UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 5 

77 WEST JACKSON BOULEVARD 

CHICAGO, IL 60604-3590 

Mail Code: LR-8J 

September 14, 2007 

Ms. Terri Zick 

Industrial Services Manager 

CTI and Associates, Inc. 

12482 Emerson Drive 

Brighton, Michigan 48116 

RE: U.S. EPA Comments on Delisting Petition for 

Owosso Graphic Arts, Owosso, Michigan 

Ms. Zick; 

Here is a list of comments concerning the Owosso Delisting Petition. I suggest these 

recommendations be addressed and the petition re-submitted for review. I am available to meet 

with the facility's representative to discuss these issues. 

1. Section Two, III, Volume of Petitioned Waste. Please clarify the reported values. 

Provide a historical list of the quantity of waste generated per month. Indicate what 

quantity value was used in the DRAS analysis. The values listed in the tables are 

measured in tons, however, DRAS asks for volume in cubic yards. Please provide an 

estimate of density or volume generated. 

2. Section Three, List and describe products manufactured at the facility. Please describe 

the brass product line, what waste is produced and how it is handled. 

3. Section Four, II.B.1.iii 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. 

4. Section 5.5. Please state if there was a sample 36660-2, and if there was, was it analyzed. 

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5. Section 5.5. Please explain why composite samples (as opposed to grab samples) were 

taken for volatile analysis. 

6. Please rearrange your laboratory submittals into chronological order. 

7. Please explain why some analytical results are reported in dry weight and others are not. 

8. Please explain the significance of Oil & Grease analytical results of 5%. Explain these 

results in light of the decision to not conduct OWEP analysis. 

9. Please provide the COC for the July 26, 2004 laboratory submittal. Also, there was no 

validation report provided for this sample describing the condition of the sample as 

received by the lab, temperature, holding time, etc. 

10. Please provide the results for all normally reported compounds under Method 8260 for all 

samples. 

11. Please provide clear copies of the February 16, 2005 COC and air currier documents. 

12. Please provide a table consisting of a list of the constituents analyzed throughout, results, 

units, detection limits, data qualifiers, sample identification numbers and sample dates. 

Also clearly delineate the total concentration and estimated TCLP concentration for each 

result. 

13. Please provide a list of DRAS input values including volume of waste, risk objectives, 

landfill life, etc. 

14. Please provide sampling logs or other documentation of the sampling events. 

If you have any additional questions, please contact me at the address above or at (312) 886-

3583. Please note that our mailing code has changed. Please use the new one for future 

submissions. 

Christopher Lambesis 

Environmental Scientist 

RCRA Programs Section 

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