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 
TIMELINE 
January 13, 2009 

Conference Call with EPA to 

discuss final details of Petition 

September 14, 2007 Process at OGA request 

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 may 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