### response to inquiry about 8/27/97 data Terri Zick to: Christopher Lambesis, Todd Ramaly 03/09/2009 04:26 PM Cc: Kathy Wilson From: To: Cc: Terri Zick <tzick@cticompanies.com >

Christopher Lambesis/R5/USEPA/US@EPA, Todd Ramaly/R5/USEPA/US@EPA Kathy Wilson <kathywilson@owossographic.com >

GentlemenAttached, please find the discussion of the lab data about which you contacted me (8/27/97 As/Ba data). Based on our discussion, this appears to be the last of the questions regarding the petition, and we look forward to moving ahead with the delisting language. Please contact me if other issues arise. Thank you Terri Zick 313-300-7401 cell tzick@cticompanies.com

The information contained in this electronic message is privileged and/or confidential information intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of the communication is neither allowed nor intended. If you have received this communication in error, please immediately notify us by return e-mail or by calling 800-CTI-TODAY and delete the message. Thank You!March 9, 2009

Mr. Christopher Lambesis Environmental Protection Agency; Region 5 77 West Jackson Blvd Mail Code LR-8J Chicago, IL 60604-3590
Re: Response to U.S. EPA Comments on Detected Levels of Arsenic and Barium; Owosso Graphic Arts, Owosso, Michigan Dear Mr. Lambesis,. Based on our recent conversation, this letter is written to address your questions regarding the detected levels of Arsenic and Barium during the August 27, 1997 sampling of wastewater treatment filter cake at Owosso Graphic Arts, Owosso, MI. The samples obtained from 2004 through the most current sampling event were collected using procedures suitable to satisfy the rigorous requirements of the delisting process, documented with appropriate Chain of. Custody (COC), and include suitable Quality Assurance / Quality Control (QA/QC) documentation. Prior to that time, sampling was conducted only as a means of gross characterization. The specific sample to which you referred was analyzed at a laboratory which is no longer is in operation, and for which the COC and QA/QC information is not available. The data for all parameters from this data set, including Arsenic and Barium must be considered informational only, as the data cannot be substantiated using accepted industry standards. In the absence of adequate QA/QC data, an evaluation of the reliability of the results from the 8/27/97 sample cannot be 

### conducted. A statistical assessment of the data collected from 1997 through the most recent samples collected as a part of the delisting process indicates that the 8/27/97 data for Arsenic is a statistical outlier (see attached graphs). Based on these facts, we reiterate that this data is useful as an historic detail only, and is not a suitable or representative data point for the purpose of the delisting petition. Conversely, the metals data obtained from samples collected from 2004 to the present, however, are relatively stable and are considered to be representative of the waste included in the petition. Please let us know if you have any additional questions or concerns regarding this information. Sincerely,

Terri Zick. Director of Compliance Services Cc: Kathy Wilson; Owosso Graphic Arts

Geotechnical, Environmental & Construction Materials Engineers

www.cti-assoc.com

### Arsenic outlier identification - first pass

### Arsenic outlier identification - second pass