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 

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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