### CTI and Associates, Inc.

12482 Emerson Drive Brighton, MI 48116 248.486.5100 248.486.5050 Fax



### October 19, 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 Request for Additional Information Owosso Graphic Arts, Owosso, MI

Dear Mr. Lambesis,
Pursuant to your request, CTI and Associates, Inc. (CTI) has prepared the attached timeline which highlights the critical developments throughout the delisting process since submittal of the original delisting petition on May 2, 2005. Transition from the aqueous Hydro-coat Hot Developer to N-Methyl Pyrrolidone (NMP) occurred on September 15, 2008. As you are aware from our correspondence dated March 31, 2009 (attached for reference), the NMP replaces the aqueous developer/degreaser which was initially selected in December, 2007 to replace Trichloroethylene (TCE) which was used prior to that time.
No other process changes related to generation of the waste proposed for delisting have occurred at the facility. Do not hesitate to contact me at any time should questions arise regarding this submittal.
Sincerely, CTI and Associates, Inc.

Terri Zick Director of Compliance Services

Cc: Ms. Kathy Wilson, Owosso Graphic Arts

Civil, Geotechnical, Environmental & Construction Materials Engineers www.cticompanies.com

## TIMELINEJanuary 13, 2009 Conference Call with EPA to discuss final details of Petition Process at OGA request September 14, 2007 Initial EPA Comments received on 5/2/06 Delisting petition

October 19, 2009 Timeline summary of transition to NMP based developer provided to EPA December 31, 2008 Text version of 7/29/08 QA/QC summary submitted per EPA

request July 29, 2008 Additional lab QA/QC summary submitted in response to EPA request November 15, 2007 Addendum #1 submitted to EPA addressing EPA comments on petition September 15, 2008 degreaser replaced with pyrrolidone as alternative developer

EPA requests 3 additional VOC samples
April m ay 7, 2008

June 27, Addendum.#3 submitted to 

### EPA results of additional VOC requested by EPA

• March 9, 2009 Correspondence detailing occurrence of Arsenic/Barium in 8/27/97 sample submitted in response to EPA request

March 20, 2009 EPA requests details on elimination of TCE
March 31, 2009 Correspondence detailing TCE elimination and NMP usage submitted to EPA

September 22, 2009 EPA requests timeline summary of transition to NMP based developer 0 mess Changes Since Transition to NMP Developer



## 1 November, 2007 Trials of aqueous degreasers conducted

December 20, 2007 Transition to aqueous degreaser complete & remaining TCE removed from

site April 10, 2008 EPA con site visit of. OGA

ancillary TCE system r from site January 24, 2008 Addendum #2 submitted to EPA documenting TCE removal and transition to aqueous degreaser Timeline of Benchmark Delisting Petition Activities

Owosso Graphic Arts

## CORRESPONDENCE MARCH 31, 2009 (w/o attachments)12482 Emerson Drive Brighton, Ml 48116 248.486.5100 248.486.5050 Fax



### March 31, 2009
Mr. Christopher Lambesis Environmental Protection Agency Region 5 77 West Jackson Blvd. Mail Code LR-8J Chicago. IL, 60604-3590

Re: Discussion of TCE Replacement with Alternate Solution; Owosso Graphic Arts, Owosso, MI
Dear Mr. Lambesis,
At the time of the initial submittal of the petition to delist the wastewater treatment sludge generated at Owosso Graphic Arts (OGA), the process generating the sludge included a cleaning step prior to etching that was conducted using Trichloroethylene (TCE). As part of OGA's demonstrated history of environmental stewardship, its staff has actively sought lower toxicity alternatives to numerous process chemicals over the years. Replacement of TCE with an aqueous product had been considered even prior to the original' petition, however, trials of alternatives available at the time failed' to meet their strict quality expectations.
In November, 2007, Owosso conducted trials using an aqueous product designed to replace TCE in the process, and shortly thereafter began the transition to the aqueous based material. By December 20, 2007 the transition was complete and the remaining TCE was removed from the site for disposal. Since that time, the process has further evolved based on performance of the aqueous developer. Over time, the aqueous material did not yield the results that OGA required for long-term use of the material and they selected an alternate developer (n-methyl-pyrrolidone) and implemented a new process which is currently in use.
Magnesium plates which are to be etched in the system are developed using the material described in the attached Material Safety Data Sheet (MSDS). Once the developer has reacted with the coating on the top of the magnesium sheet, it is washed in sinks which are directly connected to the sanitary sewer. The plates are further heated over an open flameuntil the coating is set prior to being placed in one of the etching machines. Residue from the developing process is not expected to remain on the sheets after washing and heating, and the development process occurs without any direct connection to the etching process (ie. no piping or other mechanical means of transferring developer to the etching system exists).
In the letter to the EPA dated 1/24/08, Owosso graphic Arts staff also confirmed that the remaining unused and spent TCE had been removed from the premises. A copy of the waste 

### manifest documenting the removal of the remaining material was provided as an attachment to that letter detailing the removal of the chlorinated solvent from the site. While not specifically stated in the 1/24/08 letter, it should be noted that the tank and piping previously used in the TCE

Civil, Geotechnical, Environmental & Construction Materials Engineers

www,cticompanies.com

### degreasing process was also removed from the premises. No functional means of using TCE for

this purpose remains at the facility. While some residual TCE has been detected in the system (as discussed in our 1/24/08 letter) since termination of its use, no TCE has been introduced to the system since December 20, 2007.
Should you have additional questions, please do not hesitate to contact me at 313-300-7401.
Sincerely CTI and Associates, Inc.

Terri Zick Director of Compliance Services

Cc: Kathy Wilson Jake Gadd