### FW: Owosso Graphic Arts MSDS Terri Zick to: Christopher Lambesis 03/31/2010 03:48 PM Cc: Kathy Wilson
From: Terri Zick <tzick@cticompanies.com > To: Christopher Lambesis/R5/USEPA/US@EPA Cc: Kathy Wilson <kathywilson@owossographic.com >

Chris- ! received your voice mail message and am re-sending you the response letter dated 1/24/08 which describes the transition from TCE to the aqueous developer which preceded the NMP. A copy of the MSDS is attached to that correspondence. Please let me know if this is not what you were looking for. Thank you

Terri Zick 313-300-7401 cell tzick@cticompanies.com

CTI and Associates, Inc. 

### 51331 W. Pontiac Trail, Wixom, MI 48393 248.486.5100 Phone 1, 248.486.5050 Fax

From: Terri Zick Sent: Thursday, January 24, 2008 5:51 PM To: lambesis.christopher@epa.gov Cc: Kathy Wilson; cellenberg@owossographic.com ; Jake Gadd Subject: Owosso Graphic ArtsChristopherAttached, please find an electronic copy of the amended responses to the outstanding issues of TCE use at the facility and grab sample results for volatile organics. You will also receive a hard copy of this information which includes the QA/QC package for the analytical. Please do not hesitate to contact me at any time with questions. I look forward to scheduling a time to confirm that all of the outstanding questions have been resolved. Thank you

Two:. 

### 2 ■ 44 '21'2 '21111 '7A111The 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!

### January 24, 2008

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 Delisting Petition; Owosso Graphic Arts, Owosso, MI Dear Mr. Lambesis, On November 19, 2007 CTI and Associates, Inc. (CTI) provided written responses to your letter dated September 14, 2007 in which you summarized your comments and recommendations subsequent to your review of the petition to de-list wastewater treatment filter cake generated at Owosso Graphic Arts, Inc., Owosso, MI. The following additional information is provided as further clarification of the petition dated May, 2005 and the response letter submitted on November 19, 2007: 

### Item 3; EPA Comments Letter Date September 14, 2007 Section Four, II, B. Analytical Data. As stated in the report, please submit the results of historical analysis. Please provide all historical analytical from' the facility regarding TCE, including waste, water discharge, ambient air, worker safety, etc. Also, clarify if the recent composite sampling results are attached in Appendix B or E. At the time of the initial response to your comments,. Owosso Graphic Arts was actively making arrangements to replace Trichloroethylene (TCE) with an aqueous based product. The' transition from TCE cleaning to aqueous cleaning was completed prior to December 20, 2007.. A copy of the Material Safety Data Sheet for the raw material which is currently in use in lieu of TCE is provided as Attachment A. Owosso graphic Arts staff has confirmed that all unused and spent TCE has been removed from the premises. A copy of the waste manifest documenting the removal of the remaining material is provided in Attachment B for your records.

### item 5; EPA Comments Letter Date September 14, 2007 Section 5.5. Please explain why composite samples (as opposed to grab samples) were taken for volatile analysis. 

### In the response provided on November 19, 2007 we indicated that a series of grab samples for was collected and submitted under proper chain of custody for analysis on 11/15/07. Results are provided as

. 

### Attachment C. The samples were collected by Terri Zick, CHMM on November 15, 2007. Sample volumes were obtained from each of three discrete locations along the filter press. The locations were selected to represent the filter cake produced nearest to the wastewater inlet, in the middle of the filter press and the point furthest from the inlet. Samples were placed with minimal headspace into 4 ounce glass containers prepared 

### by a qualified laboratory. Samples were transported on ice to the laboratory for analysis using CLP equivalent quality control measures. You will note that concentrations of TCE were detected above the method detection limit in each of the samples. As you are aware, the samples were collected prior to the cessation of TCE usage at the facility. Since that time, Owosso Graphic Arts has terminated use of TCE in favor of the aqueous material discussed above. No other proceSs within the facility utilizes TCE. Therefore, ICE is not reasonably expected to be present in current or future filter cake produced at the site. The above information is provided as clarification and amendment of the petition submitted in May, 2005 and the response letter submitted on November 19, 2007. Upon completion of your review of the above and enclosed information, we would appreciate setting up a conference call to discuss the status of the petition. Do not hesitate to contact me at any time should questions arise regarding this submittal.

. 

### Sincerely, CTI and Associates, Inc..)1914 Holloway Drive Holt, Mt 48842 T: (5171699-0345 F: (517)699-0388 11766 E. Grand River Brighton, AU 48116 T: (810) 220-3300 1: 010)220-3311 86605 Mackinaw trail Cadillac MI 49601 1 (231) 775.83 F: 03 1) 775-8584