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 SolidTable 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 scoop

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

10 Met ml 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_