To: Judy Kleiman/R5/USEPA/US@EPA cc: Donald Spitler <dspitler@owossographic.com >, cbuiocchi@owossographic.com , cellenberg@owossographic.com , jhvoight@owossographic.com , jholden@owossographic.com , kathywilson@owossographic.com Subject: Analytical Plan for delisting at Owosso Graphic Arts Terri Zick <tzick@cti-assoc.com > 04/01/04 11:03 AM

Ms. KleimanI would like to give you advanced notice that you will be receiving a proposed analytical plan for an upcoming delisting petition of a F006 waste stream at Owosso Graphic Arts, Owosso, MI via Federal Express on April 2, 2004. The analytical plan has been prepared in response to a telephone conversation between you and I in which you indicated that analytical approaches are being evaluated on a case-by-case basis until EPA de-listing guidance has been updated. We look forward to speaking with you regarding this plan and the petition. Please do not hesitate to contact me at any time with questions regarding the package. Thank you Terri Zick, CHMM CTI & Associates, Inc. 12482 Emerson Drive Brighton, MI 48116 248-486-5090 x 232 313-300-7401CTI and Associates, Inc. 12482 Emerson Drive; Brighton, MI 48116 Tel: 248.486.5100 Fax: 248.486.5050


## LETTER OF TRANSMITTAL

Date: April 1, 2004 Project No.: 38010068
To: Ms. Judy Kleiman

US Environmental Protection Agency Region 5 Chicago, IL

Re: Analytical plan for Owosso Graphic Arts

Included is the following information: El Original Document ❑ Copy of Document ❑ Plans ❑ Other This is transmitted: ❑ For your approval ❑ For your use As requested 

## Z For review


### COPIES DATE DESCRIPTION 1 4/1/04 Analytical plan for F006 Delisting; Owosso Graphic Arts



### COMMENTS: COPIES TO: Jack Schinderle, MDEQ; Don Spitler, Owosso Graphic Arts 

### SIGNED Terri Zick

Industrial Services Manager

Document3

### TABLE OF CONTENTS

I Analytical Plan

II Appendix A



### Waste Determination

III Appendix B



### Magnesium MSDS Magnesium Coating MSDS Gum Arabic MSDS Mag-o-zo Detergent MSDS

## ANALYTICAL PLANPROPOSED SAMPLING AND ANALYTICAL PLAN F006 WASTEWATER TREATMENT SLUGE



### Owosso Graphic Arts Owosso, MI March 31, 2004

I. Introduction 

### Owosso Graphic Arts (OGA) is submitting this proposed analytical approach for review and comment to Region 5 Environmental Protection Agency at the request of Judy Kleiman. The intent of this document is to describe the rationale for the sampling and analysis plan that is intended to substantiate a petition for de-listing of the F006 wastewater treatment sludge generated at the OGA facility in Owosso, Michigan (Appendix A).
II. Process Overview 

### Owosso Graphic Arts conducts chemical etching of magnesium plates to produce photoengraved dies for the printing and foil stamping industries. Nitric acid is used to etch the surface of magnesium plates to create the contoured die surface. When the nitric acid is no longer capable of etching the magnesium surface it is transferred through hard piping to a wastewater treatment system for neutralization and ultimately discharged to a publically owned treatment works (POTW) under the Clean Water Act. The neutralization of the etchant (nitric acid) generates an inorganic calcium based precipitate. This precipitate is dewatered using a filter press designed to remove free liquids. The resulting dewatered filter cake exits the wastewater treatment system and is collected in totes beneath the press. As neutralization is conducted on a batch basis, filter cake is also generated as a batch rather than continuously. Approximately 0.25 yards of filter cake are generated from the treatment of each batch of wastewater. A schematic of the neutralization system as designed by Systems Integration is provided in Figure 1. Photographic details of the existing wastewater treatment (neutralization) system at the Owosso Graphic Arts facility are provided in figures 2 through 5.■ I.,.-.-

### Proposed Analytical Plan

4/1/2004

III. Process Details 

### Substrate materials Magnesium is the exclusive substrate metal used in the above described etching process. Magnesium sheets are purchased from Magnesium Elektron North America. The alloy consists of magnesium, aluminum and zinc. A material safety data sheet for the magnesium sheets is provided in appendix B. The magnesium sheets are treated by the manufacturer with a red coating to protect the plates during handling and etching. The primary component of the protective coating is 2-Ethoxyethyl acetate (64%). The MSDS for this material is provided in Appendix B. The magnesium sheets are further protected during handling through the application of a 14% solution of Gum Arabic (Appendix B). 

### Etchant A solution containing nitric acid (pH <1.0) is used to etch the surface of the magnesium to create the die. The 67% nitric acid is delivered in bulk and stored in an aboveground product tank on the exterior of the building. No cross contamination of the acid is possible due to the fact that the tank is exclusively piped to supply acid to the etching process. The etching solution is comprised of 20% nitric acid (described above), 5% detergent and 75% water. The MSDS for the detergent product used in the etching solution is provided in Appendix B. Once used, the nitric acid is piped to a dedicated tank (figure 2) to await wastewater treatment. As no other systems are connected to the nitric acid storage tank, there is no potential for cross-contamination of the used acid. 

### Neutralization A 50% Sodium hydroxide solution (diluted with 2,000 gallons of water) is used to neutralize the used nitric acid to a pH between 7.5 and 9.0 prior to discharge to the Owosso Sewage Treatment Plant. The sodium hydroxide is stored in an aboveground storage tank (figure 3). There is no other potential source of cross-contamination of the sodium hydroxide.

### Proposed Analytical Plan

4/1/2004

Neutralization is conducted in a batch tank (figure 4) by combining metered amounts of the nitric acid and sodium hydroxide solutions. 

### De-watering When the treatment batch has been neutralized to an acceptable pH, the wastewater is discharged to the City of Owosso Wastewater Treatment Plant (WWTP). The WWTP staff periodically collects and analyzes effluent samples to confirm compliance with discharge requirements. The saturated precipitate that is formed during neutralization is transferred through hard piping to the filter press for de-watering. The de-watered filter "cake" is collected in two gondolas beneath the press. The gondolas are subsequently emptied into a lined roll-off container for storage prior to disposal. 

### Filter maintenance Periodically, the press filters require cleaning to remove accumulated wastewater treatment sludge. The manufacturer recommends that either of the following methods be utilized for cleaning the filters: 

### 1. Power washing The filters may be power washed to remove deposits of filter cake that collect in the filters. This is the method currently in use at Owosso Graphic Arts. The operational considerations of containerizing the washwater and disposal cost of washwater as a F006 waste have caused Owosso Graphic Arts to consider other practical options for routine maintenance of the filters. 

### 2. Closed-loop acid wash OGA is currently evaluating the potential for installing a closed-loop acid cleaning process for the press filters. Once the filter cake is emptied from the press into the gondolas (as described above), a 10 % solution of muriatic acid is flushed through the press to dissolve the precipitate residue remaining on the filters. Once the cleaning process is complete, the muriatic acid solution is returned through hard piping to the neutralization process for pH adjustment in conjunction with the nitric acid used in the etching process. A conceptual schematic is provided in Figure 6 below:Figure 6: Potential future filter cleaning schematic



### IV. Sampling and Analytical Approach 

### Historic analytical Analytical data exists for discrete samples collected in 1997 and 2001 respectively. This data will be submitted in conjunction with sampling and analytical results as described below. 

### Temporal sampling considerations Waste has been collected and staged in roll-off containers

. at the ` facility since June, 2003. A total of approximately 50 cubic yards of material is stored in five f 

### boxes on site awaiting disposal. This material represents waste generated over a period of approximately 10 ,months, Sampling and analysis of the staged material provides an excellent opportunity to explore the potential for temporal variability. The waste containers are staged in a fenced area with each box being securely covered to protect the material from weather conditions such as rain and snow. Storage of the material is not expected to alter the character of the waste, with the possible exception of diminished moisture content.

### Proposed Analytical Plan

4/1/2004

Owosso Graphic Arts has collected ten (10) discrete samples from each of the five (5) containers at the site as well as a sample o f waste directly from the filter press. These samples represent the character of the waste generated throughout approximately 20 press cycles (filter cake is removed from the press approximately every two weeks). A total of 11 samples have been collected to represent the waste generated since June, 2003 

### Spatial sampling considerations Each roll-off container contains approximately nine (9) cubic yards of waste material. Two samples have been collected from each roll-off container with sample locations near opposing ends of the containers. A composite will be generated from the ten (10) discrete samples of the staged material resulting in five (5) total samples representing the staged material. One (1) discrete sample of material has been collected directly from the filter press in addition to the samples obtained from the staged waste. 

### Analytical parameters and methods A total of six (6) samples as described above will be submitted to a qualified laboratory to be analyzed for the parameters outlined below.



### Parameter Method Detection / Quantitation Limits TCLP

extraction Universal

Treatment Standards 40 CFR 268.48 

### Cadmium Chromium Total Cyanide Amenable Cyanide Lead Nickel Silver *

6020* * 6020* 9010b* 9010b* 6020* 6020* * 6020* <0.1 mg/1

<0.5 mg/1 <500 mg/kg <30 mg/kg <0.5 mg/1 <10 mg/1 <0.1 mg/1 Yes

Yes No No Yes Yes Yes 0.11 mg/1

0.6 mg/1 590 mg/kg 30 mg/kg 0.75 mg/1 11.0 mg/1 0.14 mg/1 * other suitable SW846 method may be substituted Figure 7: Analytical parameters

### Proposed Analytical Plan

4/1/2004

With EPA concurrence, Owosso Graphic Arts will proceed with analysis of the samples as outlined above. Subsequently, a petition for de-listing the site specific wastewater treatment sludge will be prepared and submitted for EPA review. 

### Reference Documents RCRA Waste Sampling, Draft Technical Reference, EPA 530-D-02-002, 2002 Index to EPA Test methods, EPA Region New England Region I 

### Library, 2001 SW846; EPA Method 6020

## APPENDIX A Waste DeterminationUNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

Tern Zick, CHMM 

### CT! & Associates, Inc. 12482 Emerson Drive Brighton, MI 48116
Dear Ms. Zick: 

## FEB 1 2 2004 OFFICE OF SOLID WASTE AND EMERGENCY

RESPONSE

Thank you for your e-mail of September 9, 2003, to James Michael of the Environmental Protection Age eetching

PA) in which you ask for a regulatory clarification regarding the applicability of the F006 classification to wastes generated from the chemical etclng of magnesium. In your e-mail, you stated that you believe the wastes generated from the chemical etching of magnesium fall outside the definition of the F006 listing. You base this view on the fact that the chemical etching does not occur on a common or precious metal as defined in the listing background document (11/14/80) and the development document for proposed and existing source pretreatment standards for the electroplating industry (EPA, 2/78). The applicability of a Resource Conservation and Recovery Act (RCRA) hazardous waste listing is determined in the first instance by the regulatory language. The F006 listing covers wastewater treatment sludges from certain electroplating operations. The listing applies to chemical etching, among other activities, and only excludes the chemical etching of aluminum. Magnesium etching is not excluded from the F006 listing. In a December 2, 1986, Federal Register notice, EPA further interpreted the F006 language to apply to "common and precious metals," but this istatesly in certain instances, and did not affect chemical etching. Specifically, EPA's interpretative rule at 51 FR 43351 (December 2, 

### 1986) 2*A.ttes,states "The F006 listing is (and always has been) therefore, inclusive of wastewater treatment sludges from only the following processes: 

### (1) Common and precious metals electroplating, except tin, zinc (segregated basis), aluminum, and zinc-aluminum plating on carbon steel; (2) anodizing, except sulfuric acid anodizing of aluminum; (3) chemical etching and milling, except when performed on aluminum; and (4) cleaning and shipping, except when associated with tin, zinc, and aluminum plating on carbon steel." Thus, while the scope of electroplating processes is limited to common and precious metals with the exceptions as noted above, there are no such limitations for the remaining processes (anodizing, chemical etching and milling, and cleaning and stripping). Therefore, there is no exception for specific metal types from the listing for any of the remaining processes. Thus, wastewater treatment sludges generated from chemical etching of magnesium are subject to the F006 listing.

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (20% Postconsumer)We appreciate your concern that the background listing document didn't specifically

mention the chemical etching of magnesium. However, EPA's listings are defined by the regulatory language, and background documents don't necessarily catalogue every waste material that fits within that definition. In those situations where processes aren't specifically mentioned, EPA follows the straight reading of the regulations. You indicated that analysis of the wastewater treatment sludge does not show the constituents of concern for the F006 listing. if you believe that the wastewater treatment sludge does not contain any of the constituents of concern for the F006 listing, you may be eligible for a "delisting." Delisting is the procedure by which you can remove a waste from a hazardous waste listing. Since the State of Michigan is not authorized to make delisting decisions, you will need to work with EPA Region 5 if you wish to explore this option. The Regional contact for delisting is Judy Kleiman. Judy can be reached at (312) 886-1482. If you have any additional questions, please contact James Michael of my staff at (703) 308-8610.

cc: James Michael, HWID, OSW Judy Kleiman, Region 5, USEPA Jack Schinderle, Michigan DEQ

## APPENDIX B Magnesium MSDS13mg/m3-4 15 mgim 3 OSHA TWA 15 mgim 3 OSHA 

### TWA 5 m42/m 3 OSHA TWA 1314-13-2 5 mglm 3 OSHA TWA 7429-90-5 MATE IAL SAFETY DATA SHEET Magnesium Elektron North America, Incorporated / 1001 College Street / Madison, IL 62060

PRODUCT NAME: 

### PRC Magnesium Photoengraving Sheet 1. C EMICAL PRODUCT A 0 CO PAM' IDENTIFI ATION Product Name: Red Top PE Sheets, Solvent Developable PE Sheets Generic Name: Metal alloy Chemical Family: Light metals Responsible Party: Environmental Engineering

Magnesium Elektron North America, Inc. P.O. Box 258 Madison, IL 62060-0258 For further information call 8am-4pm Central Time, Mon-Fri: (618) 452-5190 24 Hour Emergency Telephone Number (Chemtrec) 1-800-424-9300 2. CO P INF 

### TI N ON NGREDIE T



# • -
HAZARDOUS COMPONENTS Base Metal Composition (Exposure values only applicable if generated) 

### MagnesiuAluminum metal (as Al) Total particulate Nurnjormimet40, , :(arkA0:: Total dust Respirable fBackcoat Zinc oxide fume 0-0.8% E3ackcoat Composition 

### None Identified PRC Coating Composition None Identi1309-48-4 3. HAZARDmg/m3NTIFICATION CAmg/m3 EXPOSURE GUImg/m3S Limits Agency Type

Potential Health Effects: 

### Based on available data, repeated exposures are not anticipated to cause any significant adverse effects. Eye: Mechanical injury only. Metal dust or fume may be dangerous to eye and surrounding tissue. Skin: Mechanical injury only. Molten material may bum skin.Inhalation: Dust may cause irritation to upper respiratory tract. Ingestion: Ingestion is unlikely due to physical state. If dusts are produced, amounts ingested incidental to industrial handling are not likely to produce injury, however, Ingestion of larger amounts could cause serious injury, even death, because the acute oral toxicity of magnesium is considered moderate. Signs and Symptoms: N/A Cancer: Not a listed carcinogen.


### 4. FIRST AID MEASURES: Eye: Irrigate immediately with water for at least 5 minutes. If mechanical injury results, consult a physician or qualified person. Skin: Wash off dust in flowing water or shower. If mechanical injury results, consult a physician or qualified person. Inhalation: Remove to fresh air if dust inhalation effects occur, Consult medical personnel Note to Physician

— No specific antidote for dust inhalation. Supportive care. Treatment based on judgement of the physician in response to reactions of the patient. Ingestion: Induce vomiting if large amounts of dust are ingested. Consult medical personnel. 5 FIRE F IN MEAS RES: Flammable Properties: Flash Point: None Melting Point: Approximately 875°F (468°C) to 1160°F (627°C) Boiling Point Not Determined

LEL/UEL: Not Applicable 

### NFPA HAZARD CLASS:

, Health: Flammability *I Reactivity 0 Unusual Fire and Explosion Hazards: When heated in air to a temperature near its melting point, magnesium alloys ignite and bum with a white flame. Use of water on molten or burning magnesium will 'produce hydrogen gas and may cause an explosion. Extinguishing Media: Smother burning magnesium by covering with an extinguishing powder approved for use on magnesium fires, such as 01, METL-X, etc. Consult National Fire Protection Association standards for other extinguishing media which may be applicable to certain operations such as foundries or heat-treat furnaces.Fire Fighting Instructions: Fire Fighting Equipment Wear positive pressure self-contained

breathing apparatus. 6. ACCIDENTAL RELEA E MEA URES: Actions to be taken for spills/leaks: clean off and reuse.

7. HANDLI TORA E: Handling: Practice reasonable care in handling magnesium and magnesium alloy product forms to avoid product damage and/or personal injury. If operations involving this product, such as machining, produce fines, such as dust, powder, chips, or turnings, proper measures should be taken to prevent dust clouds around these operations. These fines should be collected frequently and should be stored and disposed of in accordance with National Fire Protection Agency guidelines. If these fines should become ignited, they can be extinguished using procedures described in this document. Storage: Store product in dry location. Wet, moist or high humidity storage conditions will lead to corrosion of the product. Store away from other combustibles. See National Fire Protection Association Bulletin NFPA 480, "Storage, Handling and Processing of Magnesium Solids and Powders', for detailed storage information. 8. EXPOSURE CONTROL$ AND PERSONAL PROTECTION: Engineering Controls: Good general ventilation should be sufficient for most conditions. Loca exhaust ventilation may be necessary for some operations. Personal Protective Equipment: Respiratory: In dusty atmospheres, use an approved dust respirator. Skin: No precautions other than clean, long-sleeved body-covering clothing should be needed. Eye: Use safety glasses. If dust of fume causes discomfort, use chemical goggles. Face: Use face shield/welding hood as appropriate. Other Protective Equipment: Flame retardant clothing should be used when handling in molten state. 9. PHYSICAL AND CHEMICAL PROPERTIES: Flash Point: None Flammable/Explosive Limits: LEL/UEL — Not applicable Autoignition Temperature: Not applicable Melting Point Approximately 875°F (468°C) to 1160°F (627°C) Boiling Point: Not Determined Appearance: Silver Solid Odor None pH: Not applicable Vapor Pressure: Not Applicable Vapor Density: Not ApplicableSolubility in Water: Not Applicable Specific Gravity: Approximately 1.78-1.81

10. TABILI AN R TIV TY: Chemical Stability: Stable under normal handling conditions. Conditions to Avoid: Build ups of finely divided magnesium metal. Exposure to excessively high temperatures, and open flame. incompatible Materials: Acid. Reacts with acid to form hydrogen gas. In finely divided form, will react with water or acids to release hydrogen. Hazardous Decomposition Products: None under normal use or storage' . See incompatibility statement and fire and explosion hazard data for special situations. Hazardous Polymerization: Will not occur. ii 

### TOXICOLOGICAL, INFORMATION: Carcinogenity: Does not contain any carcinogens or potential carcinogens (IARC, NTP, OSHA) 12. DI PO AL CO IDE R TI. N Reclaim or recycle as much metal as possible. Dispose of waste in accordance with local, state, and federal regulations. 13 TRAM P RTA N INFORM TION: This product is not classified as U.S. Department of Transportation Hazardous Material, for road, rail, sea or air transport (no UN number required). However, by products from further processing may be listed in 49 CFR 172. 14. RE TON: 

# • - — • - This product may contain the following toxic chemical(s) subject to reporting under section 313 of the Emergency Planning and Community Right-To-Know Act of 1986(Title III of SARA) and of 40 CFR 372: Aluminum (dust or fume) CAS# 7429-90-5

Zinc (dust or fume) CS# 7440-66-6 16. •D ISCLAIM 0 EXP D AND IMPLIED WARRA TI

09/2612003 The information set forth herein is furnished without warranty of any kind. Magnesium Elektron North Ameri ca, Inc ('MENA") has presented the information in good faith and is believed to be correct as of the date hereof. MENA makes no representation as to the completeness or accuracy thereof. It is the end user's responsibility to determine suitability foMSDSeir purposes. MDeLormeeaer: RickRDALRnne •

## Red-Top Protective Coating MSDSMATERIAL SAFETY DATA. SHEET Magnesium Elektron North America 1001 College St. Madison, IL 62060 8/13/2003 PRODUCT NAME: PRC RedTop I. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION

. Product Name: PRC RedTop Generic Name: Red Resist Responsible Party: Environmental Engineering

Magnesium Elektron North Amedca P.O. Box 258 Madison, IL 62060-0258 For further information call 8am•4pm Central Time, Mon-Fri: (618) 452-5190 24 Hour Emergency Telephone Number (Chemtrec) 1-800-424-9300 2. OMPOSITION / INFORMATION N IN REDIENTS HAZARDOUS COMPONENT AS# POSURE GUIDELIN S Ethyoxyethyl acetate 64% 111-15-9

3. HAZARDS IDENTIFICATION: Potential Health Effects: Medical Conditions Aggravated by Overexposure: May aggravate asthma, existing pulmonary disease and dermatitis. Eye: Causes irritation seen as excess redness and swelling of the conjunctiva (the mucous membranes lining the eyelids and covering the front part of the eyeball). Skin: Causes irritation with discomfort, local - redness and possible swelling. Absorption: Prolonged or widespread contact with skin may lead to absorption or harmful amounts of material with accompanying signs and symptoms of toxicity as described for ingestion. Inhalation: Vapor causes irritation to the eyes, nose and respiratory tract. Overexposure may cause headache, nausea, and vomiting. Vapors have an objectionable odor. Limits 100ppm 540 mgim 3 5 ppm 27 mg/m' Agency Tvixt PEL PEL TLV TLV

Ingestion: May cause headache, nausea, vomiting, dizziness and weakness. Possible kidney damage may resumg/m3om ingestimg/m3 large qTypeties of material.Effects of Repeated Overexposure: Repeated overexposure at high concentrations (greater than 400 ppm) of 2-ethoxyethyl acetate may cause injury to bone marrow and blood cells, kidney liver and testes. Other Health Hazards: In laboratory inhalation studies, birth defects, increased fetal lethality, and delayed fetal development have been observed in offspring of female animals exposed to 2-ethoxyehthyl acetate during pregnancy, with an apparent threshold response level approaching 400 ppm concentration in the air. Skin contact may cause sensitization and an allergic reaction. 4. FIRST AID EA URES: Eye: Immediately flush with water and continue washing for several minutes. Obtain medical attention. Skin: Remove contaminated clothing. Flush skin with water. Inhalation: Remove to fresh air. Give artificial respiration if not breathing. If breathing is difficult, qualified personnel may give oxygen. Obtain medical attention. Ingestion: If patient is fully conscious, give two glasses of water. Induce vomiting. Obtain medical attention. Notes to Physician: There is no specific antidote. Treatment of overexposure should be directed at the control of symptoms and the clinical condition of the patient. 5. FIRE FIGHTIN MEA URES: Flammable Properties: Flash Point: 120° F = 51.7* C (Pensky-martens Closed Cup) Flammable Limits in Air, % by Volume: Lower Not Determined Higher Not Determined Extinguing Media: Apply alcohol type or all-purpose type foam by manufacturers recommended techniques for large fires; Use carbon dioxide or dry chemical metal for small fires. Special Firefighing Procedures; Fire fighters should wear self-contained breathing apparatus and protective clothing. Cool fire exposed containers with water. Unusual Fire and Explosion Hazards: None. HMIS Retina: Health 1 Flammability 2 Reactivity 06. ACCIDENTAL RELEASE MEASURE • Spills: Spill personnel should wear protective equipment, avoid contact with liquid and vapors. Collect for disposal. A portion of this product is insoluble in water; avoid discharge to sewers or natural waters. Disposal: Burn in an EPA licensed incinerator or dispose through a licensed waste disposal service with incineration or fuel blending/fuel burning capability. Follow Federal, State and local regulations. 7. HANDLING AND ST RAGE: Handling: No special handling required. Storage: Store tightly closed containers in a well-ventilated area from sources of heat, and flame. Precautions to be Taken in Handling and Storing: Warning! Harmful if inhaled or absorbed through skin . Causes eye and skin irritation. ,, May cause allergic skin reaction. Combustible. Can cause damage to blood-forming tissues. May cause damage to testes. Causes dizziness and drowsiness. May cause damage to liver and kidney. In laboratory animal studies, birth defects and adverse effects on pregnancy have been observed with 2-ethoxyethyl acetate. Avoid breathing vapors. Do not get in eyes, on skin on clothing. Accidental contact should be washed away immediately. Other Precautions: Warning. Sudden release of hot organic chemical vapors or mists from process equipment operating at elevated temperatures and pressure or sudden ingress of air into vacuum equipment, may result in ignitions without the presence of obvious ignition sources. Published "autoignition" or Ignition' temperature values cannot be treated as safe operating temperatures in chemical processes without analysis of the actual process conditions. Any use of this product in elevated temperature processes should be thoroughly evaluated to establish and maintain safe operating conditions. 8. EXPOSURE C L AND E SONAL PROTECTI N: Engineering Controls: Personal Protective Equipment: Respiratory: Use NIOSH/MSHA approved respirator (self-contained) in high vapor concentrations.

Ventilation: This product should be confined within closed equipment, in which case, general (mechanical) ventilation is expected to be adequate. Special ventilation is needed at points where vapors can be expected to escape to the workplace air. Skin: Butyl Eye: Monogoggles. Face: N/AT U. • Other Protective Equipment: Rubber aprons/clothing. Eye wash, safety shower. 9. PHYSICAL AND CHEMICAL PROPERTIES: Appearance and Odor: Opaque red liquid with characteristic odor Boiling Point, 760 mm Hg: 318°F (159°C) Specific Gravity (H20 =1) 1.04 + 0.01 Vapor Density (air = 1): >4 pH: N/A Vapor Pressure: greater than 2 mm Solubility in Water. <1% Percent Volatile by Weight: 71% Freezing Point -43.6 °F °C) Evaporation Rate (Butyl acetate = 1): <1 19. STABILITY AND REACTIVITY:
• Chemical Stability: Stable Conditions to Avoid: None. Incompatible Materials: Strong oxidizers Hazardous Decomposition Products: Burning may produce carbon monoxide and/or carbon dioxide. Hazardous Polymerization: Will not occur. Ii. TOXICOLOGICAL F R ATION: This product does contain chemicals known to cause cancer or reproductive toxicity. 12 REG LAT RY IN OR Constituents do require 40 CFR 372 for SARA 313 reporting.
Glycol ether category N/A 61.4 13. DI IMER F EXPRESSED AND IMPLIED W RRA T1 8:

8/1312003 The information set forth herein is furnished without warranty of any kind. MEL has presented the information in good faith and is believed to be correct as of the date hereof. MEL makes no representation as to the completeness or accuracy thereof. It is the end users responsibility to determine suitability for their purposes. MSDS Preparer: Rick Delorme •

## Gum Arabic MSDSFROM : PRINTERS RESOURCE PHUNL NU. e l e .C. ,

03/04/1999 Material , Saiety.Dats Sheet 60 Page 1 of 3

• GRAPHIORTS'SPECIALTIES, INC. E TION - MAN F CTURER INF NTISANI MANUF/DIST: GRAPHIC ARTS SPECIALTIES, INC. EMERGENCY PHONE: 800 - 424 - 9300 ADDRESS: 1630 N. Kingsbury St. PREPARATION/REVISION DATE: 02/02/1999 CITY, STATE, ZIP: Chicago, IL 60614-4811 PREPARER/CONTACT: AJG TRADE NAMEISYNON'YNIS: CHEMICAL FAMILY: VOLATILE ORGANIC MATERIAL VAPOR PRESSURE (mmHg ©20°C) - GUM MARC 14 SE, NOT APPLICABLE V.O.M. 0 LBS/GAL N/A

LIMARDOLAM SJr.M,(HMJSI

HEALTH: 0 FLAMMABILITY: 0 REACTIVITY: 0 PROTECTION: 13

THIS PRODUCT CONTAINS HAZARDOUS INGREDIENTS: NO CHEMICAL NAME/COMMON NAME: CAS NUMBER PEL-OSHA TLV-ACGIH NIA N/A N/A N/A

THIS PRODUCT CONTAINS CARCINOGENS (NTP, IARC, OSHA): NO CHEMICAL NAME/COMMON NAME: CAS NUMBER 34 NTP IARC OSHA N/A N/A N/A N/A N/A N/A

SECTiO 3- HEALTH EFFECTS (ACUTE & CHRONIC): N/A
PRIMARY ROUTES 

### or ENTRY: ingestion, eye and skin contact.
EMERGENCY FIRST AID PROCEDURES: Vapors may irritate eye, flush with copius amounts of water. Contact with skin may cause reddening, wash welt with water. Induce vomiting if ingested.INUV. r.

FROM PRINTERS RESOURCE

• PHONE NO. 2133 635 5662

03/0411999 Material Oafety.Data Sheet 60 Page 2 of 3 GRAPHIC '
.

.ART SPECIALTIES, INC. j11 4 CHEX1JCLQTA
BOILING POINT (INIT. °F): 212 SPECIFIC GRAVITY (WATER=1): 1.1069 VAPOR DENSITY (AIR=1): N/A PERCENT VOLATILE BY VOLUME (%): >70 pH: N/A EVAPORATION RATE: ( Ether =1): Long
SOLUBILITY IN WATER: Complete APPEARANCE AND ODOR INFORMATION: Amber viscous with mild odor.
ECTION 5 - PHYSICAL HAZARD DATA FLASH POINT (Method Used) None
EXTINGUISHING MEDIA:

N/A SPECIAL FIRE FIGHTING PROCEDURES: N/A - UNUSUAL FIRE AND EXPLOSION HAZARDS: N/A INCOMPATIBILITY (Materials to avoid): Strong oxidizing agents. HAZARDOUS DECOMPOSITION PRODUCTS: Carbon monoxide and Carbon dioxide, CONDITIONS TO AVOID FOR STABILITY: Strong oxidizing agents. FLAMMABLE LIMITS: Lel= N/A UEL N/A

5...EcTiotsp_gLeAKEEQuili..BES
STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED: Mop or wipe up and dispose of In DOT approved waste containers. WASTE DISPOSAL METHODS: Comply with all applicable government regulations.
SEQT101 , 1 7- EXPOSURE CONTROL INFQ,MATION VENTILATION: LOCAL EXHAUST: Acceptable MECHANICAL (General): Acceptable
RESPIRATORY PROTECTION: NoneNOV. 1. 1999 3 54PM P

FROM : PR INTERS RESOURCE PHONE NO. = sie 635 8862

03/04/1999 Material Safety.Data Sheet 60 GRAPHICARTS SPECIALTIES, INC.

• Page 3 of 3

PROTECTIVE GLOVES: Wear gioves, apron & footwear impervious to this material OTHER PROTECTIVE EQUIPMENT: Wear OSHA standard goggles or face shield, HYGIENIC PRACTICES: Avoid personal contact.

K: ‘a). R. aSEMAI._.eIRFSALL_ ,1 IONS,
PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE: f Store in containers provided by manufacturer. For bulk quantities, store in lined stainless steel or reinforced plastic tanks. Product has low vapor pressure and can be vented to atmosphere. MAINTENANCE PRECAUTIONS: Keep area dear of any spills.
OTHER PRECAUTIONS: None
ADDITIONAL COMMENTS: None
Key to Abbreviations: N/A=Not Applicable bisci_Aimerz: The informab'on on this Data Sheet represents our current data and best opinion as to the proper use and handling of this product under normal conditions. Any use of the product In combination with any other product Or any other process is the responsibility of the user.