OWOSSO GRAPHIC ARTS 

EPA DELISTING PETITION 

Addendum 06/27i08 

WASTE WATER TREATMENT SLUDGE FROM 

CHEMICAL ETCHING OF MAGNESIUM 

1. Additional samples of the petitioned waste were collected 

In addition to the sampling conducted and documented in the petition submitted May 2, 2005, six 

additional grab samples were collected for volatile organic constituents to satisfy the requirement for 

grab samples in lieu of composite samples. 

The following is a summary of the samples collected since the time of the petition submittal in May, 

2005. Samples were collected by either Donald. Spitler or Terri Zick. Qualifications of each sampler 

are provided in the petition dated May 2, 2005. Samples were analyzed at Fibertec Environmental 

Services (Fibertec), a NELAC certified laboratory. Contact information for the laboratory is as follows: 

Fibertec Environmental Services 

1914 Holloway Drive 

Holt, MI 4951 2 

Telephone: (517) 699-0345 

Contact: Daryl Strandbergh 

Title: Laboratory Director 

Table 1: Sample Collection Summary 

Sample Sample Sample Purpose 

ID Date T • e of Sample Sampler Laborato 

22670 4/3/07 Cormposite CIS D. S • itler Fibertec 

22671 4/3/07 Composite CN D. Spitler Fibertec 

22676 4/3/07 Corn • osite CN D. Spitler Fibertec 

26187-001 11/15/07 Grab VOCs 1.110103/11 Fibertec 

26187-002 11/15/07 Grab VOCs T. Zick Fibertec 

26I87-003 11/15/07 Grab VOCs T. Zick Fibertec 

28162-001 4/11/08 Grab VOCs T. Zick Fibertec 

28358-001 4/22/08 Grab VOCs T. Zick Fibertec 

28653-001 5/7/08 Grab VOCs T. Zick Fibertec 

Table 2: Physical description of samples at time of collection 

Sample ID Sample color Sample odor Other Description 

22670 Off-White Mild Dense Solid 

22671 Off-White Mild Dense Solid 

22676 Off-White Mild Dense Solid 

26187-001 Off-White Mild Dense Solid 

26187-002 Off-White Mild Dense Solid 

26187-003 Off-White Mild Dense Solid 

28162-001 Off-White Mild Dense Solid 

28358-001 Off-White Mild Dense Solid 

28653-001 Off-White Mild Dense Solid 
Table 3: Summary of grab samples collected and compositing details 

Sample ID Iamitne Compositing Date/Time Other Comments 

22670 4/3/07 4/3/07 CN only 

22671 4/3/07 4/3/07 CN only 

22676 4/3/07 4/3/07 CN only 

26187-001 11/15/07 N/A Grab 

26187-002 11/15/07 N/A Grab 

26187-003 11/15/07 N/A Grab 

28162-001 4/11/08 N/A Grab 

28358-001 4/22/08 N/A Grab 

28653-001 5/7/08 N/A Grab 

Table 4: Sample Volume and Preservation Methods 

Sample Collection Grab # Grabs per Sampling Field 

ID Point volume Sample Method Preservation 

22670 Filter press plate 100 g Hand-held None 

Hand-held 22671 Filter press plate 100 g None 

scoo 

22676 Filter press plate 100 g 3 Hand-held None 

scoop 

26187-001 Filter press plate 100 g NM Hand-held None 

scoop 

26187-002 Filter press plate 100 g 1 Hand-held None 

scoo 

Hand-held 26187-003 Filter press plate 100 g None 

scoop 

28162-001 Filter press plate 10.3 g Ma Syringe 10 ml Methanol 

28358-001 Filter press plate 10.0 g 1 Syringe 10 ml 

Methanol 

Met ml 10 28653-001 Filter press plate 10.1 g 11111 Syringe Methanol 

Table 5: Conditions at time of Sampling 

Sample Weather Facility Conditions Other Processes Trip Blank 

ID Conditions Affectin • Sample in Sampling Area Collected 

Sample collected None Materials Handling No 22670 indoors & TCE storage 

Sample collected None Materials Handling No 

22671 indoors & TCE storage 
Sample collected None Materials Handling No 22676 indoors & TCE storage _ 

26187-001 Sample collected None Materials Handling Yes 

......___ 

indoors & TCE storage 

Sample collected None Materials Handling Yes 26187-002 indoors & TCE storage 

Sample collected None Materials Handling Yes 26187-003 indoors & TCE storage 

Sample collected None Light construction, Yes. 28162-001 indoors Materials handlin. 

Sample collected None Materials Handing Yes 28358-001 indoors (cardboard) 

Sample collected None Materials Handling Yes 28653-001 indoors (cardboard) 

2.. Description of sampling devices, decontamination procedures and use of disposable 

devices for sample collection 

Samples were collected using disposable or equipment or non-disposable equipment that was 

used for a single sampling event. 

a. Samples 22670, 22671 and 22676 were collected by Owosso Graphic Arts staff using the 

laboratory prepared, unpreserved sample container as the sampling. device. The excess 

filter cake was cleaned from the exterior of the container and threads of the jar prior to 

closure. The samples were shipped in a cooler under chain of custody to the laboratory 

under chain of custody. 

b. Samples 26187-001 through 003 were collected by CTI staff using the laboratory prepared, 

unpreserved sample container as the sampling device. CTI staff utilized new nitrite gloves 

during sample collection and handling. The excess filter cake was cleaned from the 

exterior of the container and threads of the jar prior to closure. The samples were firmly 

sealed and placed in a chilled cooler with a trip blank and transported by CTI staff under 

chain of custody to the laboratory. 

c. Samples 28162-001, 28358-001 and 28653-001 were collected by CTI staff using methanol 

field preservation techniques as outlined in guidance prepared by the Michigan Department 

of Environmental Quality (Attachment xx). CTI staff utilized new nitrite gloves during 

sample collection and handling. The grab sample for each sampling event was collected 

with a laboratory cleaned and prepared 20cc syringe. 

a. The tare weight of the syringe was measured prior to sample collection. 

b. The syringe was pressed into the filter cake material to load a sufficient amount of 

waste into the syringe. 

c. The total weight of the syringe containing sample of the filter cake was measured. 

d. Excess filter cake was removed from the syringe by gently depressing the plunger 

until the net sample weight was approximately 10.0 grams. (Actual ne sample 

weights ranged from 10.0 to 10.3 grams and was withnge of variability 

recommended by the MDEQ) 

e. The measured sample amount was gently, placed into a laboratory prepared voa 

container containing 10 ml of methanol preservative. 

f. The sample and preservative were gently mixed by rolling the sealed voa container 

until thehandling was adequately mixed with the preservative. 

g. Samples were placed in a chilled cooler and transported under chain of custody to 

the laboratory by CTI staff. 
3. Description of the quality control procedures and documentation system used to track 

sample location and maintain sample integrity during transportation to the laboratory. 

a. Samples 22670, 22671 and 22676 were collected by Owosso Graphic Arts staff. Samples 

were documented using a chain of custody and shipped via overnight courier service. 

Samples were received and checked in by lab staff. Documentation of sample receipt was 

returned to Owosso Graphic Arts with the sample results 

b. Samples 28162-001, 28358-001 and 28653-001 were collected and packaged by CTI staff 

and documented' using a chain of custody. The samples were transported to the laboratory 

conducting the analysis by the sampler. Samples were hand delivered and custody 

relinquished to laboratory staff. The fully executed chain of custody was provided to CTI 

staff upon transfer of the samples. 

4. Third Party Data Assessment 

As requested by Todd Ramaly and Christopher Lambesis during a telephone conference on June 17, 

2008, a third party assessment was conducted for laboratory data submitted in conjunction with the 

initial delisting petition and its amendments. The evaluation was conducted by personnel familiar with 

laboratory analytical methods, protocols and Quality Assurance procedures. A summary of the 

assessment has been prepared and provided under separate cover. 

5. Signed Certification Statement 

I certify under penalty of law that I have personally examined and am familiar with the information 

submitted in this demonstration and all attached documents, and that, based on my inquiry of those 

individuals immediately responsible for getting the information, I believe that the submitted 

information is true, accurate and complete. I am aware that there are significant penalties for sending 

false information_ including the possibility of fine and imprisonment_