### RE: Re: OWOSSO GRAPHIC ARTS Kathy Wilson to: Christopher Lambesis 06/09/2010 11:30 AM Cc: Todd Remaly, "'Terri Zick"'

From: "Kathy Wilson" <kathywilson@owossographic.com > To: Christopher Lambesis/R5/USEPA/US@EPA Cc: Todd Ramaly/R5/USEPA/US@EPA, "'Terri Zick'" <tzick@cticompanies.com >

Christopher, Attached please find our comments on the draft version of the delisting . Sincerely, Kathy Wilson

From: Lambesis.Christopher@epamail.epa.gov [mailto:Lambesis.Christopher@epamail.epa.gov] Sent: Thursday, June 03, 2010 11:58 AM To: kathywilson@owossographic.com Subject: Fw: Re: OWOSSO GRAPHIC ARTS

Forwarded by Christopher Lambesis/R5/USEPA/US on 06/03/2010 10:57AM To: "Kathy Wilson" <kathywilson@owossographic.com > From: Christopher Lambesis/R5/USEPA/US Date: 05/26/2010 11:25AM cc: Todd Ramaly/R5/USEPA/US@EPA, "'Terri Zick'" <tzick@cticompanies.com > Subject: Re: OWOSSO GRAPHIC ARTS
Kathy,
Attached is a draft version of Owosso's proposed delisting. Please review the document and let me know if you have any questions or concerns. I will still need to review the information requested in March concerning the NMP analysis. Please let me know when I can expect to get this.
Christopher Lambesis Environmental Scientist U.S EPA Region 5 Land and Chemicals Division (312) 886-3583 (See attached file: Owosso DRAFT 5-26-10.doc)
"Kathy Wilson" ---05/04/2010 09:35:52 AM—ChristopherFrom: "Kathy Wilson" <kathywilson@owossographic.com >

To: Christopher Lambesis/R5/USEPA/US @EPA

Cc: Todd Ramaly/R5/USEPA/US @EPA, "'Terri Zick" <tzick@cticompanies.com >June 9, 2010

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

Re: Comments on Draft Delisting Document; Owosso Graphic Arts, Owosso, Michigan
Dear Mr. Lambesis,
We have reviewed the draft language that you have prepared to propose the delisting of the wastewater treatment sludge generated by Owosso Graphic Arts. We are submitting the following comments for your consideration prior to publication of the draft delisting in the Federal Register:

1. Page 14: A statement is included in parenthesis which reads: "How many of what type of samples over what time period". Is this information that you are requesting Owosso Graphic Arts provide, or is it an internal reminder to add additional information which you already possess prior to publication?
2. Page 19, Condition IV D: The draft delisting specifies that Owosso Graphic Arts must sample and analyze at least one sample annually using extraction method 1311 (TCLP), or 1330A in the presence of oil and grease greater than 1 %. The petition and delisting was predicated on a conservative analysis and estimated TCLP based on totals analysis as described on page 13 of the delisting. Owosso Graphic Arts requests that the annual sampling and analysis be consistent with the methodologies used during the delisting petition process (ie. using the SW 846 methods detailed on page 13 of the draft delisting as totals analysis without extraction methods 1311 or 1330A). The use of totals analysis should also eliminate the need for oil and grease analysis using method 9071B.
3. Page 19, Condition IV D: The parameter list for annual analysis is not clearly specified. We assume that the constituents of interest for the annual sampling are limited to those parameters outlined in the table on Page 15 of the draft delisting, and would appreciate verification that this is your intent.
4. Page 22, Condition IV G: Owosso Graphic Arts understands its obligation to notify the EPA of significant process changes which may affect the character of the sludge generated in the waste water treatment process at the facility. We would appreciate, however, clarification of the EPA's definition of "significantly" in this condition. We presume that minor changes in products suchas supplier changes and product formulation updates initiated by the manufacturer which do not

change the overall character of the raw material are not significant and do not meet the intent of this requirement. Other operational changes which may result in piping and other mechanical changes that do not affect the nature of the waste as characterized in the analytical data submitted with the petition and its addenda are also interpreted to be outside of this definition. 5. Page 28; Condition 2: Please refer to comment #3 above regarding the use of totals analysis to estimate TCLP concentration for the purpose of comparison with the delisting levels. Owosso Graphic Arts requests that the option of using the well documented procedure of dividing the totals results by 20 to estimate the TCLP concentration. We request the option of demonstrating compliance on an annual basis using methods consistent with those used throughout the delisting process. Should data be inconclusive using totals methodologies defined on page 13 of the draft delisting, we recognize that analysis using either the method 1311 or 1330A extraction prior to analysis will be considered to be definitive.

Thank you for your consideration of the above comments and concerns. We look forward to publication and initiation of the public comment period. Please do not hesitate to contact me if questions arise regarding these comments.

Sincerely, Kathy Wilson