Gribble, temporary member of the SAAC.  I also just wanted to briefly raise the question of whether the Clean Water Act section 303D was of impaired water bodies versus unimpaired water bodies.  Total maximum daily loads allowed to be discharged into a water body would be pertinent for the screening level approach as we're trying to figure out cumulative impacts on communities that are fenceline.
                  Some of these impaired water bodies may already be flagged, and so adding to an already impaired water body or one that is kind of on the border might be important for the cumulative exposure the community faces potentially to chemicals of a similar mode of action.
                  DR. DANIEL SCHLENK:  Thanks.
                  DR. CHRISTINE CHAISSON:  Dr. Gribble, this is Chris Chaisson, again.  Would you please send me that reference, so I include it correctly?
                  DR. MATTHEW GRIBBLE:  It's in the paragraph I sent you before.
                  DR. CHRISTINE CHAISSON:  Oh, the same one.  Thank you.
                  DR. DANIEL SCHLENK:  Again, I'll just reiterate anything specific databases that can be provided to the Agency in terms of how to assess communities would be very, very useful, I think.  Any other -- Dr. Li?
                  DR. LI LI:  This is Li Li speaking.  So, in terms of the culture for bioaccumulation of food chain bio-transfer, so I can also provide some database for you.  So, I can send you the literature.
                  DR. DANIEL SCHLENK:  Okay.  I just got a comment from one of our EPA staff.  Just to comment at comments on other statutory authorities and what they may or may not authorize to do, you need to be careful with those comments.  Primarily just reference other potential relevant statues and avoid interpretation in your minutes.  Okay, Bill.  Dr. Doucette.
                  DR. WILLIAM DOUCETTE:  This is Bill Doucette.  Just to follow up on Dr. Johnson's comment about the optional water partition coefficient cutoff log 3.5 for bioaccumulative things, I think that using physical-chemical properties to try to better understand potential routes of exposure and what chemicals are likely to be important through food pathways and things are important.
                  But we need to be a little bit careful.  For example, all the perfluorinated compounds we didn't think were going to bioaccumulate, they have log Kows lower than the cutoff and yet they show up.  So, they can be used to guide initial decisions, but we have to be aware of the numerous exceptions that are out there.
                  DR. DANIEL SCHLENK:  Yeah, good point, Bill.  The PFAS ones are definitely out there on their own, for sure.  Dr. Davies.
                  DR. HOLLY DAVIES:  Yeah, just jumping on that, there's a lot of different lists of possible PBT chemicals: Health Canada's list versus Environment Canada versus EPA's list.  And there's a lot of different cut-offs.  I think this is where EPA would be looking at the chemicals specifically and what we know about its characteristics in fate and transport.
                  DR. DANIEL SCHLENK:  Okay.  Any other comments for 4d?  Dr. Li.
                  DR. LI LI:  I have one more comment.  The use of cutoff, I don't think cutoff can prioritize the exposure pathway.  For example, it won't tell you which one is important because we have many, many exceptions.  But it can use to deprioritize.  For example, it can tell you which one is not likely to be important.  So maybe I think this way is more appropriately used of the cutoffs in chemical-like screening.  That's it.
                  DR. DANIEL SCHLENK:  Okay, it will be interesting to see how that's written up, but thanks for the comments.
                  DR. CHRISTINE CHAISSON:  This is Dr. Chaisson.  Once again any of the comments about the cutoffs, I would appreciate a brief email so that I don't misrepresent your points in the summary.
                  DR. DANIEL SCHLENK:  Okay.  Any other comments?  Okay, at this point I guess this concludes sort of our comments to the questions.  I guess, as we've alluded to throughout -- well, first, let's go to the Agency to see if they have any questions or clarification on 4d.
                  DR. CHRISTINE CHAISSON:  Dr. Schlenk, before we go to that, I had one more comment.  If you don't mind, I'd like to put it in the record.
                  DR. DANIEL SCHLENK:  Sure.
                  DR. CHRISTINE CHAISSON:  This is a comment about the discussion that was raised previously by EPA and then I think also by Dr. Heiger-Bernays.  I wanted some clarification on this.  The issue is about including factors or considerations -- let me broaden that -- to considerations which apply to a national assessment.  EPA in its work with tribal communities has already acknowledged -- as well as states like Alaska even -- that particularly for diet and people's activities, their diet and activities obviously put them in direct relationships with their environment which creates the opportunities for exposure.
                  But that these are going to be regional, and that is why the dietary profiles for the southeast U.S. don't look anything like the ones I showed you in the screen capture for one section of Alaska.  In fact, the dieticians in the Department of Health in Alaska as well as the entire communities of indigenous populations there have recognized Alaska to fall into five distinctly different subgroups as it has to do with both their diet, their sources of food, and their activity patterns.
                  So, I think these need to be acknowledged, and that doesn't mean that isn't nationally represented.  But it's simply creating different population subgroups who have distinctly different opportunities for exposure.  We do exactly the same thing when we utilize the huge databases about nutrition and dietary sources or consumption of different forms, even, of the foods that are being consumed.
                  The national databases are divided up, if you will, to their applicability to different regional parts of the country or of the territories, and they are applied separately.  So, I don't really see any difference between that normal assessment practice that is very traditional within EPA and FDA and every other regulatory authority I know of that considers people's activities and diets.  The data and the underlying profiles that are to be considered would also be regionalized.
                  So, we don't have to assume that anybody in the northeast consumes beluga or whale meat or anything like that, but we must consider that to be representative of Alaska that they're eating this.  So, it's got to be not just statistically correct and have a good pedigree or whatever, it, once again, needs to be, I believe, relevant to the issue.  This is particularly, acutely necessary when you're looking at the kinds of communities that are likely to be at the fenceline, however we define it.
                  DR. DANIEL SCHLENK:  Okay.  Dr. Heiger-Bernays.
                  DR. WENDY HEIGER-BERNAYS:  Yes.  Wendy Heiger-Bernays.  Thank you.  And to Dr. Chaisson, for the record, I was not in any way making this statement that these should not be considered.  I made the statement in light of the charge questions that have been posed.  So, absolutely.  And for a screening assessment, one might say that in this region this is the driver, right?
                  DR. CHRISTINE CHAISSON:  Right.
                  DR. WENDY HEIGER-BERNAYS:  So for the record, again, not stating that it should not be considered, that it should not be included.  Those data are imperative, but how those data get used need to be.
                  We need, I think, to provide some recommendation.
                  DR. CHRISTINE CHAISSON:  Right.  This is Chris Chaisson, again.  Dr. Heiger-Bernays, I know that's what you meant because I know your work.  But I wanted to make sure it wasn't misunderstood by anybody hearing your comment.
                  DR. WENDY HEIGER-BERNAYS:  Thank you.
                  DR. DANIEL SCHLENK:  Yeah.  This is Dan Schlenk.  I think, again, it goes to the point where you need to decide a generic component for the screening or more of a site-specific component for the screening because, obviously, there's different components in that conceptual model for exposure.  So, recommendations, I think, need to be made for those components qualitatively initially.  And then, again, I think as much quantitative information that you can provide.
                  Dr. Chaisson, you mentioned those five subgroupings.  I think it would be really good to get the source of those demarcations if you can as a reference to the Agency, for sure. You certainly can.
                  DR. CHRISTINE CHAISSON:  This is Chris Chaisson, again.  Dr. Schlenk, we have extensive -- I'll provide to you the entire datasets, the background on these, the peer review, and the tools that read them, basically, in multiple formats.
                  DR. DANIEL SCHLENK:  Sure.
                  DR. CHRISTINE CHAISSON:  So, I will package that up and make sure that that is available to EPA as well as the record.
                  DR. DANIEL SCHLENK:  Sure.  I think if those tools can be utilized for other communities, I think that would be very, very useful.  As you mentioned, there's so much difference.  So however they came to that decision of demarcating those five zones, if that same toolset can be utilized in some other parts of the country, that would be fantastic.
                  DR. CHRISTINE CHAISSON:  This is Dr. Chaisson again.  As part of that, we have the same kind of information for tribal communities in the southwest, ethnically defined communities along the border, et cetera.  I will make sure that all of this is transported to this team as well as this Committee.
                  DR. DANIEL SCHLENK:  Yeah, the more tools, the better, I think in that regard.
                  DR. CHRISTINE CHAISSON:  This is Dr. Chaisson, again.  Just as a matter for the record, all of this information and the tools are freely and openly available to anyone who requests it, period.
                  DR. DANIEL SCHLENK:  Great.  Any other comments before we conclude this question?  Dr. Gribble?
                  DR. MATTHEW GRIBBLE:  This is a little out of date but just something I noticed that I wanted to make sure was on the record.  This actually comes back to Question 1.  Sorry, it's a little out of order.
                  I noticed there was a typo on the definition of fenceline communities, "Specific distance measured form a receiving water body."  It should be, "From a receiving water body."  You might be totally changing it in the EPA text, but I thought the EPA should be aware there's a repeated typo of what the definition is of the water source.  Yeah, just FYI.
                  DR. DANIEL SCHLENK:  Okay, thank you very much.  Any other comments?  I apologize if you're hearing the demolition going across the street from my house here.  It's a little bit annoying.  Okay, if we're good with 4d, at this point let's go to Dr. Choudhary to see if he has any questions or clarification.
                  DR. REHAN CHOUDHARY:  Good afternoon.  Rehan Choudhary from the EPA.  No, there are no further clarifications on 4d from our side.
                  DR. DANIEL SCHLENK:  Okay, great.  At this point, a couple members of the Committee mentioned a couple additional comments that don't necessarily fit the questions provided.  And at this point, we can discuss those.  I think, Bill, you had mentioned something either yesterday or the day before.  I forget which day it was, but is there something you would -- a question that should've been asked, so to speak, and want to provide some comments there?
                  DR. WILLIAM DOUCETTE:  Dan, I think this is the appropriate spot since we're pretty much out of time.  I guess it was back to the more fundamental question and how this whole process is organized around the charge questions and the redundancy that results from the way the charge questions are worded.  And it's getting difficult because in Question 1 we talked about uncertainty, sensitivity analysis and that kept getting brought up throughout all the questions.
                  And I'm wondering if somehow if it just should be a more fundamental question; is the proposed screening level approach truly useful given the limitations and release estimates and the lack of corroborating monitoring data?  And that would be a very general sort of thing that all our comments could be focused on instead of trying to pigeonhole them into a specific charge question.  It's a frustration for me.  It's been this way for the last ten SACC meetings with the charge questions.
                  It's, again, almost like a leading question, and I think somehow -- and the way people review you can see this because of the redundancy.  People don't necessarily look at the charge question or try to look at the charge question, but really it overlaps the whole document.  And it's just a frustration for me, and I don't know if anybody else feels that way.  But I'd just like to throw that out there for future meetings since we're going to be doing this again.
                  DR. DANIEL SCHLENK:  Sure.  Again, if you could write up your comments and put them out there, it gives the Committee a chance to agree or to not respond at least at that point.
                  DR. WILLIAM DOUCETTE:  Dan, where would that go?
                  DR. DANIEL SCHLENK:  At the end.
                  DR. WILLIAM DOUCETTE:  At the end?
                  DR. DANIEL SCHLENK:  Yeah.  But send it as a separate to Alaa --
                  DR. WILLIAM DOUCETTE:  Who would be the lead on that?
                  DR. DANIEL SCHLENK:  You would.
                  DR. WILLIAM DOUCETTE:  Pardon me?
                  DR. DANIEL SCHLENK:  You would.  Send your written comments --
                  DR. WILLIAM DOUCETTE:  I would send that directly --
                  DR. DANIEL SCHLENK:  To Alaa, yes, as if you were a lead discussant.  Right.
                  DR. WILLIAM DOUCETTE:  Okay.  All right.  Thank you.
                  DR. DANIEL SCHLENK:  Yeah, sure.  Dr. Unseld.
                  DR. MONICA UNSELD:  Yes.  I just wanted to support Bill's comment and to add that as someone who's doing this for the first time, it's a bit surprising to hear from, not only more experienced SACC members, but the public that suggestions and recommendations have not been implemented, even on the process of the charge questions.
                  And so, I would lift that up to say, like, what is the utility of this entire process?  What's the best use of all of the brainpower that has gathered here?  What's the best use of the community's time?  Because I'm also not convinced that we gave the Agency what it needed because the charge questions were not very precise or concise in what they were looking for.  So, I can type that up and send that in.
                  DR. DANIEL SCHLENK:  Great.  Dr. Chaisson.
                  DR. CHRISTINE CHAISSON:  This is Dr. Chaisson.  Dr. Schlenk, is there a process by which, after the charge questions are specifically summarized and written up, that somehow we could reconvene to form sort of an overall listing of where there's great commonality or issues that just came up over and over again so that the importance of that could be emphasized and also, to make it maybe easier for the public to understand what we're trying to say?
                  DR. DANIEL SCHLENK:  We'll discuss that at the conclusion of this meeting, so stay on the line.
                  DR. CHRISTINE CHAISSON:  Okay.  Thank you.
                  DR. DANIEL SCHLENK:  The logistics of the report writing will be discussed at that point.
                  DR. CHRISTINE CHAISSON:  Thank you.
                  DR. DANIEL SCHLENK:  Yeah.  Dr. Johnson.
                  DR. MARK JOHNSON:  Yeah, I just want to agree with Monica and Bill.  And I seem to remember at one SACC meeting, we had an opportunity to review the charge questions before they went final, and maybe that's a good solution.  Maybe we can get a shot of actually corresponding and asking exactly what you want because what we want to do is be helpful.  At least, I do.  And so, maybe if we had an opportunity to review the charge questions beforehand and provide the input back to the EPA, they can consider our comments and adjust them accordingly.
                  DR. DANIEL SCHLENK:  Okay.  You do receive the charge questions before the meeting, though.  So, if you're asking for a more formal process, I guess, in terms of responding to them, that's something, I guess, we could put forward.
                  DR. MARK JOHNSON:  Yeah, we got the questions, but we weren't asked to provide any input back on them.  So I didn't, but I could've.  I could've said I could see a storm coming and if you adjust this way or something like that.
                  DR. DANIEL SCHLENK:  Sure.
                  DR. MARK JOHNSON:  It's a process question, really, or suggestion.
                  DR. DANIEL SCHLENK:  Yeah, I understand.  Yeah.  Bill, back to you.
                  DR. WILLIAM DOUCETTE:  Yeah, I didn't mean to imply that, for those that weren't involved in previous SACC meetings, the EPA doesn't listen to our comments or doesn't respond.  I didn't mean that at all.  We've always had an opportunity to respond or ask clarification for the charge questions.  My suggestion was eliminating the charge questions to a single more general review question rather than having us try to focus in specific areas because we obviously are trained.
                  Most reviewers just go through from the top of the document to the bottom of the document and make our comments, and we tend to focus on the areas that we're familiar with.  That's why we have such a wonderfully diverse background in the Panel.  So I didn't mean to imply that EPA is not responsive at all; I just meant that I think there might be a better way to deal with this in terms of that question.
                  DR. DANIEL SCHLENK:  Sure.  I think making that recommendation is totally appropriate at that point.  Sheela?
                  DR. SHEELA SATHYANARAYANA:  Yeah, I just wanted to agree with Dr. Doucette, Dr. Unseld, and Dr. Johnson about the charge questions.  We have, in the past, met as a group to discuss the charge questions, and they were modified after the discussion to reflect the conversation.  And so, it would be great if we could do that in the future.
                  The only thing I wanted to add is that there is a lot of richness in terms of meeting in person.  And many times in the past meetings, the side conversations that we've had have really improved our responses and our ability to provide EPA with the information that they need and to help them.  And in this setting, it's really hard to do, and it's also hard to be virtual and attentive for like eight hours in a row.  So, I just wanted to make the plug for that.
                  I know that these are extenuating circumstances and there's a pandemic, but in the future, it would be great if we could meet in person.
                  DR. DANIEL SCHLENK:  Okay, thanks.  Dr. Cobb.
                  DR. GEORGE COBB:  Just very briefly.  I'd kind of like to come to the Agency's defense a little bit here.  This entire meeting that we're having is directly in response to comments of the SACC to the Agency as we were reviewing the first ten.  So, they are doing their best to be responsive and I appreciate that, and I'll be quiet.
                  DR. DANIEL SCHLENK:  Thanks, George.  Dr. Li.
                  DR. LI LI:  So, this is Li Li speaking.  So, we just had some email communication with Dr. Heiger-Bernays.  So, we realized that we need to take the last few minutes to emphasize the importance of the tiered screen approach used for this.  So, I can have some thoughts, and Dr. Heiger-Bernays can add if you want.  So, because we really find it important to hammer this home, so basically, we may take the tiered approach.
                  So, the first approach is to identify what exposure pathway or what exposure sources are most important.  We can do this by either screening the chemical properties or by considering the routes of exposure to a specific population, to a specific group of people.  And if we identify the most important exposure pathway or exposure source, then we can perform more refined assessments, specifically to these exposure routes.
                  And we can go back.  For example, we can go back to the air/water pathway, and we can also consider the groundwater.  Or we can also consider some exposure pathway specific to some indigenous people, to some tribes, to some specific groups of people.  So maybe this is something we can pursue.  Yeah.
                  DR. DANIEL SCHLENK:  Dr. Heiger-Bernays.
                  DR. WENDY HEIGER-BERNAYS:  Yes, thank you, Dr. Li.  I know that this is in the context of -- I'll say it like this, that we've got three compound chemicals that have been examined now.  They're really bad actors.  Their data are very good.  The current screen that was proposed to us shows, with all of its challenges that members have raised, that these chemicals --and, again, I'll repeat -- even in the occupational setting alone, are ripe for regulatory decision.
                  And I would propose that a tiered approach could be taken such that the -- I'll call it the -- more robust, or maybe that's the wrong -- more sophisticated inclusionary screening tool that would include multiple additional pathways could be in the sort of the second round or the second step if there is evidence that the risk is truly unacceptable -- and I'll put this in air quotes -- decisions are made that these chemicals need to be dealt with.  They meet some regulatory threshold and enough study of those has been done and then we can move onto those chemicals or those chemicals for which there is a question as to whether that screening was actually sufficient.
                  DR. DANIEL SCHLENK:  Okay.  Yeah, just reading through the charge questions, I think both of those comments would probably fit into one or three of the charge questions, the way that the charge questions written.  So, if you want to propose a tiered approach, I think you can recommend that and write that up in those particular charge questions if you like.  I think those would be appropriate.  Dr. Chaisson.
                  DR. CHRISTINE CHAISSON:  Yeah.  This is Dr. Chaisson.  Dr. Heiger-Bernays, I would urge you to write out what you just put out so that it's formally introduced in those terms.
                  The issue sort of generically about how tiered approaches really work across the Agency or any other group doing it is my understanding of it may be a little different than you presented, Dr. Li.  So maybe you could clarify this.
                  When tiered approaches that I work with are employed, the first cut is usually all-encompassing, and you can't, as you tier down, you don't add to it.  So, you don't bring in 15 more routes of exposure in Tier 2 or Tier 3; you're just refining the screen that you included in Tier 1.
                  The application, however, as Dr. Heiger-Bernays is pointing out, is almost like a triage.  It's not really a tiered approach.  It's sort of a triaging.  Let's take the critically important ones off the top of the pile and deal with it, which is a slightly different way of using what could be considered an incomplete tool but certainly has the capacity to triage for those critical and obvious situations.
                  So, I would caution against accepting as applicable a tool that's not encompassing hoping that, oh, you'll catch the stuff later on downstream because it won't happen.
                  And there will be legal challenges to that kind of thing.  I can just see that whole issue coming up that, well, we weren't caught in the screen; don't throw us in now.
                  There's a third consideration to this, specifically for the charge question that I was responsible for.  These underserved communities have been ignored repeatedly throughout the history of all regulatory communities be it they federal, state, international, or whatever.  To do that again now and set this thing out there in clear -- if you will -- non-inclusion, I think sends a really terrible message to the entire regulatory community and challenges the very charge that the assistant administrator made perfectly clear in her opening remarks.
                  Personally, I think that at this stage of the game, particularly for this moment in time with this administration, this is where it's going to happen.  It's not going to happen possibly later on.  It certainly didn't happen ever before, and once again, I think that there's a moral obligation to make explicitly the inclusion of unique communities that are most likely to be the ones affected for the purpose of this screening tool explicit and included before it's ever used.  And that's just my personal, obviously very strong, opinion about a mistake that I'd like to see EPA avoid making here.