United States
Environmental Protection
Agency, Region 1
New England
Environmental Assistance
Team
EPA-901-B-97-001
May 1997
Fit
to
Print
An Environmental Compliance and
Pollution Prevention Manual for
New England Lithographers
&EPA
Region 1, New England
-------
Here is what some printers, trade associations, and regulators have said about Fit to
Print:
"'Fit to Print'is great -- an excellent source of vital information. It answered a few questions that I could
never get an answer for."
Jane Cioffi, Southington Printing Co.
"You have done a very nice job of reducing a complex, and for many of us, an incomprehensible set of
different regulations into a readable and understandable document. It is packed with useful information."
Michael D. Coughlin, Concord Litho Company, Inc.
"The manual is terrific and should go far in helping printers understand and comply with the EPA
regulations."
Anthony Racco, The Hartford
"This document is a fine effort at tackling a very difficult topic, and should serve as a valuable resource
and reference document for printers who are committed to environmental compliance."
Stig Bolgen, Printing Industries of New England
"[We were] very impressed with the thoroughness and quality of the manual. We are certain that it will be
a big help to lithographic printers in the region."
Richard T. Enander, Rhode Island Department of Environmental Management
"I thought the document was well done. It is well organized ... and this format will help printers
understand how environmental regulations specifically apply to what they do."
Paul Van Hollebeke, Vermont Agency of Natural Resources
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v0 ^^ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* " r\ REGION 1
? JOHN F. KENNEDY FEDERAL BUILDING
BOSTON, MASSACHUSETTS 02203-0001
OFFICE OF THE
April 17 1997 REGIONAL ADMINISTRATOR
I am very pleased to give you Fit to Print: An Environmental Compliance and Pollution Prevention
Manual for New England Lithographers, produced by EPA's New England Environmental Assistance
Team (NEEATeam). By using a variety of tools to promote industrial environmental protection ~
education, outreach, and assistance among them the NEEATeam has provided compliance and
pollution prevention assistance to small and medium-sized companies in New England since 1995.
Through their efforts, the NEEATeam has shown that sound environmental practices make good
business sense.
Through its Fit to Print initiative, the NEEATeam along with its state and industry partners ~ has
been busy generating helpful materials and sponsoring events for printers throughout New England.
Besides this manual, the NEEATeam's Fit to Print initiative is developing compliance and pollution
prevention workshops, technology demonstration open houses, fact sheets, customer education
projects to encourage "green" printing, and an evaluation of a new printing ink system. In using these
materials and events, we hope to help printers meet their regulatory obligations, practice pollution
prevention and thrive economically.
We hope this document helps you become "fit to print." Because this manual is the first of its kind
generated by the NEEATeam, we especially welcome your comments and suggestions. Please call
the NEEATeam at (800) 906-3328 with any comments, suggestions or questions.
Sincerely,
John P. DeVillars
Region I Administrator
Recycled/Recyclable Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
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ACKNOWLEDGMENTS
The authors would like to thank the following individuals for their contributions to the development of this
manual:
CT Department of Environmental Protection: David Cherico, Glen Daraskevich, John Gove, Jim Grier,
Bob Hannon, Mike Harder, Robert Isner, Dick Mason, Joe Pulaski, Mary Sherwin, David Westcott;
ME Department of Environmental Protection: Mike Hudson, Brian Kavanah, Jim Rogers, Chris
Rushton, Ann Pistell; MA Department of Environmental Protection: John Reinhardt, Gene Romero,
William Sirull, Nancy Wrenn; MA Office of Technical Assistance for Toxic Use Reduction: George
Frantz; NH Department of Environmental Services:.Jeffrey Andrews, George Carlson, Rudy Cartier,
Max Hilgemeier, Tod Leedberg, Mitchell Locker, Vince Perelli, Craig Wright; Rl Department of
Environmental Management: Joe Antonio, Richard Enander, Tom Epstein, Richard Girasole, Ted
Hickey, Angelo Liberti, Doug McVay, Beverly Migliore, Terry Simpson, Gregory Yekhtikian; VT Agency of
Natural Resources: Val Colgrove, Gary Gulka, Chris Jones, Sherrie Kasten, Brian Kooiker, Christine
Thompson, Paul Van Hollebeke; Northeast Waste Management Officials' Association: Lisa
Regenstein; Printing Industries of New England: Stig Bolen; Goldman Environmental Consultants:
Robert Fricke; Cambridge Environmental, Inc.: Robert Pojasek; Book Press, Inc.: Paul Norcross;
Concord Litho Company, Inc.: Michael Coughlin; The Hartford: Anthony Racco; Southington Printing
Company: Jane Cioffi; Graphic Arts Technical Foundation: Gary Jones; U.S. Environmental
Protection Agency, Washington, D.C.: Doug Jamieson, David Salmon.
We would also like to recognize the following individuals from the U.S. Environmental Protection
Agency, Region I, New England who provided valuable suggestions on improving this document:
Andrea Simpson, Lee MacMichael, Leonard Wallace, Ann Williams, and Tim Williamson. Also, we would
like to say a special thanks to: Anne Arnold, Dave Delaney, Joan Jouzaitis, Anne Leiby, Sally Mansur, Lisa
Papetti, and Mark Spinale, without whose expertise and commitment this manual would not have been
possible.
This manual discusses the most significant federal and state environmental regulations that apply to
the lithographic printing industry. This manual is not an official EPA or state guidance document and
should not be relied upon by the industry as a method to identify all applicable regulatory requirements
for the following reasons: 1) Laws and regulations change; 2) Regulations that apply to a facility
depend upon the particular processes and chemicals used -- this manual contains information that
applies in general conditions; and 3) Laws and regulations at the federal, state, and local levels may
differ -- please note that local requirements are not identified in the manual. This manual does not
create any rights enforceable in litigation with the United States or the states.
We encourage you to use this manual as part of a larger compliance effort. Take time to identify the
universe of rules that apply to your facility by examining the regulations and requirements themselves.
Also, use the wide range of resources that are available to assist you -- see Chapter 9 for a list of
federal and state assistance providers who may be able to offer you additional information.
-------
In printing this manual, the New England Environmental Assistance Team followed the
recommendations made in this manual where possible, under the constraints made by U.S.
contracting and procurement regulations. The following specifications were used:
Paper: 100% recycled
30% post-consumer minimum
70% Ib. basis weight
no bleaching
no coating
Cover: 100% recycled
30% post-consumer minimum
80% Ib. basis weight
no bleaching
no coating
Ink: vegetable-based
This manual will soon be available in electronic form through a number of sources.
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Fit to Print
TABLE OF CONTENTS
CHAPTER PAGE
1. How Can I Become "Fit To Print?" 1
1.1 How Do I Comply With the Laws and Regulations That Apply to My Lithographic Print
Shop? 1
1.2 What Pollution Prevention Techniques Can I Use at My Lithographic Print Shop? .... 2
1.3 Where Can I Get Additional Information? 2
2. How Can Pollution Prevention Make Me "Fit To Print?" 3
2.1 What Is Prevent Pollution and How Can it Help My Print Shop? 3
2.2 What P2 Techniques Can I Use? 4
3. What Wastes Do I Generate During Printing Operations? 9
4. How Do I Comply With Wastewater Discharge Regulations? 13
4.1 Do I Know Where My Wastewater Goes? 13
4.2 What Do My Printing Wastewater Discharges Contain? 13
4.3 What Must I Do if I Discharge to the Sewer? 13
4.4 What Must I Do if I Discharge to a Septic System or Other Subsurface Wastewater
Disposal System? 17
4.5 What Must I Do if I Discharge to Surface Water? 18
4.6 Good Environmental Management Practices 20
4.7 Pollution Prevention Opportunities for Wastewater Discharges 25
5. How Do I Comply With Hazardous Waste Regulations? 31
5.1 Do I Have Hazardous Wastes at My Print Shop? 31
5.2 What Is My Hazardous Waste Generator Status? 37
5.3 What Requirements Must Hazardous Waste Generators Meet? 38
5.4 Good Environmental Management Practices 47
5.5 Pollution Prevention Opportunities for Hazardous Wastes 50
6. How Do I Comply With Air Regulations? 59
6.1 Air Emissions From Printing Operations 59
6.2 Calculating Air Emissions From Your Print Shop 60
6.3 Determining Which Regulations Apply to Your Facility 63
6.4 Air Pollution Permits 70
6.5 Good Environmental Management Practices 71
6.6 Pollution Prevention Opportunities for Air Emissions 71
7. How Should I Handle Solid Waste? 75
7.1 Reduction and Recycling Opportunities for Solid Waste 75
7.2 New England State Solid Waste Programs 76
8. How Do I Respond to Spills and Plan for Emergencies? 79
8.1 Emergency Spill Reporting 79
8.2 Emergency Planning and Chemical Reporting 81
8.3 Oil Spill Prevention Control and Countermeasures 83
8.4 One Plan 84
Table of Contents
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Fit to Print
TABLE OF CONTENTS (CONTINUED)
9. Resources 85
9.1 Connecticut 85
9.2 Maine 85
9.3 Massachusetts 86
9.4 New Hampshire 86
9.5 Rhode Island 87
9.6 Vermont 87
9.7 Federal Resources in New England 88
9.8 OSHA 89
9.9 Other Sources 90
EXHIBITS
1. Summary of Pollution Prevention Techniques 5
2. Examples of Typical Lithographic Wastes 10
3. Pollutants Prohibited From Discharge to Your POTW by the Federal
Pretreatment Regulations 15
4. Conditions That Make Your Shop Subject to SIU Permit Requirements 15
5. Reporting Requirements for All Indirect Dischargers 16
6. Sample MSDS 32
7. Federal Categories of Hazardous Waste Generators and Storage Time Limits Allowed 38
8. Sample Manifest 43
9. Contingency Requirements for LQGs and SQGs 46
10. Calculating Your Actual VOC or HAP Emissions 61
11. Calculating Actual and Potential VOC Emissions at Ace Printing 62
12. List of Federal Hazardous Air Pollutants (HAPs) 65
BACK POCKET CONTENTS
Summaries of Your State's Requirements for:
Wastewater Discharge
Hazardous Waste Management
Air Emissions Control
Table of Contents
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Fit to Print
I. How CAN I BECOME "FIT To PRINT?"
As we move toward the 21st Century, printing
shops are facing increasing pressure to
understand the environmental consequences of
their operations. As a New England lithographic
printer, you should care about operating your
shop in an environmentally sound manner for
several reasons:
Your shop's use of solvents, inks, fixers,
coatings, and other chemicals can impact the
environment and your workers.
The costs of noncompliance can be high.
Alternatives to your current way of doing
business may exist that could save you
money.
This manual is designed to help you understand
these issues and to give you the tools to make
appropriate changes in your processes, where
necessary. This manual is divided into chapters
that tell you how to comply with the most
significant federal environmental regulations.
The pocket at the end of this manual contains
summaries of state-specific environmental
regulations. You will also find information on
pollution prevention, solid waste management,
emergency planning and response, and
resources throughout New England that are
available to assist you. We hope that you find
this manual useful and that it helps you become
"Fit To Print."
I.I How Do I COMPLY WITH THE
LAWS AND REGULATIONS THAT
APPLY To MY LITHOGRAPHIC
PRINT SHOP?
It is important for you to be aware of and comply
with all environmental laws and regulations that
apply to your print shop. These laws and
regulations can be found at the federal, state,
and local levels. Congress has enacted the
federal environmental laws over the past three
decades to protect our air, land, and water. The
U.S. Environmental Protection Agency is
directed to write regulations that implement
these laws. In most instances, the states have
also developed regulations that are often, but not
always, based on federal regulations. By law,
state environmental regulations must be at least
as stringent as their federal counterparts; in
some cases, they are more stringent than
federal regulations. For this reason, you should
be especially careful to determine how your
state's environmental regulations apply to your
print shop. You should become familiar with your
state environmental agency and its regulations,
and use this document to guide your inquires.
This manual discusses the most significant -
but not all of the - federal and state
environmental requirements that apply to
your print shop; local requirements are not
addressed at all. City or town water and sewer
departments, especially, will most likely have
standards of which you should be aware. You
should contact these offices directly to get the
best information on their requirements.
Here is what you should do:
First, identify the materials you use and the
wastes you generate at your print shop. The
information contained in Chapter 3 will help you
identify the types of wastes you generate in your
prepress, press, and postpress operations and
your housekeeping activities. Lithographic
printing wastes can include wastes released into
the water including treated fixer and developer;
hazardous waste, such as untreated fixer; and
releases into the air from solvents and coatings.
Second, determine which laws and
regulations apply to your print shop in light of
the materials used and wastes generated at your
print shop. Chapters 4 through 6 highlight the
most significant federal regulatory requirements
that may apply to your print shop. The pocket at
the back of this manual includes summaries of
the major state environmental requirements that
may impact your print shop. These summaries
are not intended to replace state regulations,
however.
Finally, determine what other laws and
regulations apply to your processes, in
How Can I Become "Fit to Print?"
-------
Fit to Print
addition to those that govern how you deal with
the wastes you produce. Chapter 8 sets forth
many of the additional spill reporting and other
reporting requirements to which your print shop
may be subject.
1.2 WHAT POLLUTION PREVENTION
TECHNIQUES CAN I USE AT MY
LITHOGRAPHIC PRINT SHOP?
This manual highlights pollution prevention (P2)
techniques that may improve your shop's
compliance and environmental performance.
Why should you try pollution prevention? A U.S.
Chamber of Commerce survey of 800
companies showed that labor and environmental
regulations are business "growth killers" (i.e.,
they caused businesses to raise prices and
reduced their profitability). So the best way to
improve the viability of your shop is to decrease
your regulatory burden. And the only legal way
to do that is to prevent pollution. Chapter 2
explains pollution prevention in detail and
summarizes some of the P2 options that can be
used in your industry. Chapters 4 through 6
provide examples of P2 techniques. Solid waste
reduction techniques and resources are provided
in Chapter 7.
commercial organizations, and non-profit groups;
we can provide written reference materials and
advise you on environmental compliance and
pollution prevention strategies; and we can give
you the recognition you deserve for practicing
pollution prevention. So, call us at 1-800-
90NEEAT. Look for our homepage on the
Internet at http://www.epa.gov/region01. Or,
write to us at the address listed in Chapter 9.
A closing thought: You can do it! If you can
master the fine art of printing, you can comply
with environmental regulations and prevent
pollution as many others in your industry have
done.
1.3 WHERE CAN I GET ADDITIONAL
INFORMATION?
The names and telephone numbers of federal
and state contacts are provided throughout this
manual. If you have a question about your
compliance obligations or about P2
opportunities, we encourage you to call the
contacts listed at the end of Chapter 9 and
provided in the pocket at the end of this manual,
as well as your local city or town agents.
Who are "we?" Regional experts in conjunction
with the New England Environmental Assistance
Team (the NEEATeam) produced this manual.
The NEEATeam provides environmental
compliance and pollution prevention information
for selected regulated groups, including printers,
throughout New England. We can help you find
experts in federal and state governments,
How Can I Become "Fit to Print?"
-------
Fit to Print
2. How CAN POLLUTION PREVENTION MAKE ME "FIT TO PRINT?"
Pollution prevention is a simple idea: it means
you eliminate pollution before it is created by
your manufacturing processes rather than
controlling the pollution from your processes and
then treating and disposing of the wastes that
you generate. Pollution prevention techniques
that printers can use range from merely using
chemicals in the shop more conservatively and
responsibly to making fundamental changes in
the way presses are operated and maintained.
This chapter discusses the benefits of pollution
prevention, as well as some of the techniques
that might work in your shop.
2.1 WHAT Is POLLUTION
PREVENTION AND How CAN IT
HELP MY PRINT SHOP?
The U.S. Environmental Protection Agency
defines pollution prevention as the use of
materials, processes, or practices that reduce or
eliminate the generation of pollutants or waste at
the source. The direct benefits of pollution
prevention are:
Decreased waste management costs
Decreased input materials costs and energy
consumption
Decreased environmental compliance costs
Decreased liability
Increased compliance
Increased worker safety
Improved corporate image.
What will these benefits mean to your printing
business?
Reductions in the cost of operating your
print shop.
The creation of waste that impacts the water,
land, or air, and the use of certain chemicals,
translates into additional dollars you must spend.
When you generate waste, your operating costs
increase since you must pay for items, such as
hazardous waste disposal, the installation and
operation of pollution control equipment, and
permit fees. By reducing waste streams, you
can cut the cost of operating your shop. And
these cost savings should translate to lower
prices and increased profits.
For example, you purchase a petroleum-based
solvent for press cleaning, you clean your
presses with the solvent, and the remainder that
collects in drip trays becomes a hazardous
waste (because it has been mixed with inks and
other contaminants). Then, you pay someone to
dispose of the solvent in a responsible manner.
Essentially, you have paid for the solvent twice
-- once when you bought it the first time and
again when it went out for disposal as a
hazardous waste. You would not throw out part
of a completed job, so why waste the materials
that go into the job by using them carelessly?
Using your press wash conservatively is an
example of pollution prevention that can prevent
waste and reduce your operating costs.
A more efficient and more productive
business.
In order to maintain compliance with
environmental regulations, you and your staff
must conduct a great number of activities. Each
of these compliance activities costs your shop
time and money. And, more often than not, the
cost is hidden in your shop's overhead. The
more waste you generate, the more your shop
may be regulated. So, if you spend less time on
compliance because you have less waste to
manage, you will have more time to do what you
are supposed to do: PRINTING.
Peace of mind.
If your workers are exposed less frequently to
hazardous materials, their health and safety will
not be as much at risk. Your employees will be
happier, and you will not need to be concerned
about their well being -- or your liability. If there
are fewer hazardous materials in your shop, your
compliance obligations will be fewer. The
environment will be cleaner. You will be
prepared for a regulator's inspection, and your
corporate image will shine. The old saying is
true: an ounce of prevention is worth a pound of
cure.
How Can Pollution Prevention Make Me "Fit to Print?"
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2.2 WHAT P2 TECHNIQUES CAN I
USE?
This section presents an overview of pollution
prevention techniques that can be incorporated
into your prepress, press, and postpress
operations and housekeeping activities.
Prepress operation pollution prevention
techniques primarily involve:
- Activities that extend the chemical and wash
bath life
- Activities that reduce, recover, and recycle
the chemicals used in photo-processing
operations
- Activities that reduce energy and input
material consumption
- Activities that eliminate the need for wet
processing operations.
Press operation pollution prevention
techniques incorporate:
- Process modifications that reduce ink use at
the press and waste ink generated
- Equipment changes to improve solvent and
fountain solution use
- Use of less toxic or non-toxic inks, solvents,
and fountain solution
- Improvements in handling of and waste
management practices for input materials.
Postpress operation pollution prevention
techniques focus on:
- Material substitutions such as switching to
water based adhesives
- Equipment modifications to make finishing
operations more efficient.
Exhibit 1 summarizes pollution prevention
techniques for the prepress, press, and
postpress operations, as well as for
housekeeping activities. The exhibit provides a
general idea of the options available to you and
their potential benefits in your shop. Chapters 4
through 7 present detailed descriptions of each
pollution prevention technique. It is important to
remember that not every pollution prevention
technique will work at every print shop. You
should compare and evaluate these pollution
prevention techniques to identify those that may
help you meet your pollution prevention goals.
Fit to Print
You will then need to try a select few to
determine what works in your shop, but does not
compromise the quality of your product. Some
pollution prevention techniques are easy; some
are more challenging. They all involve changes
in how you do business. When you understand
how much it costs to comply with all the
regulations that apply to your shop, however, we
think you will see that changing your operations
makes good business sense.
Each New England state has a staff of pollution
prevention experts who can provide additional
information and confidential on-site technical
assistance, free of charge. You should work
with the pollution prevention office in your state,
using this manual to guide your inquiries.
Chapter 9 presents a list of contacts.
So, get going! Start today by making a
commitment to pollution prevention, and give
your print shop a business advantage in an
increasingly competitive industry.
How Can Pollution Prevent/on Make Me "Fit to Print?"
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Fit to Print
Exhibit 1. Summary of Pollution Prevention Techniques
Pollution Prevention
Technique
Benefits
Waste Reduced
Page
No.
PREPRESS
Cover Photoprocessing
Chemical Containers
Aqueous Platemaking
Extending Bath Life
Reduce
Photoprocessing
Wastewater
Wash Water
Control
Units
Wash Water
Recirculation Units
Countercurrent
Washes
Silver Recovery
On-Site
Off-Site
Material Substitution
Electronic Imaging and
Laser Platemaking
Reduction of the amount of raw materials lost
to evaporation.
Elimination of hazardous plate developer
waste. Increased employee safety because
of reduced exposure to chemicals.
Cost savings on raw materials. Reduction in
the amount of wastewater or hazardous
waste generated. Increased employee safety
by reduction in exposure to chemicals.
Cost savings from decreased fresh water use.
Reduced wastewater discharge. Decreased
energy consumption.
Revenue from on-site recovery of silver.
Increased employee safety due to reduced
exposure to waste fixer. Cost savings from
recovery of fixer solution.
Reduction in the amount of hazardous waste,
wastewater, and solid waste generated due to
use of less hazardous or nonhazardous
materials.
Reduction in the amount of input materials
used, thereby resulting in a reduction in the
amount of waste generated. Increased
productivity because of reduced manual
labor.
Air emissions
Hazardous waste
Air emissions
Wastewater
Hazardous waste
Air emissions
Wastewater
Wastewater
Hazardous waste
Wastewater
Hazardous waste
Solid waste
Wastewater
Hazardous waste
72
53
25
25-27
27-29
29
30
How Can Pollution Prevention Make Me "Fit to Print?"
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Fit to Print
Exhibit 1. Summary of Pollution Prevention Techniques (Continued)
Pollution Prevention
Technique
Benefits
Waste Reduced
Page
No.
PRESS
Ink Inventory Control
Improve Press
Cleaning Practices
Recycle Used Ink
Automated Press
Adjustments for
Makeready
Alternative Inks
Alternative
Fountain Solutions
Automatic Ink
Levelers and
Antiskinning Spray
Alternative
Cleaning Solutions
Reuse and Recycle
Waste Solvents
Reduce Fountain
Solution Temperature
Automatic Blanket
Cleaners
Cost savings from reductions in out-dated
materials and waste ink disposal costs.
Reductions in the amount of waste ink
generated and the amount of cleaning solvent
and towels used.
Reductions in ink use and ink disposal.
Increased quality control. Reductions in
waste paper and ink generation.
Reduction in hazardous materials used,
waste generated, hazardous waste disposal
costs, Volatile Organic Compound (VOC)
emissions, and the amount of solvent needed
to clean the equipment.
Will help meet VOC emission limitations.
Increase in indoor air quality because of
reduced emissions. Elimination of the use of
Isopropyl Alcohol (IPA) fountain solutions.
Reductions in ink use and ink disposal.
Reduced VOC emissions. Improved indoor
and regional air quality. Increased employee
safety from reduction in handling toxic
chemicals.
Reductions in the amount of new solvent
used and the quantity of waste solvent that
must be disposed.
Reductions in fountain solution losses.
Reduction in amount of waste paper and ink
generated from poor press runs. Less
evaporation of IPA.
Cost savings from decreased solvent use and
labor required for cleaning the presses.
Increased employee safety from reduced
solvent handling and exposure. Reductions
in solvent use, waste solvent generation, and
VOC emissions.
Hazardous waste
Hazardous waste
Hazardous waste
Hazardous waste
Solid waste
Hazardous waste
Air emissions
Air emissions
Hazardous waste
Solid waste
Air emissions
Hazardous waste
Air emissions
Hazardous waste
Solid waste
Hazardous waste
Air emissions
50-51
52
52
53-54
54-55
72
56
72
56
73
57
How Can Pollution Prevention Make Me "Fit to Print?"
6
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Fit to Print
Exhibit 1. Summary of Pollution Prevention Techniques (Continued)
Pollution Prevention
Technique
Benefits
Waste Reduced
Page
No.
POSTPRESS
Water-Based
Adhesives for Post
Press Operations
Increase Use of In-Line
Finishing
Reduction in solvent-based adhesives used.
Reduction in VOC emissions. Reduction in
waste disposal.
Reductions in labor. Increase in rate of
production.
Air emissions
Solid waste
73
75
HOUSEKEEPING
Material Handling and
Storage
Reduce Materials Used
Reuse Materials
Recycle Scrap
Solvent Sink For
Parts Cleaning
Cost savings resulting from a reduction in the
amount of raw materials discarded due to
damage or expiration.
Cost savings from decreased material
purchases. Reduction in waste generated by
printing operations.
Cost savings from reuse of materials in
printing operations and reduction in solid
waste disposal.
Cost savings from reduced waste disposal.
Reductions in environmental impacts of
landfilling or trash incineration.
Reductions in the amount of new solvent
used and the quantity of waste solvent that
must be disposed.
Hazardous waste
Solid waste
Solid waste
Solid waste
Solid waste
Hazardous waste
51
75
75
75
57
Here is how to get started:
1. Read Chapter 3 to get a sense for the wastes you may generate.
2. Identify your problem waste first. This will include waste that you generate in high volume, that is
costly to dispose, that is highly toxic, or that is heavily regulated.
3. Read the P2 suggestions in this manual and seek additional information if you need it. Talk to
your staff, the experts listed in this manual, other printers, or your vendors.
4. Keep an eye on results. You will want to know whether the changes are helping and how much
money you have saved. Your shop will be proof that pollution prevention pays - you will know you
are on the right track if your shop is clean and orderly (e.g., no towels lying around, containers are
closed, waste management areas are neat).
5. And last, but definitely not least, pat yourself on the back and enjoy the advantage! The New
England Environmental Assistance Team (the NEEATeam) has a program to provide you with the
public recognition you deserve for a job well done. Call 1-800-90NEEAT for more information.
How Can Pollution Prevention Make Me "Fit to Print?"
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Fit to Print
3. WHAT WASTES Do I GENERATE DURING PRINTING OPERATIONS?
If you are a lithographic printer, you generate
waste. This waste can take one of the four
forms called waste streams'.
Wastewater
Hazardous waste
Air emissions
Solid waste.
Waste will be generated throughout prepress,
press, and postpress operations, as well as
housekeeping activities.
Exhibit 2 presents examples of typical
lithographic wastes. (Note: This exhibit is not all
inclusive. Depending on the input materials
used in your shop, your shop may generate
waste that is not listed.) Each waste is grouped
in the table according to the waste stream (i.e.,
wastewater, hazardous waste, air emissions, or
solid waste) in which it is commonly found in a
print shop. For example, used, treated fixer and
used developer are most commonly put in a
print shop's wastewater, rather than being
drummed and disposed of as a hazardous
waste. So, you will find this waste listed in the
wastewater section of the exhibit, and you will
need to pay careful attention to Chapter 4 of this
manual in order to comply with the appropriate
regulations. Similarly, if you dispose of this
waste in drums as hazardous waste, you should
read Chapter 5 of this manual and follow those
regulations.
To identify the regulations that may impact your
shop and the pollution prevention opportunities
available follow these four steps:
1. Use Exhibit 2 as a general guide to identify
the waste your shop generates.
2. Identify any waste generated at your shop
that is not listed in Exhibit 2. Refer to the
resources listed in Chapter 9 if you are not
sure whether some aspect of your process is
generating a waste.
3. Determine how you currently manage each
waste you generate by answering the
question, "In what form or waste stream does
this waste leave my shop?"
4. Refer to the following chapters for information
on regulatory compliance and pollution
prevention for each of your shop's waste
streams:
Wastewater -- Chapter 4
Hazardous Waste -- Chapter 5
Air Emissions -- Chapter 6
Solid Waste -- Chapter 7.
What Wastes Do I Generate During Printing Operations?
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Exhibit 2. Examples of Typical Lithographic Wastes
PREPRESS WASTE
Wastewater
Used, treated fixers
Used developers
Used activators/
stabilizers
Plate developer
Rinse water
Hazardous Waste*
Chrome-based
system cleaners
Non-empty
aerosol cans
Discarded, unused,
or outdated chemicals
Used, untreated
fixers
Used shop towels
contaminated with
hazardous waste**
Proofing system
chemicals
Air Emissions
Volatile Organic
Compounds (VOCs)
or toxics emitted
from
-Film cleaner
-Proofing systems
solvents
Solid Wastes
Empty containers
Developed or out-
dated film
Out-dated materials
Used or damaged
plates
Used, empty aerosol
cans
Used shop towels**
PRESS WASTE
Wastewater
Spent fountain
solution
Rinse water
Hazardous Wastes*
Waste ink containing
solvents
Waste lubricating oil
(if defined as hazardous
waste by your state)
Used blanket or roller
wash
Spent cleaning solvent
Used shop towels
contaminated with
hazardous waste**
Used parts washer
solvent
Air Emissions
VOCs or toxics
emitted from
- Solvents from
heatset inks/ink oils
- Isopropyl alcohol
- Cleaning solvents
- Coatings
- Solvent-saturated
shop towels
- Fountain solution
additives
Solid Wastes
Ink containers
Used plates
Used blankets
Off-spec printings
Paper wrappings
Paper roll ends
Unprinted paper roll
cores
End caps
Used shop towels**
* A waste is a "hazardous waste" if it is listed in federal or state regulations or if it exhibits hazardous characteristics.
(See Section 5.1 for the definition.) The list of hazardous waste here assumes that the waste meets one of these
criteria.
** Check with your state's hazardous waste office (see the information presented in the pocket at the end of this
manual) to help you determine whether your shop towels are hazardous.
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Exhibit 2. Examples of Typical Lithographic Wastes (continued)
POSTPRESS WASTE
Wastewater
Water-based
inks from ink
jet operations
Water-based
coatings
Water-based
adhesives
Hazardous Wastes*
Used shop towels
contaminated with
hazardous waste**
Air Emissions
VOCs or toxics
emitted from
- Adhesives
- Coatings
Solid Wastes
Waste paper
Waste shipping materials
Scrap board
Excess adhesives
Used shop towels**
Non-recyclable paper
Empty containers
HOUSEKEEPING WASTE
Wastewater
Cleaning
wastewater
Hazardous Wastes
Waste oil (if defined
as hazardous waste
by your state)
Absorbent materials
used to pick up
residual oils (if defined
as hazardous waste
by your state) or
solvents
Used shop towels
contaminated with
hazardous waste**
Air Emissions
VOCs or toxics emitted
from
- Miscellaneous
cleaners
- Paints
- Parts washers
Solid Wastes
Empty containers
Used shop towels**
Pallets
* A waste is a "hazardous waste" if it is listed in federal or state regulations or if it exhibits hazardous characteristics.
(See Section 5.1 for the definition.) The list of hazardous waste here assumes that the waste meets one of these
criteria.
** Check with your state's hazardous waste office (see the information presented in the pocket at the end of this
manual) to help you determine whether your shop towels are hazardous.
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4. How Do I COMPLY WITH WASTEWATER DISCHARGE REGULATIONS?
The discharge of wastewater from an industrial
source, including your lithographic print shop, will
generally be covered by either the Federal Clean
Water Act or the Safe Drinking Water Act. This
chapter explains these laws and the
implementing regulations which establish the
basic framework for keeping pollution, including
toxic pollutants, out of our rivers, lakes, and
oceans. Since the primary sources of such toxic
water pollutants are industrial facilities, the U.S.
Environmental Protection Agency (EPA) has
taken steps to regulate these facilities.
4.1 Do I KNOW WHERE MY
WASTEWATER GOES?
You must be able to answer "yes" to this
question. Discharges to unknown locations can
harm your workers and the environment and can
expose your shop to potential liability.
Your printing wastewater most likely gets
discharged to one of three locations:
Sewers leading to publicly owned treatment
works (POTW). After treating the wastewater,
the POTW discharges it to a surface water,
such as a river, lake, or stream.
Septic and leach field systems (and other
subsurface disposal systems).
Surface waters, including ponds, lakes,
oceans, streams, wetlands, and other water
bodies.
Federal, state, and local regulations regulate
discharges to each of these locations. To
comply with these regulations, you should have a
good understanding of where your wastewater is
being discharged and what your wastewater
discharge contains.
4.2 WHAT Do MY PRINTING
WASTEWATER DISCHARGES
CONTAIN?
Now that you have identified where your
wastewater goes, the next step is to determine
what is in it. Wastewater is commonly generated
during prepress, press, and postpress
operations. Exhibit 2 lists lithographic wastes
(e.g., used fixer and spent fountain solution)
typically found in wastewater (see Chapter 3).
While this list is not all inclusive, it gives you a
general idea of the kinds of waste generated in
each operation that may end up in your shop's
wastewater. For most shops, silver discharges
will be of primary concern.
After you identify the waste in the wastewater
generated by your facility, you must determine
how best to manage it according to the
regulations that apply. Here are the steps you
should follow to responsibly manage wastewater
from your print shop:
Follow the compliance guidelines listed in
Sections 4.3 through 4.5 according to where
your wastewater is discharged.
Comply with all applicable federal, state, and
local regulations, including obtaining the
necessary permits or registrations. The pocket
at the end of this manual contains a summary
of your state's requirements.
Practice good environmental management.
(Section 4.6)
Prevent pollution. (Section 4.7)
4.3 WHAT MUST I Do IF I
DISCHARGE TO THE SEWER?
If your print shop discharges wastewater into a
sewer system that leads to a municipal treatment
plant, also known as a publicly owned treatment
works, you are subject to the requirements
discussed in this section. Sometimes, you may
hear these referred to as the requirements for
indirect discharges. Usually, POTWs treat
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domestic household wastes using filtration and
biological treatment processes. Because certain
pollutants present in industrial discharges can
adversely affect the POTW's treatment
processes or pass through the plant directly to
surface water without receiving adequate
treatment, POTWs generally cannot handle
certain types of industrial pollutants in large
quantities.
Federal pretreatment regulations were
developed to prevent or minimize the discharge
of certain pollutants to the POTW. These
regulations, apply to all industrial facilities,
including lithographic printers, that discharge
industrial wastewater to POTWs. Industrial
wastewater includes any sources of non-sanitary
wastes (i.e., process wastewater). Because
EPA or the states often delegate the authority to
enforce these requirements to the POTWs, you
should familiarize yourself with your POTW's
local requirements.
Two types of pretreatment requirements exist:
those for all industry (known as general
pretreatment standards) and those for specific
industries (known as categorical pretreatment
standards):
General pretreatment standards establish
minimum discharge requirements for all
industrial dischargers, including lithographic
printers. These standards prohibit all industrial
users from discharging specific pollutants to
POTWs. Exhibit 3 lists the types of pollutants
prohibited by the general pretreatment
standards.
Categorical pretreatment standards apply to
specific types or categories of industrial
facilities or processes. As of the date of this
printing, such standards have not been
established for the printing industry.
In addition to the general pretreatment
standards, your shop may be subject to
requirements established by your local POTW.
That is, the POTW may impose its own
wastewater discharge limits upon your industrial
discharges in order to protect its treatment plant
and to meet its own direct discharge permit
limits. Where POTW requirements are more
stringent than federal requirements, they will
apply in lieu of the federal requirements. In all
instances, you must notify and get approval from
your POTW to discharge industrial wastewater to
the POTW.
In addition to the above, you also may need to
get a wastewater discharge permit from the local
POTW or the state if one of the two following
conditions exist:
Your print shop is considered a significant
industrial user (SIU) (Exhibit 4 lists the criteria
that would make you an SIU.)
You are not an SIU but the POTW to which
you discharge requires that all industrial
dischargers, including small dischargers, have
a permit.
(Check with your local POTW to find out if you
must obtain a permit in either situation.)
Regardless of whether a POTW issues a local
permit to your facility, you must check with your
state environmental agency to find out if a state
permit is also required for a discharge to a
POTW. Some states may have a permit
program specifically for discharges to the sewer.
Overall, even if a POTW or the state does not
require a permit, you should notify and obtain
approval from the POTW to discharge into the
sewer system.
If you discharge to a POTW, you may also be
required to monitor, submit reports, and keep
records of your industrial wastewater discharges.
Certain reporting requirements apply to all
discharges to the POTW. Exhibit 5 presents the
most significant of these requirements. In
addition, if your shop must obtain a permit, as
discussed above, your facility-specific permit
may contain additional monitoring, reporting, and
recordkeeping requirements.
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Exhibit 3. Pollutants Prohibited From Discharge to Your POTW By the
Federal Pretreatment Regulations
Some of the general types of prohibited pollutants include:
Pollutants that cause pass through or interference at the POTW
Pollutants that create a fire or explosion hazard in the POTW, including waste streams with a
closed cup flashpoint of less than 140 degrees Fahrenheit
Pollutants that cause corrosive structural damage (i.e., any wastewater with a pH less than 5)
Pollutants that are solid or viscous and can obstruct the wastewater flow
Pollutants that are released in a discharge at a flow rate or concentration that will cause
interference at the POTW
Heat in amounts that will inhibit biological activity at the POTW, and, in any case, discharges
that will cause the temperature at the POTW to exceed 104 degrees Fahrenheit
Petroleum oil, non-biodegradable cutting oil, or products of mineral oil in amounts that will
cause interference or pass through
Pollutants that result in the presence of toxic gases, vapors, or fumes in the POTW that may
cause acute worker health and safety problems
Any trucked or hauled pollutants, except at discharge points designated by the POTW.
See 40 Code of Federal Regulations Section 403.5 (40 CFR § 403.5) for a complete list.
Exhibit 4. Conditions That Make Your Shop Subject to SIU Permit
Requirements
If your shop meets at least one of the following criteria, you should check with the local POTW or state
to receive information about obtaining a permit:
Discharges an average of 25,000 gallons or more per day of process wastewater (excluding
sanitary and noncontact wastewater)
Contributes a process waste stream that makes up 5 percent or more of the average dry
weather hydraulic or organic capacity of the POTW treatment plant
Is determined to have a reasonable potential for adversely affecting the POTW's operation or
for violating any pretreatment standard or requirement
Is subject to categorical pretreatment standards (as stated previously, none has been
established for lithographic printers).
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Exhibit 5. Reporting Requirements For All Indirect Dischargers
Requirement*
Notify the POTW or state immediately of a wastewater discharge that could
cause problems to the POTW, including slug loading (defined as any relatively
large release of a pollutant that might not ordinarily cause a problem when
released in small quantities), spills, and unpermitted pollutants.
Notify the POTW or state of a substantial change in your shop's wastewater
discharge.
Notify the POTW, state hazardous waste authorities, and EPA Regional Waste
Management Division Director of the Office of Site Remediation and Restoration
of a hazardous waste discharge. This is a one-time written notification required
of those who discharge more than 15 kg (33 Ibs) of a hazardous waste in a
month, or, if the waste is acutely hazardous, any amount that is discharged.
Contact EPA, or see 40 CFR Part 261 , for what must be included in the written
notification. Note: A list of acutely hazardous wastes is presented in 40 CFR
§ 261.30(d) and 40 CFR § 261.33(e).
Time Frame
Immediately
Prior to the change
One-time written
notification for each
hazardous waste
discharge
For a complete list of reporting requirements, see 40 CFR § 403.12.
How to Comply If You Discharge Wastewater
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4.4 WHAT MUST I Do IF I
DISCHARGE TO A SEPTIC SYSTEM
OR OTHER SUBSURFACE
WASTEWATER DISPOSAL
SYSTEM?
The Safe Drinking Water Act established the
basic framework for protecting the drinking water
of the United States. This act requires EPA to
regulate underground injection of waste fluids
through subsurface wastewater disposal
systems, such as your septic system, that
discharge waste into, or above, the underground
sources of drinking water. These regulations,
often referred to as the Underground Injection
Control (UIC) Regulations, are designed to
protect the country's drinking water supply. EPA
has authorized all six of the New England states
to implement the UIC program.
Industry and commercial businesses commonly
operate subsurface wastewater disposal
systems. These disposal systems can include
septic systems, leach fields, leaching pits and
trenches, dry wells, cesspools, and wastewater
disposal wells. Subsurface disposal systems
can pose a significant threat to underground
sources of drinking water because they are
numerous, often are located near public water
supplies, and are used to dispose of a wide
range ot nonhazardous and hazardous wastes.
It is important to know what you discharge to
your subsurface wastewater disposal
system. Wastes discharged to these disposal
systems typically include liquid waste, process
wastewater, non-contact cooling water, sewage,
and storm water. Fluid wastes of this sort
commonly contain wash water, spill drainage,
and storm water from maintenance areas,
hazardous substance storage areas, processing
and manufacturing areas, and fueling areas and
are susceptible to contamination by hazardous
materials and wastes. If your wastewater
disposal system(s) is not connected to a
municipal sewer or does not discharge to a
surface water, you may be using a septic system
or other subsurface wastewater disposal system
to dispose of your waste.
Your state regulates your subsurface wastewater
disposal system(s). If you use a septic system
or other subsurface wastewater disposal system:
/ You may not discharge hazardous waste
from your lithographic printing operations
to your subsurface disposal system.
Subsurface discharges of hazardous
materials and wastes that render drinking
water undrinkable or that endanger public
health are prohibited by law. (See
Chapter 5 to determine which of your
printing wastes are hazardous.)
/ You must obtain a permit from your state.
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/ If your facility disposes of sewage that is
generated by 20 or more people per day to a
septic system or other subsurface
wastewater disposal system, you are subject
to DIG regulations, even if you do not
discharge industrial wastewater to the
disposal system. Contact your state UIC
program to get more information about
applicable UIC regulations. (Please refer to
your state's requirements provided in the
pocket at the end of this manual.)
/ You may not discharge hazardous wastes
into your septic system or other
subsurface wastewater disposal system.
Discharge of hazardous waste is prohibited
by law. If any amount of hazardous waste is
discharged to a subsurface wastewater
disposal system, you must stop the discharge
and immediately notify your state UIC
program. (Please refer to your state's
requirements provided in the pocket at the
end of this manual.)
4.5 WHAT MUST I Do IF I
DISCHARGE To SURFACE
WATER?
Any wastewater (excluding storm water, which is
discussed below) from your shop that is
discharged directly into surface water, including
a pond, lake, river, tributary to a river, wetland,
and ocean, requires you to apply for and obtain a
permit under the National Pollutant Discharge
Elimination System (NPDES) program. An
NPDES permit sets limits on the amounts of
pollutants that can be discharged to surface
waters. The NPDES permit system is designed
to protect the quality of the water bodies into
which wastewater is discharged. Consequently,
stringent limits are imposed on the amounts and
concentrations of the pollutants that may be
discharged.
NPDES Permits. The NPDES program is
implemented either by EPA or by states running
an equivalent EPA-approved program.
Therefore, your facility may be required to submit
an application and receive a permit from EPA or
the state. Please refer to Section 4.6 to
determine if you should apply to EPA or your
state for a general or individual NPDES permit.
In addition, in states where EPA is the permit-
issuing authority, the states have separate
wastewater permit requirements and issue their
own additional permits.
If your lithographic print shop is required to get
an NPDES permit, your permit will:
Specify the amount of pollutants that you can
discharge, depending on either the
wastewater treatment technology in your shop
or on the specific water quality standards of
the body of water to which your shop
discharges, whichever is more protective of
the environment.
Require that you routinely conduct monitoring
and submit reports (generally on a monthly
schedule). Such requirements are
determined on a facility-specific basis;
.however, some reporting requirements apply
to all facilities.
Require that you maintain all monitoring
records for at least 3 years.
Contain other site-specific requirements,
including:
- Construction schedules
- Best management practices
- Whole effluent toxicity testing
- Spill prevention plans.
Storm Water NPDES Permits. Certain
industrial facilities that discharge storm water
must apply for a storm water permit. You must
obtain a storm water NPDES permit if the
answer to all three of the following questions
is YES:
1. Do you have a storm water discharge?
The answer is YES if there is a positive
collection or conveyance system, and it
culminates at a point source (e.g., a pipe, ditch,
channel, tunnel well, or container). A positive
collection or conveyance system is any type of
system that is meant to collect storm water and
remove it off-site (e.g., parking lot drains or
ditches to convey storm water off-site).
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2. Does this point source discharge to regulated
waters?
The answer is YES if the storm water is
discharged to a surface water, or if it is
discharged to a separate storm sewer, which is
then discharged to surface waters. Surface
water is defined broadly and includes rivers,
ponds, oceans, and wetlands.
3. Do you conduct an industrial activity subject
to the regulations?
As a lithographic printer, your Standard Industrial
Classification (SIC) code is 27 (or possibly 26),
so the answer is YES. For industries in this
group, you have to ask one more question: Is
there exposure or potential exposure of input
materials, finished products, byproducts, or
material handling equipment to storm water? If
the answer is YES to this final question and this
storm water is discharged to surface waters, you
are subject to the storm water regulations and
must obtain a storm water permit.
If you are unsure about whether you should
answer yes to any of the above, or you are
unclear about whether you have a point source
or discharge into surface water, call one of the
resources listed at the end of this chapter.
/ Ensure that your shop meets the effluent
limits in your NPDES permit. Conduct
monitoring, reporting, and recordkeeping
activities for your permitted discharges
(wastewater and/or storm water).
/ Notify the permitting authority:
- Of a noncompliance that has occurred
with your wastewater discharge that
may endanger health or the
environment within 24 hours of
becoming aware of the violation and in
writing within 5 days
- Of any planned physical alterations or
additions that may affect your
wastewater discharge at your shop as
soon as possible
- Of any planned changes in your
wastewater discharge that may result
in noncompliance (advance notice
required)
- Of the transfer of the facility to a new
owner as soon as possible in advance
of the transfer.
How to Comply If You Discharge to Surface
Water
/ Apply for and obtain an NPDES permit for
wastewater and, if applicable, for storm
water. Contact EPA or your state regulatory
agency to find out how to obtain an NPDES
permit application for wastewater and/or
storm water discharges. (Please refer to your
state's requirements provided in the pocket at
the end of this manual.)
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4.6 GOOD ENVIRONMENTAL MANAGEMENT PRACTICES
Here are some tips on good environmental management practices that could help save you money and
improve your operations:
Manage silver-bearing wastewater properly. Do not put untreated fixer down the drain. Reclaim
and recycle the silver prior to wastewater discharges (see methods described in Section 4.7).
If you use a silver recovery unit, operate and maintain it according to the manufacturer's
specifications.
Place signs near all sinks and drains in the work area prohibiting disposal of press-cleaning
solvents, inks, and untreated silver-bearing waste. (Remove or photocopy the sample signs
found on the next two pages, and place above or near the sinks and drains in your shop.)
Properly manage wastewater discharges to septic systems. Ensure that you have the proper
permits. It is good practice to avoid discharging process chemicals to your septic system.
Never discharge industrial wastewater to floor drains!
Extend the lives of photoprocessing baths by adding replenishers and regenerators.
Keep process baths covered to preserve their quality and life.
Reduce drag-in of contaminants by using a squeegee on film between baths. Reduce drag-out
of solution by adding drip boards and extending drip time.
Use non-hazardous developers and finishers.
Add glass marbles to developer solution to bring the liquid level up to the brim to reduce
oxidation.
How Do I Comply With Wastewater Discharge Regulations? 20
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4.7 POLLUTION PREVENTION OPPORTUNITIES FOR WASTEWATER DISCHARGES
This section describes pollution prevention (P2) opportunities that can reduce wastewater discharges.
Information on whether the technique is easy or more difficult to use is included next to each listing,
followed by a description of the technique and its benefits. Each discussion provides information on the
relative cost of the technique and the waste stream that can be reduced using each technique, where
possible. For more information, please contact the individuals listed in Chapter 9.
Extending Bath Life Easy
Technique: To reduce generation of waste and fixer solution, this P2 technique can be implemented
with no capital expenditure and no equipment modifications by your print shop.
You can extend the life of your fixer bath by the following activities:
Adding ammonium thiosulfate (hypo), which doubles the allowable concentration
of silver buildup in the bath.
Using an acid stop bath prior to the fixing bath if you do tray processing.
Adding acetic acid to the fixing bath as needed to keep the pH low.
Changing the fixer bath solution only when it is no longer effective,
rather than changing photoprocessing fixer bath solutions on a set
schedule. Manufacturer chemistry replenishment schedules are
typically conservative; therefore, you may be discarding bath
solution as waste when it is still effective.
You should discuss these options with your vendors to see what will work for your shop.
Benefits: Cost savings on the purchased fixer.
Decrease in the volume of waste fixer solution generated.
Increase in employee safety because of reductions in the number of changeouts
and, therefore, reductions in employee handling of and exposure to bath solution
chemicals.
Costs: Use of these techniques can increase the chemical concentrations in your baths.
Thus, if you discharge wastewater to your local POTW, your NPDES permit limits
or treatment practices may be affected. Contact your wastewater treatment plant
or, if you are a direct discharger, EPA or the state, for guidance prior to making
these changes.
Wash Water Control Units Easy
Technique: This P2 technique will assist you in reducing your fresh water use and wastewater
generation, which in turn will result in cost savings to your print shop and decreased
demands on the POTW to process your wastewater. Many automatic photoprocessors
provide a continuous flow of fresh water across the film, while others require continuous
replenishment of a wash bath when film is processed. A wash water control unit can be
added to automatic photoprocessors to reduce fresh water use. A wash water control unit
is basically an electronic valve that only turns on when film is being processed. Wall-
mounted control units, which control the flow and temperature of the water to the wash
bath, can be installed with any photoprocessor.
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Benefits: Cost savings can be realized from decreased fresh water use and reduced
wastewater discharge. Here is an example to help you determine your cost
savings from the use of a wash water control unit:
ABC Photoprocessqr uses up to 2.6 gallons of wash water per
minute. If the wash water were allowed to run for an 8-hour
period, up to 1,248 gallons of water would be required. If running
water is needed for only 10 percent of the 8-hour period, a
control unit could reduce water consumption by up to 1,124
gallons.
Assuming a savings of up to 1,120 gallons of water per day, at a
cost of $1.02 per unit (1 unit is 100 ft3), a savings of up to $45 per
month (up to $540 per year) would be realized. Wastewater
discharge savings may amount up to $190 per month (up to
$2,280 per year), at a discharge fee of $4.25 per unit. Your
payback period to recover the cost of the unit could be less than
1 year.
Costs: A water control unit costs approximately $1,200.
Wash Water Recirculation Units Moderate
Technique: This pollution prevention technique will assist you in reducing your fresh
water use and wastewater generation, which in turn will result in cost
savings to your print shop and decreased demands on the POTW to
process your wastewater. Water recirculation units can be installed to
reuse photoprocessing wash water in film and plating processing
equipment.
Benefits: Reduces fresh water use, wastewater discharge, and energy
consumption associated with heating the wash water baths.
Costs: The costs associated with installing water recirculation units vary among print
shops. Capital expenditures are required for:
The water recirculation unit (a minimum of $500)
Replumbing of the wash water bath system
Ongoing operation and maintenance.
Use of these techniques can increase the chemical concentrations in your baths.
Thus, if you discharge wastewater to your local POTW, your NPDES permit limits
or treatment practices may be affected. Contact your wastewater treatment plant
or, if you are a direct discharger, EPA or the state, for guidance prior to making
the changes.
Filters from the water recirculation units require disposal and may be considered
hazardous waste in some states (check with your state agency).
Countercurrent Washes Moderate
Technique: This pollution prevention technique will assist you in reducing your fresh water use and
wastewater generation, which in turn will result in cost savings to your print shop and
decreased demands on the POTW to process your wastewater. In tray processing,
countercurrent washing can replace commonly used parallel tank systems.
Countercurrent washing is done by using rinse water in the initial film wash and
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Benefits:
Costs:
introducing fresh water only at the final rinse stage when much of the contamination has
already been rinsed off the film.
Reduces the amount of contamination in processing solutions and conserves
water.
Reduces the volume of fresh water used.
Reduces the volume of wastewater generated. You can achieve dramatic
reductions of up to 90 percent water use with this method. Combining
countercurrent washing and automatic controls can cut water use by 99 percent.
Because water and sewer use rates are increasing, these techniques will yield
short payback periods.
The countercurrent washing system requires more space and equipment.
Capital expenditures are required for:
- Equipment maintenance
- Secondary containment to protect the shop in the event of a spill.
Employees will need to learn proper mixing of chemistry.
Silver Recovery
Silver recovery can be performed either at your print shop or at an off-site recycling facility to reduce silver
from your wastewater and generate revenue from the recovery of this metal. This discussion highlights
four methods (three on-site and one off-site):
On-site methods
Metallic replacement cartridges
Ion exchange and chemical precipitation
Electrolytic silver recovery
Off-site methods
Fixer recycling.
Many printers have determined on-site recovery to be cost-effective compared to disposal costs. Reverse
osmosis is another method of silver recovery that is not discussed here because of its costs.
ON-SITE METHODS
Easy
Technique: Metallic replacement cartridges -- Silver can be recovered from fixer bath solution
through use of a metallic replacement cartridge at your print shop before the solution is
discharged to the sewer. As wastewater passes through the cartridge, iron replaces the
silver in solution, and the silver settles out as a solid. The metallic replacement cartridge
must then be processed off-site to reclaim the collected silver.
Cartridges containing steel wool are connected to the fixer bath overflow in order to trap
silver. Silver concentrations can be reduced by up to 99 percent if two cartridges are
used in series. Cartridges must be closely monitored to determine when they are spent in
order to prevent silver from being discharged to the sewer. Generally, a single cartridge
treats at least 150 gallons of fixer solution.
Benefits: Revenue can be generated from the sale of silver (approximately $70 per troy
ounce).
This method is readily available and in widespread use in the printing industry.
There are no energy needs or plumbing requirements.
Little maintenance is required.
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Costs: Capital expenditures for the initial metallic replacement cartridge hookup are
generally less than $50.
Ongoing expenses will include 1) the cost of replacement metallic cartridges at
approximately $50 for a 5-gallon cartridge and 2) cartridge collection and
processing ($75 refining fee in addition to an average $125 collection fee per 5-
gallon cartridge). Cartridges cannot be reused.
Recovery fees may exceed revenues from silver because of the small amount of
silver recovered. The cost per gallon of fixer solution is estimated at $1.60.
The wastewater that results contains high iron concentrations.
Moderate
Technique: Electrolytic silver recovery is a pollution prevention technique that can be performed at
your printing facility to recover silver in nearly pure form from wastewater discharges.
Two types of electrolytic silver recovery units (SRUs) use a controlled current to remove
silver from wastewater solutions:
A recirculating 3RD is placed "in line" as part of the fixer recirculating system. A
recirculating SRU prolongs the effectiveness of the fixer bath by filtering silver to
reduce its concentration and replenishing the fixer, thereby reducing the fixer
replenishment rate by 60 to 90 percent.
A terminal SRU is connected to the overflow discharge hoses of the process.
Fixer solution passes through the SRU, where the silver is collected. A terminal
SRU may also require a backup metallic replacement cartridge in order to meet
applicable local sewer use limits.
Both types of units may have either a stationary or rotating cathode. Silver is periodically
scraped off the cathode and collected for pickup by a metals recycler.
Benefits: Typically, recirculating SRUs remove up to 90 percent of the silver from fixer bath
solutions. Revenue can be generated from sale of the silver.
It can minimize silver carried into the wash tank.
Costs: De-silvered fixer can be reused, thereby reducing fixer chemistry costs.
A rotating cathode removes more silver but requires additional maintenance
because it has more moving parts than a stationary cathode.
Capital expenditures include the purchase of an SRU and the replumbing to
install the unit.
There are operation and maintenance costs.
An SRU can cost between $700 and $2,000, and recycler fees vary according to
the monthly use of fixer.
pH must be closely monitored.
Challenging
Technique: Ion exchange is done by passing wastewater through a number of ion-exchange resins,
or by using a strong base-gel anion resin, to selectively remove the silver. The resins are
then sent off-site for silver recovery. It is important to choose the correct resin to
maximize efficiency of this operation. (Ion exchange is usually a secondary or tertiary
process, following electrolytic recovery and/or use of metallic replacement cartridges,
because it is best for silver recovery from dilute solutions.)
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Ion exchange can be followed by chemical precipitation, in which chemicals (e.g.,
sulfide) are added to wastewater to precipitate silver chloride out of the solution. For this
reason, ion exchange is cost effective for larger shops only.
Benefits: Revenue can be generated from the sale of silver (approximately $70 per troy
ounce).
It can help achieve low silver concentrations in wastewater.
Costs: Automated ion exchange units are only cost effective for processing large
amounts of wastewater, because of their high cost. A small unit can cost $3,000
to $5,000.
The cost of chemicals for precipitation, holding tanks, and supplemental heat
input can make this somewhat costly.
Employee training or use of chemicals add other costs.
OFF-SITE METHODS
Easy
Technique: Fixer recycling can be performed at an off-site licensed recycling facility to recover silver
from wastewater discharges. Fixer bath solution is collected at the print shop and is sent
to a fixer recycler. The recycler recovers the silver and, in some cases, regenerates the
fixer. The recycler must send the silver to a reclamation facility for processing.
Benefits: Revenue can be generated from the sale of silver (approximately $70 per troy
ounce).
Cost savings can be realized from reduced fixer purchases.
Costs: The cost of collecting the fixer solution and sending it to an off-site treatment
facility may cost more than $2 per gallon.
Material Substitution Moderate
Technique: By using fewer and nonhazardous input materials, you will generate less hazardous and
nonhazardous wastes.
Nonhazardous chemical substitutes may be available to replace hazardous chemicals
currently used at your shop. Because many are available, you should ask your vendors to
provide you with information about nonhazardous or less toxic chemicals. Examples
include:
Prepress chemistry that eliminates the use of formaldehyde.
Photographic intensifies and reducers that do not contain mercury or
cyanides.
Nonhazardous aerosols, although you should limit your use of aerosols or
switch to non-aerosol products, such as manual pump cans or bottles,
especially if they can be refilled. (Always return defective cans to your
vendor.)
Pre-sensitized plates should be used as an alternative to metal-etched plates because
they are nonhazardous and can be recycled for aluminum content. The pre-sensitized
plates should be stored under the recommended conditions to maintain effectiveness.
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Silverless films are beginning to appear on the market. The benefit of their use is that
they typically produce nonhazardous fixer wastes. However, they do require a large
capital investment in new technology. As this technology advances, they may become a
more viable option for printers.
Benefits: Reduces the volume of wastewater generated.
Reduces the volume of hazardous waste generated.
Electronic Imaging and Laser Platemaking Challenging
Technique: Computerized electronic prepress systems are now available for image processing.
Using an electronic scanner, text, photos, graphics, and layout are entered into the
system. The copy is edited on the display monitor rather than on paper.
Benefits: The reduction in the quantity of film, developing chemicals,
and paper used during image processing, will, in turn, reduce
the amount of waste film, waste paper, waste chemicals,
wastewater, and hazardous waste generated.
This technique should increase productivity because of the ( JH
reduced manual labor required for image processing.
Costs: This technique requires extensive research and evaluation to determine what
systems would be right for your operations.
A large capital investment is required for the purchase of the computer hardware
and software. Electronic prepress systems were initially restricted to large
printing facilities because of the high initial capital investment. As computer
hardware and software prices become more reasonable, smaller printing facilities
will be better able to afford this technique.
How Do I Comply With Wastewater Discharge Regulations? 30
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5. How Do I COMPLY WITH HAZARDOUS WASTE REGULATIONS?
As a printer, you produce wastes that could be
hazardous. Therefore, it is important that you
identify and manage them properly to protect
yourself, coworkers, and others in your
community, as well as the environment. As the
waste generator, you are responsible for all
steps in hazardous waste management, from
generation to final disposal.
You can be held liable for any
mismanagement of your wastes, even after
they leave your facility. So, it is important for
you to know the facts.
This chapter explains the hazardous waste law,
known as the Resource Conservation and
Recovery Act (RCRA), and its regulations which
impose many requirements on how you must
handle and dispose of the wastes you generate
in your print shop. Sections 5.1 through 5.3
focus on the major federal requirements with
which you must comply. In many instances, the
states impose additional and more stringent
requirements on how you handle your wastes. It
is critical, therefore, that you review your state's
requirements provided in the pocket at the end
of this manual and contact your state
environmental agency (numbers and addresses
are listed in the pocket at the end of this manual)
for any additional requirements. Sections 5.4
and 5.5 present information on good
environmental management and pollution
prevention techniques that address hazardous
waste.
Here are the steps you should follow to ensure
compliance with this law and to prevent pollution:
Determine whether you have hazardous waste
at your print shop.
Determine your hazardous waste generator
status.
Meet the eight major requirements for
hazardous waste generators.
Practice good environmental management.
Prevent pollution from hazardous waste.
Determine your state's hazardous waste
requirements.
5.1 Do I HAVE HAZARDOUS WASTES
AT MY PRINT SHOP?
Since you are a printer, the answer will probably
be "yes." Hazardous waste is generated during
many lithographic printing operations. The
following lists will give you an idea of the types of
waste you may be generating. (Note: Because
each lithographic print shop is unique, this is
not all inclusive.) Exhibit 2 (see Chapter 3)
presents a profile of typical hazardous waste
generated by lithographic printing operations.
Some materials that may be familiar to you and
that may be considered hazardous wastes
depending on the state you are in include:
Spent untreated fixer solution/silver-bearing
photographic wastes
Non-empty aerosol cans
Certain discarded or unused chemicals
Waste solvent-based inks
Spent cleaning solvents
Used parts washer solvent
Solvent-contaminated rags
Proofing system chemicals.
An important source of information about the
chemicals you use is the Material Safety Data
Sheet (MSDS). The MSDS is provided by your
chemical supplier and gjves general health and
safety information about handling these
chemicals. These MSDSs will not provide you
with all of the answers to your environmental
questions, but they can help you identify your
hazardous waste. Exhibit 6 provides a sample
MSDS. As you can see, properties of a
chemical, such as its pH or flashpoint, are
included on an MSDS. To ensure that your
MSDSs are current, require your vendors to
automatically supply you with an MSDS with new
products and to have anyone approving
purchases in your business ask for them from
the supplier.
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Exhibits. Sample MSDS
MSDS for ISOPROPYL ALCOHOL
1 - PRODUCT IDENTIFICATION
PRODUCT NAME: ISOPROPYL ALCOHOL
FORMULA: CH3CHOHCH3
FORMULA WT: 60.10
CAS NO.: 67-63-0
NIOSH/RTECS NO.: NT805000
COMMON SYNONYMS: 2-PROPANOL; ISOPROPANOL; SEC-PROPYL ALCOHOL; IPA;
DIMETHYLCARBINOL
PRODUCT CODES: U298,5082,9080
EFFECTIVE: 09/03/86
REVISION #02
PRECAUTIONARY LABELING:
BAKER SAF-T-DATA (TM) SYSTEM
HEALTH - 1 SLIGHT
FLAMMABILITY - 3 SEVERE (FLAMMABLE)
REACTIVITY - 1 SLIGHT
CONTACT - 1 SLIGHT
HAZARD RATINGS ARE 0 TO 4 (0 = NO HAZARD; 4 = EXTREME HAZARD).
LABORATORY PROTECTIVE EQUIPMENT:
- SAFETY GLASSES
LAB COAT
VENT HOOD
PROPER GLOVES
CLASS B EXTINGUISHER.
PRECAUTIONARY LABEL STATEMENTS:
WARNING
FLAMMABLE
CAUSES IRRITATION
HARMFUL IF SWALLOWED OR INHALED
KEEP AWAY FROM HEAT, SPARKS, FLAME
AVOID CONTACT WITH EYES, SKIN, CLOTHING
AVOID BREATHING VAPOR
KEEP IN TIGHTLY CLOSED CONTAINER
USE WITH ADEQUATE VENTILATION
WASH THOROUGHLY AFTER HANDLING
IN CASE OF FIRE, USE ALCOHOL FOAM, DRY CHEMICAL, CARBON DIOXIDE - WATER
MAY BE INEFFECTIVE
FLUSH SPILL AREA WITH WATER SPRAY.
SAF-T-DATA(TM) STORAGE COLOR CODE: RED (FLAMMABLE)
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Exhibit 6. Sample MSDS (continued)
2 - HAZARDOUS COMPONENTS
COMPONENT % CAS NO.
ISOPROPYL ALCOHOL 90-100 67-63-0
3 - PHYSICAL DATA
BOILING POINT: 82°C (180°F) VAPOR PRESSURE (MM HG): 33
MELTING POINT: -89°C (-128°F) VAPOR DENSITY (AIR=1): 2.1
SPECIFIC GRAVITY: 0.79 EVAPORATION RATE: 2.83
(H2O=1) (BUTYL ACETATE=1)
SOLUBILITY (H2O): COMPLETE (IN ALL PROPORTIONS) % VOLATILES BY VOLUME: 100
APPEARANCE & ODOR: COLORLESS LIQUID WITH SLIGHT ODOR OF RUBBING ALCOHOL
4 - FIRE AND EXPLOSION HAZARD DATA
FLASH POINT (CLOSED CUP): 12°C(53°F) NFPA 704M RATING: 1-3-0
FLAMMABLE LIMITS: UPPER - 12.0% LOWER - 2.0%
FIRE EXTINGUISHING MEDIA:
USE ALCOHOL FOAM, DRY CHEMICAL OR CARBON DIOXIDE. (WATER MAY BE INEFFECTIVE.)
SPECIAL FIRE-FIGHTING PROCEDURES:
' FIREFIGHTERS SHOULD WEAR PROPER PROTECTIVE EQUIPMENT AND SELF-CONTAINED
BREATHING APPARATUS WITH FULL FACEPIECE OPERATED IN POSITIVE PRESSURE MODE
MOVE CONTAINERS FROM FIRE AREA IF IT CAN BE DONE WITHOUT RISK
USE WATER TO KEEP FIRE-EXPOSED CONTAINERS COOL.
UNUSUAL FIRE & EXPLOSION HAZARDS:
- VAPORS MAY FLOW ALONG SURFACES TO DISTANT IGNITION SOURCES AND FLASH BACK
CLOSED CONTAINERS EXPOSED TO HEAT MAY EXPLODE
CONTACT WITH STRONG OXIDIZERS MAY CAUSE FIRE.
TOXIC GASES PRODUCED:
CARBON MONOXIDE, CARBON DIOXIDE
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Exhibit 6. Sample MSDS (continued)
5 - HEALTH HAZARD DATA
THRESHOLD LIMIT VALUE (TLV/TWA): 980 MG/M3 (400 PPM)
SHORT-TERM EXPOSURE LIMIT (STEL): 1225 MG/M3 (500 PPM)
PERMISSIBLE EXPOSURE LIMIT (PEL): 980 MG/M3 (400 PPM)
TOXICITY: LD50 (ORAL - RAT) (MG/KG) - 5045
LD50 (IPR - MOUSE) (MG/KG) - 933
LD50 (SKN - RABBIT) (G/KG) -13
LD 50 (IV - MOUSE) (MG/KG) - 1863
CARCINOGENICITY: NTP: NO
IARC: NO
Z LIST: NO
OSHA REG: NO
EFFECTS OF OVEREXPOSURE:
INHALATION OF VAPORS MAY CAUSE HEADACHE, NAUSEA, VOMITING, DIZZINESS,
DROWSINESS, IRRITATION OF RESPIRATORY TRACT, AND LOSS OF CONSCIOUSNESS.
INHALATION OF VAPORS MAY CAUSE PULMONARY EDEMA.
LIQUID MAY BE IRRITATING TO SKIN AND EYES. PROLONGED SKIN CONTACT MAY RESULT
IN DERMATITIS. EYE CONTACT MAY RESULT IN TEMPORARY CORNEAL DAMAGE.
INGESTION MAY CAUSE NAUSEA, VOMITING, HEADACHES, DIZZINESS, GASTROINTESTINAL
IRRITATION.
INGESTION MAY CAUSE CENTRAL NERVOUS SYSTEM DEPRESSION.
TARGET ORGANS
EYES, SKIN, RESPIRATORY SYSTEM
MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE
NONE IDENTIFIED
ROUTES OF ENTRY
INHALATION, INGESTION, EYE CONTACT, SKIN CONTACT
EMERGENCY AND FIRST AID PROCEDURES
CALL A PHYSICIAN
IF SWALLOWED, DO NOT INDUCE VOMITING
IF INHALED, REMOVE TO FRESH AIR. IF NOT BREATHING, GIVE ARTIFICIAL RESPIRATION.
IF BREATHING IS DIFFICULT, GIVE OXYGEN.
IN CASE OF CONTACT, IMMEDIATELY FLUSH EYES WITH PLENTY OF WATER FOR AT LEAST
15 MINUTES. FLUSH SKIN WITH WATER.
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Exhibit 6. Sample MSDS (continued)
6 - REACTIVITY DATA
STABILITY: STABLE HAZARDOUS POLYMERIZATION: WILL NOT OCCUR
CONDITIONS TO AVOID: HEAT, FLAME, OTHER SOURCES OF IGNITION
INCOMPATIBLES: STRONG OXIDIZING AGENTS, ALUMINUM, NITRIC ACID, SULFURIC
ACID, AMINES AND AMMONIA, HALOGEN ACIDS AND HALOGEN
COMPOUNDS
DECOMPOSITION PRODUCTS: CARBON MONOXIDE, CARBON DIOXIDE
7 - SPILL AND DISPOSAL PROCEDURES
STEPS TO BE TAKEN IN THE EVENT OF A SPILL OR DISCHARGE:
WEAR SUITABLE PROTECTIVE CLOTHING
SHUT OFF IGNITION SOURCES; NO FLARES, SMOKING, OR FLAMES IN AREA
STOP LEAK IF YOU CAN DO SO WITHOUT RISK
USE WATER SPRAY TO REDUCE VAPORS
TAKE UP WITH SAND OR OTHER NON-COMBUSTIBLE ABSORBENT MATERIAL AND PLACE
INTO CONTAINER FOR LATER DISPOSAL
FLUSH AREA WITH WATER.
J.T. BAKER SOLUSORB(R) SOLVENT ADSORBENT IS RECOMMENDED FOR SPILLS OF THIS
PRODUCT.
DISPOSAL PROCEDURE:
DISPOSE IN ACCORDANCE WITH ALL APPLICABLE FEDERAL, STATE, AND LOCAL
ENVIRONMENTAL REGULATIONS.
EPA HAZARDOUS WASTE NUMBER: D001 (IGNITABLE WASTE)
8 - PROTECTIVE EQUIPMENT
VENTILATION:
USE GENERAL OR LOCAL EXHAUST VENTILATION TO MEET TLV REQUIREMENTS.
RESPIRATORY PROTECTION:
RESPIRATORY PROTECTION REQUIRED IF AIRBORNE CONCENTRATION EXCEEDS TLV. AT
CONCENTRATIONS UP TO 1000 PPM, A CHEMICAL CARTRIDGE RESPIRATOR WITH ORGANIC
VAPOR CARTRIDGE IS RECOMMENDED. ABOVE THIS LEVEL, A SELF-CONTAINED BREATHING
APPARATUS IS RECOMMENDED.
EYE/SKIN PROTECTION:
SAFETY GOGGLES, UNIFORM, APRON, AND NEOPRENE GLOVES ARE RECOMMENDED.
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Exhibit 6. Sample MSDS (continued)
9 - STORAGE AND HANDLING PRECAUTIONS
SAF-T-DATA(TM) STORAGE COLOR CODE: RED (FLAMMABLE)
SPECIAL PRECAUTIONS:
BOND AND GROUND CONTAINERS WHEN TRANSFERRING LIQUID
KEEP CONTAINER TIGHTLY CLOSED
STORE IN A COOL, DRY, WELL-VENTILATED, FLAMMABLE LIQUID STORAGE AREA.
10 - TRANSPORTATION DATA AND ADDITIONAL INFORMATION
DOMESTIC (D.O.T.)
PROPER SHIPPING NAME:
HAZARD CLASS:
UN/NA:
LABELS:
INTERNATIONAL (I.M.O.)
PROPER SHIPPING NAME:
HAZARD CLASS:
UN/NA:
LABELS:
ISOPROPANOL
FLAMMABLE LIQUID
UN1219
FLAMMABLE LIQUID
ISOPROPANOL
3.2
UN1219
FLAMMABLE LIQUID
What Is Hazardous Waste?
Generally, waste is defined as:
Any solid, liquid, or contained gaseous materials
that you no longer intend to use and that you
store, dispose or recycle.
A waste is hazardous if it:
Is listed in the regulations
Exhibits hazardous characteristic(s).
Each hazardous waste has a code that you must
use as you document shipment of your waste
off-site.
LISTED WASTE
A waste is considered a listed waste because it
either exhibits one of the characteristics
described below or contains any number of toxic
constituents that have been shown to be harmful
to human health and the environment. Any
nonhazardous materials that are
contaminated with listed waste are
considered listed waste.
The types of listed hazardous waste that you
may generate include:
Waste solvents (e.g., toluene, xylene, acetone,
and methyl isobutyl ketone), which are
classified as "F" wastes
Unused, discarded or off-specification
materials (e.g., unused methanol), which may
be classified as "U" wastes.
CHARACTERISTIC WASTE
A waste is considered characteristic because it
exhibits one or more of the four defined
hazardous characteristics, as follows:
Ignitable (D001) - Easily catches fire;
flashpoint is below 140° F. (See your MSDS.)
Please note that the terms "combustible,"
"flammable," and "ignitable" have different
definitions under other federal and state
regulations, so they cannot be used
interchangeably. An example of a D001 waste
is isopropyl alcohol.
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Corrosive (D002) - Aqueous liquids (liquids
containing water) that easily corrode materials
(e.g., metal drums) or human tissue and have
a pH of less than or equal to 2 or greater than
or equal to 12.5. An example is waste battery
acid.
Reactive (D003) -- Potentially explosive or
produces toxic gases when mixed with water,
air, or other incompatible materials. Printers
do not normally generate reactive wastes.
Toxic (D004-D043) -- If a chemical extract of
your waste contains specific constituents, such
as cadmium, chromium, or silver, and exceeds
specified levels, the waste is hazardous. The
waste code varies, depending on which
constituents are present. Examples include
plate processing chemicals and waste fixer.
Hazardous waste found in the printing industry is
most likely to be ignitable or toxic.
HAZARDOUS WASTE CODES
Specific hazardous waste types have designated
waste codes. A waste code is a four-digit
classification system used by the U.S.
Environmental Protection Agency (EPA) to
identify hazardous waste on labels, shipping
papers, and other records. All federal hazardous
waste codes begin with a letter and are followed
by numbers. All listed waste begins with the
lettered "F," "K," "U," or "P," and all characteristic
waste begins with the letter "D."
In order to determine what the waste code is for
your hazardous waste, you need to look at the
regulations. For the sake of brevity, we have
not included copies of any regulations in this
manual. You should call your state
environmental agency (see your state summary
page in the pocket at the end of this manual) to
determine where you can obtain a copy of your
state's regulations. They are typically available
at your State House book store.
5.2 WHAT Is MY HAZARDOUS
WASTE GENERATOR STATUS?
If you are a lithographic printer and your
operations cause hazardous waste to be
generated, you must now determine your
generator status.
Hazardous waste generators are divided into
different status categories, depending on the
quantity of hazardous waste generated each
month and on the total amount of hazardous
waste stored at the printing facility at any time.
The measured amount (by weight) of hazardous
waste generated at your facility per calendar
month determines which hazardous wastes
requirements and standards apply to you.
Exhibit 7 lists three federal categories of
hazardous waste generators. This chart is
included to illustrate the federal generation rates
and storage time limits applicable to certain
generator categories. It is important to note
that states may specify different categories
than those specified in the federal
regulations and that you must meet the
requirements specified for your state! Please
refer to your state's requirements in the
summary pages in the pocket at the end of
this manual.
To determine which category applies to your
shop, you must count all quantities of hazardous
waste that is:
Generated and collected at your shop prior to
treatment or disposal
Packaged and transported off-site.
From Exhibit 7, you can see that it pays to be in
one of the small quantity generator categories.
There is more leeway for storage time, which will
allow you to more cost-effectively manage your
smaller quantities of hazardous waste. Pollution
prevention can help you change your generator
status. Section 5.5 presents pollution prevention
techniques that may work at your shop.
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Your Generator Status
Now that you have accounted for all the
hazardous waste that your print shop generates
and you have consulted your state's regulations,
you can determine your generator status.
/ My generator status is:
Note: Because it is possible for your
generator status to change from year to year,
and even from month to month, it is very
important to keep an accurate accounting of
how much waste you have on-site at any
particular time.
Exhibit 7. Federal Categories of Hazardous Waste Generators and
Storage Time Limits Allowed
Generator Category
Conditionally Exempt
Small Quantity Generator
(CESQG)
Small Quantity Generator
(SQG)
Large Quantity Generator
(LQG)
Monthly Hazardous Waste
Generation Rate
< 220 pounds (100 kg),
< 2.2 pounds (1 kg) acute, or
< 220 pounds spill residue from
acute
> 220 pounds (100 kg) and <
2,200
pounds (1,000 kg) or
< 2.2 pounds (1 kg) acute
> 2,200 pounds (1,000 kg) or
> 2.2 pounds (1 kg) acute
Storage Time Limits
No Limit
<1 80 days or < 270 days if
waste
treatment/disposal facility is
>200
miles away
< 90 days
5.3 WHAT REQUIREMENTS MUST
HAZARDOUS WASTE
GENERATORS MEET?
Hazardous waste generators must comply with
eight major requirements:
Waste identification
EPA identification number
Container management
Personnel training
Hazardous waste shipment labeling and
placarding
Reporting and recordkeeping requirements
Contingency planning
Emergency procedures and accident
prevention.
Each requirement is explained below. Please
ensure that you have met each requirement and
refer to your state's requirements, presented in
the pocket at the end of this manual.
1. Waste Identification
As a generator, you must determine whether
your waste is hazardous. As explained in
Section 5.1, the MSDS for each chemical may
help you with this determination. The MSDS will
identify specific chemical properties of a
material, such as whether a material is highly
acidic or basic, whether solvents are present,
and other chemical properties, such as
ignitability (flashpoint).
/ Make a list of all the hazardous waste you
have at your shop and determine the waste
code for each.
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/ You may know that a waste is hazardous
because of information on a MSDS.
/ If you are not sure, you will need help. This
may mean calling EPA or your state, a
consultant, or a licensed transporter. Or, you
may need to send a sample of your waste to a
laboratory for them to determine if the waste is
hazardous.
2. EPA Identification Number
If your lithographic printing facility generates
more than 100 kg (about 220 pounds or 25
gallons) of hazardous waste in any calendar
month, you must obtain an EPA identification
number. These 12-character identification
numbers are part of a national database on
hazardous waste activities. Some states also
require conditionally exempt or very small
quantity generators to have identification
numbers. Furthermore, companies that
transport hazardous waste and facilities that
store, treat, or dispose of regulated quantities of
hazardous waste generated by lithographic
printing shops must also have EPA identification
numbers.
How to Obtain an EPA Identification Number
/ Call or write your state hazardous waste
management agency or EPA regional office
and ask for a copy of EPA Form 8700-12,
"Notification of Regulated Waste Activity."
You will be sent a booklet containing the two-
page form and instructions for filling it out.
Note that a few states use a form that is
different from the EPA form. If you contact
your state first, you will be sent the
appropriate form to complete.
/ Complete one copy of the form for each of
your printing shops where you generate or
handle hazardous waste. There is no fee
associated with filling out this form. Each site
or location will receive its own unique EPA
identification number. You must use this
identification number on all hazardous
waste shipping forms.
An EPA identification number is a unique
number that applies to a particular physical
printing facility site or location. If you move
your printing facility to another location, you
must notify EPA or the state of the new
location, submit a new form, and obtain a
new EPA identification number. If hazardous
waste was previously handled at the new
location and the new location already has an
EPA identification number, that number will be
reassigned to your relocated printing facility.
3. Container Management
The following list summarizes the most
significant requirements for managing containers
of hazardous waste, regardless of their size:
/ Set aside and mark a storage area for your
hazardous waste. This is your designated
on-site hazardous waste storage area, and
it is a collection area for your entire shop.
The length of time that you can store
hazardous waste in this area depends on
your generator category. The type of area
and marking requirements are set by your
state. (Please refer to your state's
requirements provided in the pocket at the
end of this manual.)
S Label and mark all containers of hazardous
waste in your hazardous waste storage area.
Clearly mark each container with the words
"HAZARDOUS WASTE" and with the date
the waste was first collected in that
container. (Labels for this purpose may be
available from the waste hauler or a trade
association.) When your waste is shipped
off-site, it is important that your transporter is
aware of and complies with Department of
Transportation marking requirements for the
truck used to haul your waste. Further, many
states require additional labeling, such as a
description of the contents of the container.
(Please refer to your state's requirements
provided in the pocket at the end of this
manual.)
/ You can accumulate up to 55 gallons of
hazardous waste in properly labeled
containers or drums at or near the various
parts of your shop where the waste is
generated. This is called satellite
accumulation. Once 55 gallons have
accumulated, satellite waste must be moved
to your designated on-site hazardous waste
storage area prior to shipment off-site.
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/ Containers in satellite accumulation areas
must be clearly marked with the words
"HAZARDOUS WASTE" or with other
wording that identifies the contents of the
container. Satellite waste must be moved
within 3 days to your shop's designated on-
Site hazardous waste storage area. The
operator of the process that generated the
waste is responsible for this container or
drum as long as it is kept separate from the
designated storage area; this operator must
control the waste accumulated there.
/ Mark the EPA waste code on the drum.
Although federal regulations do not require
marking the EPA waste code on the drum,
most states do require marking, and it is
highly recommended.
/ Keep containers in good condition, handle
them carefully, and replace any leaking ones.
If a container is in poor condition, the waste
must be transferred to a container in good
condition.
/ Use containers made of, or lined with,
materials that will not react with the waste.
Do not store hazardous waste in a container
if it may cause rupture, leaks, corrosion, or
other failure. For instance, store your fixer in
plastic drums and your flammable liquids,
such as solvents, in metal drums.
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4. Personnel Training
S If you are an LOG or an SQG of hazardous
waste, you must train your employees on the
procedures for properly handling hazardous
waste, as well as on emergency procedures.
For LQGs, the training must be formalized
and be completed by employees within 6
months of accepting a job involving the
handling of hazardous waste, and you are
required to provide annual reviews of the
initial training.
CESQGs or VSQGs are not required by
federal laws to train their employees on waste
handling or emergency preparedness, but it is
strongly advised!
Proper waste handling can save your shop
money in waste treatment and disposal and in
lost time due to employee illness or accidents.
For information on employee training, please
contact the federal or state agencies listed in
Chapter 9 and in the pocket at the end of this
manual. It is important to note that training you
may be required to conduct by OSHA (the
Occupational Safety and Health Administration)
differs from hazardous waste management
training. Make sure you provide both types of
training to your employees.
5. Hazardous Waste Shipment Labeling and
Placarding
When you prepare hazardous waste for
shipment, you must put the waste in properly
labeled containers that are appropriate for
transportation according to Department of
Transportation (DOT) regulations (see Chapter
9). Your transporter should be able to assist you.
If you are an SQG or LOG, you must:
/ Write the manifest document number on the
drum label. A blank space intended for this
purpose is provided on hazardous waste
labels available from label distributors.
/ Label all drums using the 4-inch DOT warning
labels (available from the waste hauler or a
label distributor), which are marked with the
proper DOT shipping name and number
according to DOT requirements. Usually your
hauler will do this.
If you need additional information, you may want
to consult the requirements for packaging and
labeling hazardous wastes contained in the DOT
regulations. To find out what the requirements
are for your specific waste, you should contact
your state transportation agency. Your state
transportation agency, your hauler, or your waste
disposal/treatment facility can help you
understand the DOT requirements. It may be
helpful for you to create a shipping manual with
guidance for packing, shipping, and
disposal/recycling of all wastes leaving your
facility.
6. Reporting and Recordkeeping
Requirements
Your printing facility is required to meet various
reporting and recordkeeping requirements as
part of your hazardous waste management
obligations. These requirements are
summarized below:
Uniform Hazardous Waste Manifest. The
Uniform Hazardous Waste Manifest Form (EPA
Form 8700-22) is a multi-copy shipping
document that reports the contents of the
shipment, the transport company used, and the
treatment/disposal facility receiving the wastes.
(Exhibit 8 provides a sample manifest.)
The manifest form is designed so that shipments
of hazardous waste can be tracked from the site
of generation to the final destination (i.e., from
"cradle-to-grave"). The hazardous waste
generator, the transporter, and the
treatment/disposal facility must each sign this
document and keep a copy. The waste
treatment/disposal facility also must send a copy
back to you, so that you can be sure that your
shipment was received.
It is important that you receive a signed copy of
the manifest from the company that takes your
waste. This is your proof that the waste made it
to the final destination. If you do not receive a
signed copy of the manifest within a reasonable
period of time, you may need to file an exception
report with EPA and state environmental
agencies. (This is a situation you may never
encounter. If you do, please contact EPA and
your state environmental agency for further
information.) The signed copy of the manifest is
required to be kept on file for 3 years.
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You can obtain blank copies of the manifest form
from several sources. To determine the best
source for you, use this system:
If the state to which you are shipping your
waste has its own manifest, use that manifest
form (your waste transporter will know which
manifest form is required). Contact the
hazardous waste management agency of that
state, your transporter, or the waste
treatment/disposal facility to obtain manifest
forms.
If the state to which you are shipping your
waste does not have its own manifest, use
the manifest of the state in which your waste
was generated. Contact your transporter or
your state hazardous waste agency for blank
forms.
If neither state requires a state-specific
manifest, you may use the "general" Uniform
Hazardous Waste Manifest (EPA Form 8700-
22). Copies are available from some haulers
and waste treatment/disposal facilities, or they
may be purchased from some commercial
printers.
When you sign the certification on Item 16 of the
manifest form (see Exhibit 8, presented
previously), you are personally confirming that:
The manifest is complete and accurately
describes the shipment.
The shipment is ready for transport.
You have reduced the amount and hazardous
nature of your waste to the greatest extent
possible (within your budget constraints).
Transporters, recyclers, and waste
treatment/disposal facilities may require
additional information. Check with them before
you prepare a hazardous waste shipment. The
states may also have additional requirements
that must be followed. Your hazardous waste
hauler often will be the best source for
packaging and shipping information and will help
in completing the manifest. If you have any
trouble filling out or using the manifest, ask your
waste transporter, your waste disposal/treatment
facility operator, or the appropriate contact listed
in your state summary page provided in the
pocket at the end of this manual.
Biennial Reports. If you are an LOG of
hazardous waste, you must submit a biennial
report (EPA Form 8700-13A) on March 1 of each
even-numbered year to the appropriate state
regulatory office. Some states impose this
requirement on SQGs.
Biennial Report applications and instructions can
be obtained from your state office (see your
state summary page in the pocket at the end of
this manual). Copies of biennial reports must be
maintained at your shop for 3 years.
Land Disposal Restriction Notification. Land
disposal restrictions are regulations prohibiting
the disposal of hazardous waste on land without
prior treatment of the waste. With every
shipment of your waste off-site, you will need to
provide a notification that specifies which of the
waste you have generated is restricted from land
disposal. This notification should be attached to
your hazardous waste manifest. This form
ensures proper treatment of the waste prior to
disposal; copies of each form must be kept for 5
years.
If you plan to ship wastes off-site for recycling,
then you may not need a Land Disposal
Restriction Notification form for every shipment.
For SQGs, a "tolling agreement" can be
developed for shipments after the initial
shipment. Please contact your state for more
information on these agreements and the land
disposal restrictions.
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Exhibit 8. Sample Manifest
Please print or type. (Form designed for use on elite (12-pitch) typewriter.)
Form Approved. OMB No. 2050-0039. Expires 9-30-88
UNIFORM HAZARDOUS
WASTE MANIFEST
1 . Generator's US EPA ID No
I I I I !
Manifest
Document No
I
2 Page 1
Informal on in the shaded areas
is not required by Federal
law.
3. Generator s Name and Mailing Address
4 Generator's Phone ( )
A. State Manifest Document Number
B. State Generator's ID
5. Transporter 1 Company Name
US EPA ID Number
C. State Transporter s ID
US EPA ID Numbei
D. Transporter's Phone
E. State Transporter's ID
7. Transporter 2 Company Name
F. Transporter's Phone
9. Designated Facility Name and Site Address
10!
US EPA ID Number
G. State Facility's ID
H. Facility's Phone
1 1 . US DOT Description (Including Proper Shipping Name, Hazard Class, and ID Number}
1 2. Containers
No. Type
13.
Total
Quantity
14.
Unit
Wt/Vo
Waste No.
J. Additional Descriptions for Materials Listed Above
K. Handling Codes for Wastes Listed Above
15. Special Handling Instructions and Additional Information
16. GENERATOR'S CERTIFICATION: t hereby declare that the contents of th s consignment are fully and accurately described above by
proper shipping name and are classified, packed, marked, and labeled, and are in all respects in proper condition for transport by highway
according to applicable international and national government regulations.
If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be
economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which minim zes the present and
future threat to human health and the environment; OR, if I am a small quantity generator, I have made a good fa th effort to minimize my waste generation and select
the best waste management method that is available to me and that I can afford.
Printed/Typed Name
S gnature
Month Day Year
1 7. Transporter 1 Acknowledgement of Receipt of Materials
Printed/Typed Name
Signature
Month Day Year
III I
1 8. Transporter 2 Acknowledgement of Receipt of Materials
Printed/Typed Name
Signature
Month Day Year
1 9. Discrepancy Indication Space
20 Facility Owner or Operator Certification of receipt of hazardous materials covered by this manifest except as noted in Item 19.
Printed/Typed Name
S gnature
Month Day Year
I I I I I '
EPA Form 8700-22 (Rev. 9-86) Previous editions are obsolete.
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Exhibit 8. Example Manifest (continued)
Please print or type. (Form designed for use on e ite (12-pitch} typewriter.) Form Approved OMB No 20500039 Expires 9-30-9'
1
G
N
E
R
A
T
0
R
T
R
A
N
S
P
0
R
T
£
R
F
A
C
1
L
1
T
Y
UNIFORM HAZARDOUS 21. Generator's US EPA ID No Manifest
WASTE MANIFEST Document No
(Continuation Sheet)
23. Generator's Name
24. Transporter Company Name 25 US EPA ID Number
1
26 Transporter Company Name 27. US EPA ID Number
1
28. US DOT Description (Including Proper Shipping Name. Hazard Class, and ID Number}
a.
b.
c
d.
e.
i
g
h.
i.
29 Conta
No.
S. Additional Descriptions for Materials Listed Above
22 Page Informa on in the shaded
areas is not required by Federal
law
L. State Manifest Document Number
M. Stale Generator's (D
N. State Transporter's 10
O. Transporter's Phone
P. State Transporter's !D
Q. Transporter's Phone
ners
Type
30
Total
Quantity
31
Unit
Wt/Vo
R
Waste No.
T. Handling Codes far Wastes Listed Above
32. Special Handling Instructions and Additional Information
33. Transporter Acknowledgement of Receipt of Materials
Printed/Typed Name Signature
34. Transporter Acknowledgement of Receipt of Materials
Printed/Typed Name Signature
Date
Month Day Year
I I
Date
Month Day Yaai
I I
35. Discrepancy Indication Space
-PA Form 8700-22A (Rev. 9-88) Previous edition is obsolete
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Summary of Recordkeeping Requirements
EPA requires that certain records be kept on file
at your shop for 3 years. These records are
listed below. Included is a note where the
requirements apply to LQGs, SQGs, or both.
/ Laboratory analyses or waste profile sheets
for determining whether wastes generated by
your shop are hazardous [LOG, SQG]
/ Copies of all hazardous waste manifests, land
disposal restriction notifications, and
exception reports [LQG, SQG]
/ Copies of all Notification of Hazardous Activity
Forms submitted to and received from the
state or EPA [LQG, SQG]
/ Copies of personnel training plans and
documentation that indicates employees have
completed the required training [LQG]
/ Copies of your shop's contingency plan [LQG]
/ Copies of your biennial report [LQG].
It is a good idea to have these documents filed
neatly in one place at your shop. State or federal
inspectors will likely ask for copies of these
documents while inspecting your shop.
7. Contingency Planning
A contingency plan will help you look ahead and
prepare for accidents involving hazardous waste
that could possibly occur at your shop. If you are
an LQG of hazardous waste, you are required to
have a written contingency plan. If you are an
SQG of hazardous waste, you must have basic
contingency procedures in place. Exhibit 9
presents the contingency requirements for LQGs
and SQGs. Although a written contingency plan
is not federally required for SQGs or
conditionally exempt SQGs, it is strongly
recommended. It is also important to check with
your state and local authorities for any additional
contingency planning or emergency
preparedness requirements.
8. Emergency Procedures and Accident
Prevention
Emergency Procedures. Your contingency
plan, discussed in the previous section, must
contain facility-specific details on what you have
to do if you have an emergency. Specifically:
/ In the event of a fire, explosion, or
accidental release of hazardous waste, you
must notify immediately the National
Response Center if the fire, explosion, or
other release could threaten human health
outside your print shop or when the release
has reached surface water. The Center
operates a 24-hour toll free number:
1-800-424-8802. As soon as possible, have
the hazardous waste and any contaminated
materials or soils cleaned up by an
appropriately trained person.
ANYONE WHO IS REQUIRED TO
CALL THE NATIONAL RESPONSE
CENTER AND DOES NOT IS
SUBJECT TO A $10,000 FINE, A
YEAR IN JAIL, OR BOTH. If you are
an owner or manager of a print shop
and you fail to report a release, you
may have to pay for the entire cost of
repairing any damage, even if your
shop was not the single or main cause
of the damage.
As stated above, the RCRA regulations require
that emergency telephone numbers and
locations of emergency equipment be posted
near telephones. This means that next to the
telephone you must post:
/ The name, office phone number, home phone
number, and address of your emergency
coordinator.
/ A site plan or list of nearby:
- Portable fire extinguishers
- Special extinguishing equipment (e.g., foam,
dry chemicals)
- Fire alarms (only if not directly connected to
fire department)
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- Spill control equipment (e.g., absorbent
cotton rags)
- Decontamination equipment (e.g., safety
shower, eye wash fountain)
- Water at adequate volume and pressure
(e.g., water hoses, automatic sprinklers,
water spray systems).
/ The telephone numbers of the fire and police
departments.
/ Although not required, it is strongly
recommended that you also post the
following phone numbers by the telephone:
- State or local emergency response teams
- Hospital
- Local ambulance service
- National Response Center
- State Department of Public Safety
All employees who deal with hazardous waste
must know proper waste handling and
emergency procedures. You must appoint
yourself or an employee to act as the emergency
coordinator to ensure that emergency
procedures are carried out in the event of an
emergency.
Exhibit 9. Contingency Requirements for LQGs and SQGs
LOG Contingency Plan Contents
SQG Contingency Procedures
Written plan required.
The contingency plan must contain:
Instructions on what to do immediately
whenever there is a fire, explosion, or release
The arrangements agreed to with local police
and fire departments, hospitals, and state and
local emergency response teams to provide
emergency services
The names, addresses, and telephone
numbers of all persons qualified to act as
emergency coordinators
All emergency equipment at the shop
An evacuation plan.
Copies of the contingency plan must be
submitted to the local police and fire
departments, hospitals, and state and local
emergency response teams that may be called
upon to provide emergency services. You
should maintain documentation showing that
local authorities have been notified.
Basic plan required (not required to be written).
The contingency procedures include the
following:
You must have an emergency coordinator (an
employee) either at the shop or on-call who is
responsible for coordinating all emergency
response measures.
You must post next to the telephone 1) the
name and telephone number of your
emergency coordinator, 2) the locations of the
fire extinguishers and spill control material, and
3) the telephone number of the fire department.
You must ensure that all employees who
handle hazardous waste are thoroughly familiar
with proper waste handling and emergency
procedures.
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The emergency coordinator (or someone
designated by that person) must:
Be available 24 hours a day either at the
facility or by phone
Know whom to call and what steps to follow in
an emergency
Commit company resources as necessary to
respond to an emergency.
Because most printers are small businesses, the
owner or operator probably already performs
these functions. Therefore, it is not intended
(nor is it likely) that you will need to hire a new
employee to fill this role.
Accident Prevention. Your shop should have
appropriate cleanup materials and emergency
communication equipment for handling
hazardous waste at your site. Some of the steps
you should take to prepare for emergencies at
your shop include the following:
/ Make sure that there are no floor drains near
the area where chemicals are used that lead
to the sewer, septic tank, or storm water
drain.
/ Have absorbent cotton blankets or other
absorbent materials in the area where
hazardous materials are used or stored and
keep them in a container marked "spill
cleanup absorbent blankets/materials." If a
spill occurs, use the cotton blankets or other
absorbent materials to absorb the spill.
/ Store hazardous waste in areas away from
doorways. The floor in your storage area
should be leak-proof (e.g., concrete with an
epoxy coating). If a doorway is nearby, a
concrete barrier is required to prevent the
flow of material out of the door in case of a
large spill.
/ Provide room for emergency equipment and
response teams to get into any area in your
shop in the event of an emergency.
/ If you are an LOG, you must write to local
fire, police, and hospital officials or state or
local emergency response teams explaining
that you handle hazardous waste.
/ You must install and maintain emergency
equipment (e.g., an alarm, a telephone, two-
way portable radios, fire extinguishers, hoses,
and automatic sprinklers) at your shop in
hazardous waste storage areas for
flammable and combustible liquids storage,
so that it is immediately available to your
employees if there is an emergency. This
equipment must be inspected monthly.
5.4 GOOD ENVIRONMENTAL MANAGEMENT PRACTICES
How to Select a Hazardous Waste Transporter and Waste Disposal/Treatment Facility
You should choose a transporter and waste disposal/treatment facility carefully. Even when the waste
leaves your control, your print shop remains legally responsible for the proper disposal of your waste
and any associated spills or accidents.
Before choosing a transporter or designating a facility, check with the following sources:
Your state hazardous waste management agency or EPA regional office, which will be able to
tell you whether a company has an EPA/state identification number and may know
whether a company has had any problems. They may also have a list of licensed
(approved) transporters.
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Your friends and colleagues in the printing business who may have used a specific hazardous
waste transporter or disposal/treatment facility in the past.
Your trade association(s), which may keep a file on companies that handle hazardous waste.
Your Better Business Bureau or Chamber of Commerce to find out if any complaints have been
registered against a transporter or facility.
After checking with these sources, contact the transporter and hazardous waste disposal/ treatment facility
directly to verify that they have an EPA/state identification number and that they can and will handle your
waste. In some states, the transporter and the designated facility may be required to have a special
permit to operate. Make sure that the transporter and waste disposal/treatment facility have the
necessary permits and insurance and that the transporter's vehicles are in good condition. You may also
want to ask them:
Where the waste is going
To provide information on their track record
If they have ever been cited for improper practices.
Checking sources and choosing a transporter and waste disposal/treatment facility may take some time.
You should begin checking before you open your shop or well ahead of the time you will need to ship your
waste.
Disposing of Hazardous Waste On-Site
You may not dispose of your hazardous waste on your property.
Manage Shop Towels Responsibly
Every printer uses shop towels of one sort or another. When shop towels are used to clean presses, they
become contaminated with residual ink, blanket wash, and solvents. Used shop towels can pose a threat
to human health and the environment if they are improperly managed, both in the shop and after they are
sent off for disposal or laundering. Here are some guidelines that you should follow to ensure that you are
handling, storing, and disposing of your shop towels in an environmentally responsible manner:
1. DO NOT THROW SHOP TOWELS INTO THE TRASH.
2. Check with your state environmental agency to determine how towels contaminated with
solvents and other hazardous waste are handled in your state. Each state in New England has
different requirements; you should identify your state's requirements before you take any
steps.
3. Follow these best management practices for handling your shop towels in the shop before they
are sent away for disposal or laundering:
Do not pour solvents on shop towels as a disposal method.
Collect and store shop towels in closed metal containers. Air
drying contaminated shop towels may pose fire and health
hazards, as well as violate hazardous waste, fire, and air
regulations.
PLEASE
PLACE USED
TOWELS
IN
CONTAINERS
PROVIDED
Keep shop towel containers in a ventilated area away from other flammable materials and
ignition sources. Do not store used shop towels on your dryer or electrical panel.
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Keep used shop towels away from corrosives, including haze removers, and oxidizers, such
as stencil and emulsion removers that contain up to 100-percent sodium metaperiodate
crystals. These substances react chemically with contaminated shop towels and can start a
fire.
4. Determine which of the following management options for your shop towels are permissible
with your state environmental agency:
Centrifuge or hand/mechanically wring solvents from rented or leased shop towels, collect
the solvents, and then manage the towels using one of the methods listed below. By
centrifuging or wringing the solvent off the towels, the solvent can be reused in-house and/or
reclaimed.
Send rented or leased solvent-contaminated shop towels to a permitted industrial laundry or
dry cleaning facility. Industrial laundry services are available that will provide you with clean
shop towels and launder your soiled towels. The laundry must have the approval of its
sewer utility to launder the shop towels. By using this method, you can eliminate the
disposal of used shop towels as solid waste and the need for purchasing new towels.
Send disposable solvent-contaminated shop towels to a permitted hazardous waste disposal
facility, using a licensed hazardous waste transporter.
If permissible by your state agency, manage towels as an industrial solid waste.
Send towels to an incinerator to burn for energy recovery.
Good Housekeeping
Good waste management can be thought of as simply good housekeeping practices which include:
Using fewer hazardous materials ?;
Reusing materials as much as possible
Recycling and reclaiming waste
Reducing the amount of waste you generate.
To reduce the amount of waste you generate:
Do not mix nonhazardous wastes with hazardous waste (e.g., combining nonhazardous
cleaning agents or rags in the same container as hazardous wastes). If you do, the
nonhazardous waste may become subject to hazardous waste regulations and you will have
more hazardous waste for disposal.
Avoid mixing different hazardous waste together, unless your waste disposal facility instructs
you otherwise. Doing so may make recycling very difficult, if not impossible. It may also make
disposal more expensive.
Avoid spills or leaks of hazardous products. The materials used to clean up such spills or leaks
may also become hazardous wastes.
Make sure the original containers of hazardous products are completely empty before you throw
them away. Use ALL of the product - it is good business sense. For information on how to deal
with your empty containers that once held hazardous waste refer to Section 5.3.
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Avoid using more of a hazardous product than you need. For example, use no more cleaning
solvent than you need to do the job.
If you drain or wring excess solvent from shop towels, reuse it for low-quality cleaning or capture
it for proper disposal.
Reducing your hazardous waste means saving money on raw materials and reducing the costs to your
business for managing and disposing of your hazardous wastes.
5.5 POLLUTION PREVENTION OPPORTUNITIES FOR HAZARDOUS WASTES
This section describes pollution prevention (P2) opportunities that pertain to hazardous waste.
Information on whether the technique is easy or more difficult to use is included next to each listing,
followed by a description of the technique and information on its benefits. Each discussion provides
information on the relative cost of the technique and the waste streams it can reduce, where possible.
For more information, please contact the individuals listed in Chapter 9.
Ink Inventory Control Easy
Technique: This pollution prevention technique will reduce ink waste generated from color changes,
press cleaning, and poor ink management. Good operating practices focus on smart raw
material management.
Good operating practices and process changes to reduce waste ink include the following:
Use a standard ink sequence for process colors; schedule runs from lighter to
darker colors to decrease the need to change inks and the amount of cleaning
necessary.
Scrape as much ink as possible from the containers when disposing of or
recycling ink containers.
Use first in first out: put new stock on shelves behind older stock.
Monitor ink inventory closely to assure that inks are used before their expiration
dates. Return unused excess inks to the manufacturer if you can.
Keep ink containers sealed and the contents labeled for future use. Plastic or
waxed paper can be placed on top of the ink to prevent oxidation (skinning).
Counsel customers about the environmental impacts associated with particular
colors, paper, or printing method choices.
Ensure that your printing jobs represent the actual cost of
conducting business and disposing of hazardous waste.
Factor waste disposal costs into the price of your products,
and let the market do the rest.
Improve your accuracy in job estimation. Keep track of ink
waste generation by job, press, and operator.
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Benefits:
Costs:
Consult with your supplier or use a computer mixing program with a digital scale
for mixing colors. A digital scale should also be used when measuring ink to
improve accuracy. You can also use software to remix and custom-formulate
PMS colors.
Decreases the amount of waste ink generated.
Process changes generally require some equipment purchases and employee
training.
Material Handling and Storage
Easy
Technique:
This pollution prevention technique can easily be implemented at your printing shop to
avoid disposing of unused or damaged materials. The material handling and storage
activities that can be implemented as part of this technique include the following:
Material pre-inspection
Ordering of materials
Proper storage
Inventory control (first in, first out)
Expired materials.
Material Preinspection -- You should always inspect new materials carefully before
accepting them. Unacceptable, damaged, or nearly expired materials should be returned
to the supplier.
Ordering of Materials -- Minimize wastes by ordering quantities of materials that match
your needs. When ordering input materials, such as film and photoprocessing chemicals,
avoid overstocking by ordering according to usage demands. A good unit price is
meaningless if the material goes bad on your shelf and you then have to dispose of it as
hazardous waste.
Buy the largest container that allows you to use all the contents before they go bad. This
minimizes solid waste from packaging.
If you operate a large printing shop, it may be appropriate to purchase raw materials in
large containers, preferably in returnable or refillable totes, which will eliminate or reduce
the need to clean them. If you do need to clean them, large containers take less time to
clean than several small ones. And there is less waste packaging produced by one 55-
gallon drum than from ten 5-gallon drums.
Proper Storage -- Chemicals that are sensitive to light and temperature should be stored
according to manufacturer's directions to prevent damage to the materials. Chemical
container labels generally list recommended storage conditions.
Paper waste can be minimized through proper handling and storage of rolls or packages
of paper. Paper can easily absorb moisture; therefore, storing paper in an area with
controlled temperature and humidity is important. Ideally, sheet-fed paper should be
conditioned to the temperature and humidity of the press room for 1 day before printing.
Storage areas should be kept free of dust or other contaminants that could damage raw
materials. These areas should not be open to traffic, which increases dust and dirt.
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Benefits:
Inventory Control - Chemical container labels list the shelf life for the material. You
should follow these dates and keep inventories using first-in, first-out practices, which will
help you reduce the amount of materials with expired shelf lives. Also, control access to
materials that will become hazardous waste when spent by using a locked cabinet; these
materials should not be used when a nonhazardous substitute would work as well.
Expired Materials - Because expiration dates are estimated, you should perform small-
scale tests on outdated materials prior to return or disposal to determine if they are still
effective. The material may be usable, rather than becoming an expensive hazardous
waste.
Cost savings from the decreased amount of raw materials discarded due to
damage or expiration.
Less solid waste from packaging, meaning lower trash disposal costs.
Improve Press Cleaning Practices
Easy
Technique: This simple pollution prevention method includes reducing the amount of solvent applied
to shop towels and the number of shop towels used to clean printing presses. Dedicating
presses to specific colors or special inks will also decrease the number of cleanings
required for each press. Ink fountains should be cleaned only when a different color of
ink is used or when the ink might dry out between runs. Aerosol sprays are available that
can be applied to the ink fountains to prevent drying overnight. This means that ink can
be left in the fountain without cleaning at the end of the day.
Benefits: It reduces the amount of waste ink produced and the amount of cleaning solvent
and shop towels used.
Less labor is required to apply the spray to the ink fountains than is needed to
drain and clean the fountains and dispose of the waste ink.
Recycle Used Ink
Easy
Technique: Waste inks can be recycled on-site or through an ink recycling service. Off-site recycling,
either by ink manufacturers or by larger printers, may be more economical for smaller
printers. The waste ink can be reformulated into black ink and sold back to the printer.
Whenever possible, you should manage excess ink as if it were a manufacturing
byproduct that will be reintroduced back into the printing process.
If you recycle ink at your shop, separate waste ink colors and recycle lighter
colors into darker (usually black) or specialty colors. Also, store different types
of ink separately. Clearly mark the containers used to collect waste ink and
prevent contamination with solvents and trash.
Inks can also be sent to a fuel blending service, where they are combined with other
liquids and burned in industrial boilers or kilns. The advantage of this form of disposal is
that it reduces the printer's exposure to litigation and cleanup costs from improperly
landfilled inks.
Benefits: This technique eliminates waste ink disposal costs.
It optimizes cost of purchased ink.
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Aqueous Platemaking Easy
Technique: Aqueous platemaking processes use presensitized plates that do not require the use of
toxic developers. Plate quality is as good as that achieved with traditional platemakers.
Aqueous chemicals must be very clean to maintain plate quality. You should always
purchase the presensitized plates and aqueous developers from the same manufacturer.
Benefits: It reduces pollutants in wastewater.
This technique will eliminate hazardous plate developer waste from your printing
operation. By eliminating hazardous materials used in the platemaking process,
you will reduce employee exposure to toxic chemicals, which increases their
safety.
If you use platemaking equipment designed to use solvent-based developers, it
can also accommodate aqueous chemicals and processes.
Costs: A new aqueous platemaker costs from $20,000 to $30,000.
Aqueous chemical life is 15 to 20 percent shorter, and chemical changeouts must
be performed more frequently than with the solvent-based chemicals. Therefore,
chemical usage is higher.
Aqueous chemical costs will be less than the costs of solvent-based chemicals
because you use less of just one chemistry. You will also realize cost savings
because you will no longer be disposing of the plate- developing chemicals as
hazardous waste (an approximate minimum cost of $3.60 per gallon).
Automated Press Adjustments for Makeready Easy/Moderate
Technique: Numerous devices have been developed to automate press adjustments to speed up the
makeready process. They include:
Web Break Detectors and Web Splicers -- A web break detector can be installed to
detect tears in the web as it passes through a high-speed web press. If a tear occurs, the
detector automatically shuts down the press. Electronic systems are available that detect
web breaks without coming into contact with the rollers.
Splices can be made while the paper is running at operating speed or while the paper is
stationary.
Automated Plate Benders - These devices were designed to prevent problems that
occur when fitting a plate to a cylinder (e.g., plate cracking, unaligned plate bending along
the length of the bend, and curvature of the plate varying from that of the cylinder).
Automated Plate Scanners -- These devices were developed for lithographic web and
sheet-fed offset presses using microprocessor technology. By scanning plates to
determine the relative density of the printing image, ink fountain keys can be pre-set to
compensate for variations in image density.
Automated Ink Key Setting System - Automated ink key setting is accomplished
through scanning to determine ink density. Ink density information is transmitted to a
computer controlled inking system so that automatic ink adjustments are made to the ink
profile for each ink slide position.
Automated Registration Systems -- These devices are optical scanners and
microprocessors used to search for registration marks.
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Ink/Water Sensors -- These devices are used to ensure that the proper ink/water ratio is
being used to produce a sharp dot and strong contrast without the risk of tinting. These
sensors can be apart of an automated press control system.
Benefits: These devices yield increased quality control and reductions in waste paper and
ink generation, as well as time.
Costs: The costs of installing specific devices can be obtained from the product
manufacturer. Cost savings may be realized in reductions in waste paper, ink,
and plates generated.
Alternative Inks
The following alternative inks are available for use:
Vegetable-based (including soy)
Rubber-based (waterless printing)
Near-zero volatile organic compound (VOC) ink/press-wash systems
Ultraviolet-cured
Electron-beam cured.
Moderate
Technique: Vegetable-based inks are common substitutes for petroleum- or solvent-based inks.
Soy-based inks must contain a minimum of 20 percent soybean oil. Some vegetable-
based inks do not contain any petroleum products.
Benefits: The use of vegetable-based inks can reduce VOC emissions by 50 to 99 percent.
Vegetable-based inks typically contain less than 1 to 20 percent VOCs, whereas
petroleum-based inks contain a slightly higher percent VOCs.
Employee safety increases because worker hazards from VOC emissions are
reduced or eliminated.
Products printed with vegetable-based inks are said to be more deinkable by
waste paper processors and produce less hazardous sludge, making them more
recyclable than products printed with petroleum-based inks.
Costs: Vegetable-based inks may be harder to use, especially in high-speed or handling
situations.
Some customers may not accept such inks because they do not yet produce very
high quality results in some applications.
They may be slightly more expensive.
Because their quality is improving and because of the environmental advantages
they offer, you should use vegetable-based inks in as many applications as
possible. The fact that you use them can also be used to your marketing
advantage.
Many colored vegetable-based inks are comparable in price to petroleum- or
solvent-based inks because the price is driven by the pigment and not the
vehicle.
Moderate
Technique: Rubber-based (waterless printing) -- This pollution prevention technique describes a
new development in lithography that eliminates the use of fountain solutions. In waterless
printing, silicone rubber is used in place of fountain solution to repel ink from non-image
areas of the printing plate.
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Benefits: Sharper images can be created using this printing technology because inks can
be applied at higher densities.
Costs: The inks must be maintained within narrow temperature ranges, so cooling of the
printing presses is often required.
Current plate-making methods for waterless printing are solvent-based, which
adds to facility VOC emissions and hazardous waste.
Moderate
Technique: Near-Zero VOC Ink/Press Wash - A new ink/press wash system on the market for use
by lithographers contains virtually no VOCs. The ink is made from a 100-percent
vegetable oil base and, through use of special chemicals, presses can be cleaned with a
water-based press wash solution. Essentially, these special chemicals make the ink
water soluble. To find out more about this new system, contact your state pollution
prevention office or the New England Environmental Assistance Team (see Chapter 9). A
technology demonstration on this innovative system showed positive results, as indicated
in the following list of benefits.
Benefits: Reduces conventional press wash use and can reduce purchases of press wash.
Eliminates hazardous solvents in wastewater discharges.
Reduces hazardous waste generation and disposal.
Eliminates worker health risks associated with solvents containing VOCs.
Can reduce ink consumption.
Business form and check printers and job shops are excellent candidates for this
system. Performs well on one-color sheet fed, raised imprint, and web presses
and may work on duplicators.
Creates potential for green marketing of your print shop.
Reduces VOC generation.
Costs: Blanket and roller cleanup is more time consuming but is still acceptable.
There are potential drying problems.
High-quality sheet fed printers must work closely with the manufacturer to perfect
use for their shop. Other printers must be willing to experiment with this product
and seek support from the manufacturer.
Challenging
Technique: Ultraviolet (UV)-curing inks - These inks consist of liquid prepolymers and initiators.
When exposed to large doses of UV radiation, these compounds immediately polymerize
into a solid. As substitutes for solvent-based inks, UV-curing inks are particularly suitable
for lithographic printing on nonabsorbent substrates, such as foil and plastics. Because a
high capital expenditure is required to purchase the equipment, however, its use is limited
to larger shops.
Challenging
Technique: Electron-beam (EB) - curing inks - These inks are similar to UV-curing inks in that they
contain no solvent and offer the same operational advantages. EB-curing inks are
suitable substitutes for solvent-based inks used in lithographic printing. Because the cost
of an EB starter system can be $1 million or more, however, its use is limited to larger
shops.
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Automatic Ink Levelers and Antiskinning Spray
Fit to Print
Moderate
Technique: Automatic ink levelers work by distributing ink evenly across the ink tray and agitating the
ink to prevent a skin from forming on the surface. These are most appropriate for large
printing presses that are too large to spread the ink by hand. The automatic ink levelers
reduce the amount of ink required to be in the ink tray to ensure distribution. Another
method to prevent ink from skinning is to spray a nontoxic antiskinning agent on the ink in
the tray.
Benefits: Reductions in ink use and associated waste ink disposal.
Reduction in the amount of waste paper generated due to poor press runs.
Costs: Some capital expenditure is required for installing the ink levelers. However, you
will probably experience cost savings from reduced loss of paper and ink in poor
press runs, as well as from waste ink disposal.
Reuse and Recycle Waste Solvent
Moderate
Technique:
Benefits:
Costs:
By placing drip pans under presses, solvent can be collected and reused for cleaning.
Used solvent will remove most of the ink from rollers and blankets, with only a small
amount of fresh solvent needed for final cleanup. In addition, waste solvents having one
ink color can be reused to make up the solvent content of new inks of the same color.
This pollution prevention technique will allow for a significant reduction in solvent waste
generation by reusing or recycling waste solvent.
Waste solvents can also be recycled, although they are frequently fuel-blended.
Recycling waste solvents requires you to segregate used waste solvents from other
hazardous wastes (e.g., waste inks, fountain solutions). These waste solvents should be
handled as a hazardous waste and be recycled through a licensed off-site solvent recycler
who must have an EPA identification number. These recyclers clean, regenerate, and
sell used solvents as recycled solvent products.
On-site distillation units are often used to reclaim solvents. Use of a distillation unit can
greatly reduce the amount of hazardous waste solvent sent off-site. (Unless you hard-pipe
waste solvent directly to a recycling unit, it gets counted as a hazardous waste
generated.) Note: On-site distillation of flammable liquids is VERY dangerous.
By reusing waste solvents as part of your cleaning process, you significantly
reduce the amount of fresh solvent needed and reduce the quantity of waste
solvent that must be disposed of off-site.
Recycling waste solvent also reduces the amount of hazardous waste incinerated
or burned for energy. Both incinerators and fuel blending generate air emissions.
Purchasing recycled solvents reduces the need for fresh solvents and promotes
the solvent recycling industry.
There is a hazardous sludge generated that you must manage.
Distillation units can require some capital investment, which varies greatly with
the size of the unit. A continuous 110-gallon still costs about $25,000; a 5-gallon
batch costs about $3,000.
You must also register recycling equipment or get a state permit. (See your
state's summary for more information.)
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Solvent Sink For Parts Cleaning
Moderate
Technique: This pollution prevention technique can reduce your generation of hazardous solvent
waste and used shop towels generated by equipment cleaning. Solvent sinks are only
appropriate for your printing shop if parts from your presses can be easily removed and
taken to a sink for cleaning. A solvent sink is a steel sink that parts can be placed in and
cleaned with solvent. Solvent is supplied from a barrel and is recirculated. The solvent
may be filtered in the sink and used until it is dirty and no longer effective. Solvent sinks
are generally serviced by a company that will remove and replace ineffective solvent.
Service companies typically use recycled solvents for solvent sinks. The service
company must be a licensed supplier and solvent recycler.
Benefits: It reduces the use of fresh solvent.
Worker safety is improved because of reduced handling of solvent-soaked shop
towels to clean press parts.
Costs: Solvent sinks that are serviced by a company will cost approximately $200 per
month for a one-barrel sink that is changed monthly. Note: You should negotiate
with your service-provider for less frequent solvent replacement (every 6 to 8
weeks). Service providers will want to change the solvent often, which increases
your hazardous waste generation rate. Solvent sinks with filtration systems start
at approximately $700. You should compare the cost of the solvent sink with the
savings associated with reducing the use of shop towels and solvents, as well as
with waste ink disposal costs.
Automatic Blanket Cleaners
Challenging
Technique:
Benefits:
Costs:
This pollution prevention technique can reduce your waste solvent generation. Automatic
blanket cleaners, which replace hand cleanup using shop towels and solvents, have been
determined to be more efficient and use less solvent than manual cleanup.
Increased employee safety because of reduced solvent handling and associated
employee exposure to toxic chemicals.
Reduced solvent use.
Reduced waste solvent generation.
Reduced VOC emissions.
By using an automatic blanket cleaner, you should realize cost savings based on
decreased solvent use and labor time required for press cleaning.
A significant capital investment is required for an automatic blanket cleaner and
other attachments.
A press needs to have sufficient clearance under the blanket rollers to allow for
an automatic cleaner. Small presses may not have sufficient clearance.
It is not easy to retrofit old presses for this technology. It can also be expensive
and not be a good return on investment.
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6. How Do I COMPLY WITH AIR REGULATIONS?
As a printer, you release or emit pollutants to the
air because you work with inks and solvents that
contain volatile organic compounds and toxic
vapors. These emissions lead to the formation
of smog, and they degrade air quality. Therefore,
it is important that you comply with air pollution
control requirements and seek out methods for
reducing air emissions from your print shop in
order to protect yourself, your co-workers, and
the quality of the air in New England. This
chapter explains how you can meet these two
objectives.
Both the U.S. Environmental Protection Agency
(EPA) and state environmental agencies
regulate sources of air pollution. The
requirements for most printers in New England,
however, will most likely be regulated at the state
level. You can be held liable for failing to
comply with federal AND state regulations,
so it is important that you comply with all the
regulations that apply to your shop. You
should also know that pollution prevention is a
smart management tool that will benefit you in
many ways, including helping you to comply with
Clean Air Act regulations.
Here are the steps you should follow to
responsibly manage air emissions from your
print shop:
Determine which products you use that contain
volatile organic compounds and hazardous air
pollutants (defined below).
Calculate air emissions from your shop.
Check with your state air pollution control
office and determine which regulations apply to
your shop.
Comply with all applicable regulations,
including obtaining necessary permits.
Practice good environmental management.
Prevent pollution.
6.1 AIR EMISSIONS FROM PRINTING
OPERATIONS
Air emissions from printing operations include
volatile organic compounds (VOCs) and
hazardous air pollutants (HAPs). Exhibit 2 (see
Chapter 3) lists typical air emissions generated
by lithographic printing operations. While this list
is not all inclusive, it provides a general idea of
the kinds of air emissions that your printing
operations generate.
The federal Clean Air Act is the law that
regulates air pollution in the United States. It
requires state environmental agencies to
regulate the use of VOCs because VOC
emissions lead to the formation of ground-level
ozone or smog. VOCs are found in press wash,
parts-cleaning solvents, proofing system
solvents, fountain solutions (alcohol or its
substitutes), inks, coatings, adhesives, and
photo- and plate- processing solutions. Press
washes can be composed of up to 100-percent
organic solvents and are a major contributor to a
facility's VOC emissions.
The Clean Air Act also identifies 189 chemicals
that are subject to regulation as HAPs. Section
6.3 presents a list of federally regulated HAPs.
The state in which you operate may also
regulate additional chemicals as HAPs. (Please
see your state's requirements provided in a
pocket at the end of this manual). On the
federal HAP list, the most common chemicals
used by lithographers are certain glycol ethers,
which can be found in alcohol substitutes and
cleaning solutions.
After you identify which products used at your
shop contain VOCs and/or HAPs, you must
determine the quantity of emissions generated
from the use of these products and the best way
to manage these emissions. Section 6.2
explains how to calculate your emissions.
Section 6.3 explains the requirements you must
follow to address emissions from VOCs and
HAPs. Section 6.4 explains the permitting
regulations. Sections 6.5 and 6.6 offer
information on good environmental management
and pollution prevention opportunities that can
improve the efficiency of your printing
operations. The pocket at the end of this
manual contains a summary of your state's
requirements.
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6.2 CALCULATING AIR EMISSIONS
FROM YOUR PRINT SHOP
You will need to calculate the actual amount of
VOCs and HAPs generated by your facility, as
well as your facility's potential to emit these
pollutants. Under the Clean Air Act, your
facility's potential to emit VOCs and HAPs is
important in determining which regulatory
requirements apply to your facility.
A facility's potential to emit is defined as the
greatest amount of emissions that could be
released by all the equipment in the facility if it
was operated 24 hours a day, 365 days a year
(its "maximum design capacity"). Pollution
control devices that reduce emissions and
restrictions on the hours of operation are not
included in the calculation of a facility's potential
to emit unless you have a federally enforceable
permit that includes these conditions (see
Section 6.4).
You need to perform the following calculations to
determine your facility's actual and potential
VOC and HAP emissions in order to determine
which regulations apply to your facility.
A. Determining Your Shop's
Actual YOC or HAP Emissions
The material balance method is suggested for
determining your actual air emissions. The basic
concept underlying the material balance method
is that the amount of material entering a process
(like printing) is equal to the amount exiting the
process. Therefore, what you purchase as raw
material must become part of the finished
product, be emitted to the air or water, be
disposed of as waste, or be accumulated in
inventory.
You must have the following information to use
the material balance method to calculate
emissions:
Beginning of the month inventory
New purchases
End of the month inventory
Quantity shipped (i.e., manifested) off-site
Density or specific gravity of the material
Percentage of VOCs and HAPs in the
material.
Material Safety Data Sheets (MSDSs) generally
provide the density or specific gravity of the
material. MSDSs also give the percentage of
VOCs or HAPs in the material (usually stated on
a weight basis). If any of this information is not
available on the MSDSs, you should contact your
vendor to obtain the necessary data. Exhibit 10
illustrates the necessary steps to calculate your
actual VOC or HAP emissions.
B. Determining Your Facility's
Potential YOC or HAP
Emissions
Once you have determined your shop's actual
annual emissions, you should use this
information to determine your shop's potential to
emit VOCs or HAPs. As previously mentioned, a
facility's potential to emit is based on its
maximum design capacity (all equipment in the
shop operating 24 hours per day, 365 days per
year, or a total of 8,760 hours per year). Also,
pollution control devices that reduce emissions
and restrictions on the hours of operation are not
included in the calculation, unless you have a
federally enforceable permit that includes these
limits. So, you should compare your facility's
actual hours of operation to the maximum design
capacity of 8,760 hours per year, using this
formula:
Potential emissions (Ibs/year) = Actual emissions
x (8,760 = Actual hours of operation).
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Exhibit 10. Calculating Your Actual VOC or HAP Emissions
Step 1: Determine which products you purchased that contain VOCs or HAPs, using your Material
Safety Data Sheets.
Step 2: Determine the weight of each VOC- or HAP-containing product used in pounds.
Step 3: For each VOC- or HAP-containing product, subtract the amount of material that your records
show was disposed of or that remains in your shop.
Step 4: Multiply the number from Step 3 by the VOC or HAP content of each product (usually as a
percentage) as listed on the MSDS.
Step 5: Add together the results from Step 4 for each VOC- or HAP-containing product used. The
number that results is your facility's total actual VOC or HAP emissions.
Please keep in mind that your potential to emit
must account for emissions that could have
come from any unused equipment that may not
have been included in determining the facility's
actual emissions. For example, a printer may
own four presses but only have operated three
during the past year. Emissions from three of
the presses would be used to determine the
facility's actual emissions. But calculation of
potential emissions must include emissions from
all four presses.
In addition, according to EPA guidance,
calculations of your facility's maximum
production capacity should include the use of
coatings and inks with the highest VOC content
used in practice at your shop during the previous
2 years.
Finally, if you can document inherent physical
design limitations (e.g., your individual emissions
units require consistent and necessary
maintenance), you should contact your state to
determine whether you can reduce the number
of hours you must use in calculating your
potential to emit. Exhibit 11 provides an
example of how to determine your facility's
actual and potential VOC emissions using a
hypothetical print shop.
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Exhibit 11. Calculating Actual and Potential VOC Emissions at Ace Printing
(Note: This is a hypothetical example. The amounts assumed below will vary at your shop.)
Step 1: Determine which products were purchased that contain VOCs:
Bob, the owner of Ace Printing, operates three presses. He uses the following amounts of product in
one year (VOC content and other parameters were obtained from suppliers and Material Safety Data
Sheets):
Ink -- 40,000 Ibs (VOC content of 20% by weight)
Alcohol -- 3,000 gallons (density of 6 pounds per gallon, VOC content of 100%)
Press Wash -- 3,000 gallons (VOC content of 75%; specific gravity [sg] of 0.9).
Note: Make sure to include in your calculation all VOC-containing materials that you use,
including adhesives; solvents used in parts cleaners; and proofing system solutions.
Step 2: Determine the weight in pounds of each product used:
Ink = 40,000 Ibs
Alcohol = 3,000 gallons x 6 Ibs/gallon = 18,000 Ibs
Press Wash = 3,000 gallons x (0.9 sga x 8.34 Ibs/gallon) = 22,500 Ibs
a Note: Specific gravity (sg) is the density of a compound as compared to water (8.34
pounds/gallon). To calculate the density from a given specific gravity, multiply the specific
gravity by 8.34 pounds per gallon.
Step 3: Subtract the amount of material disposed of, or remaining, that can be accounted for:
Ink -- Assume that 1,000 Ibs of ink are disposed of in waste shipments.
Total ink used = 40,000 Ibs -1,000 Ibs = 39,000 Ibs.
Alcohol -- All alcohol is used in the operation.
Total alcohol used = 18,000 Ibs.
Press Wash -- Assume that 1,000 Ibs are disposed of in shop towels. This number may be
estimated by weighing shop towels dry and then again before laundry pickup.
Total press wash used = 22,500 Ibs -1,000 Ibs = 21,500 Ibs.
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Exhibit 11. Calculating Actual and Potential VOC Emissions at Ace Printing
(continued)
Step 4: Determine the amount of VOCs used at the facility per year by multiplying the annual usage by
the VOC fraction of the material:
- Ink = 39,000 Ibs x 0.20 = 7,800 Ibs (Note: 20% expressed as a decimal is 0.20)
Alcohol = 18,000 Ibs x 1.0 = 18,000 Ibs (Note: 100% expressed as a decimal is 1.0)
Press Wash = 21,500 Ibs x 0.75 = 16,125 Ibs.
Step 5: Total the actual emissions:
7,800 Ibs (ink) + 18,000 Ibs (alcohol) + 16,125 Ibs (press wash) = 41,925 Ibs total
actual VOC emissions.
The potential emissions from Ace Printing are:
= Actual emissions x [potential hours of operation = actual hours of operation]
= 41,925 Ibs/yr x [8,760 hrs/yrb-^ 2,600 hrs/yrb]
= 41,925 Ibs/yr x 3.37
= 141,287.25 Ibs/yr
= 70.6 tons per year.
"Potential hours of operation = 24 hrs/day x 365 days/yr = 8,760 hrs/yr;
actual hours of operation for Ace Printing = 10 hrs/day x 5 days/wk x 52 wks/yr =
2,600 hrs/yr
6.3 DETERMINING WHICH
REGULATIONS APPLY TO YOUR
FACILITY
Once you have calculated your facility's actual
and potential emissions, you are ready to
determine which state and federal regulations
may apply to your facility.
A. Major VOC Sources
A facility may be classified as a major source of
VOC emissions depending upon its potential to
emit VOCs and its location. Areas that
experience unhealthy ground-level ozone (i.e.,
smog) concentrations more than once per year
on average are designated as non-attainment
areas. These areas are then classified as
marginal, moderate, serious, severe, or extreme,
depending upon the severity of the air quality
problem.
In most of New England, which is part of a
special area known as the Northeast Ozone
Transport Region, a major source is one with the
potential to emit 50 tons (100,000 pounds) of
VOCs or more per year. However, for facilities
located in the southwestern portion of
Connecticut, a major source is one with the
potential to emit 25 tons (50,000 pounds) of
VOCs or more per year, because this area has
severe ground level ozone problems.
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/ If your shop is a major source of VOCs,
based on its potential to emit, you must
follow the requirements listed below.
/ If your shop is not a major source of
VOCs, skip to Section B (Major HAP
Sources).
REQUIREMENTS FOR MAJOR VOC SOURCES:
You must reduce your emissions through the
use of Reasonably Available Control
Technology. In some cases, states have
established their own control levels. EPA
issued a draft Contrgl Techniques Guideline
document outlining recommended levels of
control for the offset lithographic printing
industry in September 1993. EPA also issued
an Alternative Control Techniques document
in June 1994 that contains supplemental
information. These documents may be
obtained from state and federal environmental
agencies. In these two EPA guidance
documents for offset lithographic printing shops,
the recommended levels of control are as
follows:
Heatset web -- The fountain solution
must contain no greater than 1.6-percent
alcohol by weight or no greater than 3.0-
percent alcohol by weight if the solution is
refrigerated to less than 60° F. If, however,
the fountain solution contains no alcohol, it
may contain up to 5.0-percent VOCs by
weight. Also, VOC emissions from the
press dryer exhaust vent must be reduced
by 90 percent (by weight), or a maximum
dryer outlet concentration of 20 ppmv must
be maintained, whichever is less stringent.
Non-heatset web - The fountain
solution must contain no alcohol.
Sheet-fed - The fountain solution
must contain no greater than 5.0-
percent alcohol by weight or no
greater than 8.5-percent alcohol by
weight if the solution is refrigerated to below
60° F. Alternatively, if the fountain solution
contains no alcohol, the fountain solution
may contain up to 5.0-percent VOCs by
weight.
Cleaning solutions - You must use
cleaning solutions with a VOC content of 30
percent or less or cleaning solutions with a
VOC composite partial vapor pressure less
than 10mm Hgat20°C.
These are the EPA recommended levels of
control. Check with your state to see whether
their requirements are more stringent and
whether a state license is needed. In addition, if
you are a major VOC source, you need to obtain
a Title V operating permit. Section 6.4 discusses
operating permits.
B. MAJOR HAP SOURCES
If your print shop has the potential to emit 10
tons per year (20,000 pounds) of any single HAP
on the federal HAP list (see Exhibit 12) or 25
tons per year (50,000 pounds) of any
combination of HAPs on the federal HAP list, it is
considered a major source of HAPs and will
need to obtain a Title V operating permit.
Your state may regulate other pollutants in
addition to those on the federal HAPs list. Refer
to your state's requirements provided in the
pocket at the end of this manual.
/ If your shop is a major source of HAPs,
you must obtain a Title V operating permit.
See Section 6.4 for details, and
/ You should also review the requirements in
Section C, New Sources or Modifications.
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Exhibit 12. List of Federal Hazardous Air Pollutants (HAPs)
Sec. 112 (b) List of Pollutants. -- (1) Initial List. -- The Congress establishes for purposes of this section
a list of hazardous air pollutants as follows:
CAS Number
75070
60355
75058
98862
53963
107028
79061
79107
107131
107051
92671
62533
90040
1332214
71432
92875
98077
100447
92524
117817
542881
75252
106990
156627
105002
133062
63252
75150
56235
463581
120809
133904
57749
7782505
79118
532274
108907
510156
67663
107302
126998
1319773
95487
Chemical Name
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
2-Acetylaminofluorene
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Allyl chloride
4-Aminobiphenyl
Aniline
o-Anisidine
Asbestos
Benzene (including benzene from gasoline)
Benzidine
Benzotrichloride
Benzyl chloride
Biphenyl
Bis(2-ethylhexyl)phthalate (DEHP)
Bis(chloromethyl)ether
Bromoform
1,3-Butadiene
Calcium cyanamide
Caprolactam (Removed 6/6/96)
Captan
Carbaryl
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Catechol
Chloramben
Chlordane
Chlorine
Chloroacetic acid
2-Chloroacetophenone
Chlorobenzene
Chlorobenzilate
Chloroform
Chloromethyl methyl ether
Chloroprene
Cresols/Cresylic acid (isomers and mixture)
o-Cresol
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Exhibit 12. List of Federal Hazardous Air Pollutants (HAPs) (continued)
CAS Number Chemical Name
108394
106445
98828
94757
3547044
334883
132649
96128
84742
106467
91941
111444
542756
62737
111422
121697
64675
119904
60117
119937
79447
68122
57147
131113
77781
534521
51285
121142
123911
122667
106898
106887
140885
100414
51796
75003
106934
107062
107211
151564
75218
96457
75343
50000
76448
m-Cresol
p-Cresol
Cumene
2,4-D, salts and esters
DDE
Diazomethane
Dibenzofurans
1,2-Dibromo-3-chloropropane
Dibutylphthalate
1,4-Dichlorobenzene(p)
3,3-Dichlorobenzidene
Dichloroethyl ether (Bis(2-chloroethyl)ether)
1,3-Dichloropropene
Dichlorvos
Diethanolamine
N,N-Diethyl aniline (N,N-Dimethylaniline)
Diethyl sulfate
3,3-Dimethoxybenzidine
Dimethyl aminoazobenzene
3,3'-Dimethyl benzidine
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1-Dimethyl hydrazine
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-cresol, and salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
1,4-Dioxane (1,4-Diethyleneoxide)
1,2-Diphenylhydrazine
Epichlorohydrin (1 -Chloro-2,3-epoxypropane)
1,2-Epoxybutane
Ethyl acrylate
Ethyl benzene
Ethyl carbamate (Urethane)
Ethyl chloride (Chloroethane)
Ethylene dibromide (Dibromoethane)
Ethylene dichloride (1,2-Dichloroethane)
Ethylene glycol
Ethylene imine (Aziridine)
Ethylene oxide
Ethylene thiourea
Ethylidene dichloride (1,1-Dichloroethahe)
Formaldehyde
Heptachlor
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Exhibit 12. List of Federal Hazardous Air Pollutants (HAPs) (continued)
CAS Number Chemical Name
118741
87683
77474
67721
822060
680319
110543
302012
7647010
7664393
7783064
123319
78591
58899
108316
67561
72435
74839
74873
71556
78933
60344
74884
108101
624839
80626
1634044
101144
75092
101688
101779
91203
98953
92933
100027
79469
684935
62759
59892
56382
82688
87865
108952
106503
75445
7803512
7723140
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexamethylene-1,6-diisocyanate
Hexamethylphosphoramide
Hexane
Hydrazine
Hydrochloric acid
Hydrogen fluoride (Hydrofluoric acid)
Hydrogen sulfide
Hydroquinone
Isophorone
Lindane (all isomers)
Maleic anhydride
Methanol
Methoxychlor
Methyl bromide (Bromomethane)
Methyl chloride (Chloromethane)
Methyl chloroform (1,1,1-Trichloroethane)
Methyl ethyl ketone (2-Butanone)
Methyl hydrazine
Methyl iodide (lodomethane)
Methyl isobutyl ketone (Hexone)
Methyl isocyanate
Methyl methacrylate
Methyl tert butyl ether
4,4-Methylene bis(2-chloroaniline)
Methylene chloride (Dichloromethane)
Methylene diphenyl diisocyanate (MDI)
4,4'-Methylenedianiline
Naphthalene
Nitrobenzene
4-Nitrobiphenyl
4-Nitrophenol
2-Nitropropane
N-Nitroso-N-methylurea
N-Nitrosodimethylamine
N-Nitrosomorpholine
Parathion
Pentachloronitrobenzene (Quintobenzene)
Pentachlorophenol
Phenol
p-Phenylenediamine
Phosgene
Phosphine
Phosphorus
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Exhibit 12. List of Federal Hazardous Air Pollutants (HAPs) (continued)
CAS Number Chemical Name
85449
1336363
1120714
57578
123386
114261
78875
75569
75558
91225
106514
100425
96093
1746016
79345
127184
7550450
108883
95807
584849
95534
8001352
120821
79005
79016
95954
88062
121448
1582098
540841
108054
593602
75014
75354
1330207
95476
108383
Phthalic anhydride
Polychlorinated biphenyls (Arochlors)
1,3-Propane sultone
beta-Propiolactone
Propionaldehyde
Propoxur(Baygon)
Propylene dichloride (1,2-Dichloropropane)
Propylene oxide
1,2-Propylenimine (2-Methyl aziridine)
Quinoline
Quinone
Styrene
Styrene oxide
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1,1,2,2-Tetrachloroethane
Tetrachloroethylene (Perchloroethylene)
Titanium tetrachloride
Toluene
2,4-Toluene diamine
2,4-Toluene diisocyanate
o-Toluidine
Toxaphene (chlorinated camphene)
1,2,4-Trichlorobenzene
1,1,2-Trichloroethane
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Triethylamine
Trifluralin
2,2,4-Trimethylpentane
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride (1,1-Dichloroethylene)
Xylenes (isomers and mixture)
o-Xylenes
m-Xylenes
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Exhibit 12. List of Federal Hazardous Air Pollutants (HAPs) (continued)
CAS Number Chemical Name
106423
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
p-Xylenes
Antimony Compounds
Arsenic Compounds (inorganic including arsine)
Beryllium Compounds
Cadmium Compounds
Chromium Compounds
Cobalt Compounds
Coke Oven Emissions
Cyanide Compounds1
Glycol ethers2
Lead Compounds
Manganese Compounds
Mercury Compounds
Fine mineral fibers3
Nickel Compounds
Polycyclic Organic Matter4
Radionuclides (including radon)5
Selenium Compounds
Note:
For all listings above which contain the word 'compounds' and for glycol ethers, the following
applies: Unless otherwise specified, these listings are defined as including any unique chemical
substance that contains the name chemical (i.e., antimony, arsenic, etc.) as part of that chemical's
infrastructure.
X'CN where X=H' or any other group where a formal dissociation may occur. For example KCN or
Ca(CN)2.
Includes mono- and di-ethers or ethylene glycol, diethylene glycol, and triethylene glycol R-(OCH2CH2) -
OR' where n=1, 2, or 3; R=alkyl or aryl groups; R'=R ,H, or groups which, when removed, yield glycol
ethers with the structure: R-(OCH2CH)n-OH. Polymers are excluded from the glycol category.
Includes mineral fiber emissions from facilities manufacturing or processing glass, rock, or slag fibers
(or other mineral derived fibers) of average diameter 1 micrometer or less.
Includes organic compounds with more than one benzene ring, and which have a boiling point greater
than or equal to 100°C.
A type of atom which spontaneously undergoes radioactive decay.
C. NEW SOURCES OR MODIFICATIONS
Your shop is subject to the Clean Air Act new
source review requirements if you are either a
new major source or an existing major source
with significant modifications to equipment at
your shop.
New source review requires you to control your
emissions to the greatest extent technically
possible. In non-attainment areas and in the
Ozone Transport Region, all new major sources
are required to offset their emissions. Each
state's regulations define when a shop would be
considered a "new" source (see your state's
regulations provided in the pocket at the end of
this manual). An emissions offset is the
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reduction of emissions at an existing source to
compensate for new emissions at another
source. You can offset new emissions by buying
or trading emissions reductions from other
sources. If you are a new major source of VOC
emissions, you will definitely be subject to new
source review. If you are a new source whose
emissions are less than major, you may still be
subject to minor new source review depending
on your state. Most minor new source review
programs do not require offsets, but do require
the source to implement the best available
control technology.
Because you may be more likely to modify your
existing facility rather than build a new one, you
should understand the regulatory implications of
modifying your plant. You will be subject to new
source review if you undertake a significant
modification to an existing major source. A
modification to an existing major source (e.g.,
adding a press) is considered significant if it
causes emissions at your facility to exceed:
40 tons per year of VOCs in Maine,
Vermont, and portions of New Hampshire
25 tons per year of VOCs in Connecticut,
Rhode Island, Massachusetts, and other
portions of New Hampshire.
Further, each state has a federally approved
program to regulate minor modifications and
minor new sources (see your state's regulations
provided in a pocket at the end of this manual).
If your new shop is a major or minor new
source or if you undertake a significant
modification to an existing source, your
state environmental agency will determine
the specific control measures you must
implement. Contact the office listed on
your state summary page provided in the
pocket at the end of this manual.
You should also review the requirements
in Section 6.4, Air Pollution Permits.
local agencies to plan for either further
reductions of air pollution or the maintenance
of current air quality.
Designate the control requirements to be used
to reduce the emissions of certain pollutants at
a facility.
Identify how a facility demonstrates
compliance with the control requirements.
Permits can take several forms, including a
permit-to-construct and a permit-to-operate. A
construction permit may be required before any
new facility can be built or before any new piece
of equipment (e.g., a printing press) can be
installed or modified (see your state summary
page provided in a pocket at the end of this
manual). An operating permit will contain all
applicable and enforceable control requirements
and, like all permits, will have a defined period of
effectiveness.
One type of operating permit, mandated by the
1990 Clean Air Act Amendments, is the Title V
operating permit. The Title V operating permit
specifies all of the state and federal control
requirements, emission limits, and
recordkeeping, monitoring and reporting
requirements to which your facility is subject.
Your facility will need to obtain a Title V
operating permit if it is a major source of HAPs
or a major source of VOCs, based on your
facility's potential to emit these pollutants (see
Sections 6.3A and 6.3B).
In some states (e.g., New Hampshire,
Massachusetts, Rhode Island, and Maine), if you
are a major source based on your potential
emissions but your actual emissions are much
less than your source levels, you can obtain a
permit to restrict your emissions below the major
source threshold and you will not be required to
obtain a Title V operating permit or comply with
major new source requirements (see your state
summary provided in the pocket at the end of
this manual).
6.4 AIR POLLUTION PERMITS
Air permits serve three roles. They:
Provide an inventory of air pollution sources.
This inventory is used by federal, state, and
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6.5 GOOD ENVIRONMENTAL MANAGEMENT PRACTICES
Here are some tips on good environmental management practices that could help you save money and
improve your operations:
Document all actions you take to reduce or eliminate emissions.
Keep good records of product purchases and use so you can accurately
calculate your emissions.
Do appropriate reporting and keep important records of waste disposal.
Document your actual and potential VOC and HAP emissions calculations as
well as your operating time.
Educate your customers on the environmental impacts of their product
choices.
Conserve and reuse inks.
Handle solvents carefully to minimize spills.
Avoid use of products containing VOCs and chlorinated solvents (e.g., benzene,
1,1,1-trichloroethylene, methylene chloride, toluene, and xylene).
Choose solvents with a low VOC content or low vapor pressure or that are water-miscible when
possible.
Reuse shop towels for low quality cleaning needs in the shop prior to
proper disposal.
Use solvents conservatively by using plunger cans to dispense solvents
with meters and using only the amount necessary. Appoint one person to
store and distribute solvents.
Do not leave shop towels out in the open; use a metal container with a lid
that can be closed using a foot pedal.
Do not leave product containers open.
Switch to alcohol-free fountain solution -- today.
6.6 POLLUTION PREVENTION OPPORTUNITIES FOR AIR EMISSIONS
If you are subject to any of the requirements outlined in Sections 6.2 through 6.4, you should use pollution
prevention techniques as a means of both complying with regulations and reducing your regulatory
burden. Even if you are not subject to any of the above requirements, you should prevent pollution where
possible in your facility because it can save you money on solvents and reduce
worker exposure to chemicals so that your facility provides a safer and more
pleasant work environment.
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This section describes pollution prevention (P2) opportunities that can limit air emissions.
Information on whether the technique is easy or more difficult to use is included next to
each listing, followed by a description of the technique and its benefits. Each discussion
provides information on the relative cost of the technique and the waste streams that can
be reduced using each technique, where possible. For more information, please contact
the individuals listed in Chapter 9.
Cover Photoprocessing Chemical Containers Easy
Technique: This is a simple P2 technique that can be implemented at your shop to:
Reduce or eliminate air emissions generated by chemical evaporation
Reduce purchases of virgin photoprocessing chemicals.
Developers evaporate very quickly, while fixers evaporate at a slightly slower rate. The
containers should always be sealed or covered to prevent evaporation. Many print shops
use floating lids, caps, or other devices to do this. You should also cover trays overnight if
tray processing is done.
Benefits: Your photoprocessing costs are reduced because there is minimal loss of the
product through evaporation.
Your working environment will be safer because of the reduction and/or
elimination of air emissions from the solutions.
Costs: This technique may require you to purchase covers and lids. Special
tanks/containers can be purchased for $20 to $250.
Alternative Fountain Solution Easy/Moderate
Technique: The use of alternative fountain solution will reduce or eliminate your facility's VOC
emissions. Fountain solutions traditionally contain isopropyl alcohol (IPA). Non-lPA
fountain solutions that use glycol ether are typically used as a replacement for IPA.
Benefits: Substitutes may help you meet VOC emission limits for your printing shop.
Since substitutes are used at much lower concentrations, you will incur cost
savings by using less product.
Substitutes will improve the indoor air quality of your shop because VOC
emissions will be significantly reduced or eliminated.
Substitutes eliminate the use of highly flammable, dangerous products.
Costs: Non-lPA fountain solutions cost approximately $18 to $20 per gallon, while IPA
solutions cost around $10 per gallon.
Non-lPA fountain solutions perform differently on the press than IPA solutions.
Generally, their operating range is smaller, and the viscosity can vary with
temperature resulting in inconsistent wetting.
Alternative Cleaning Solutions Moderate
Technique: The use of alternative blanket washes and cleaners that are less toxic and flammable will
reduce your facility's VOC emissions. Typical press-cleaning solutions contain aliphatic
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Benefits:
Costs:
and aromatic hydrocarbons. Alternative blanket washes, which contain mixtures of glycol
ethers and other heavier hydrocarbons, have higher flashpoints and low toxicities, which
are formulated to produce lower VOC emissions. These glycol ether solutions clean
comparably to conventional solvents.
These alternative cleaning solutions do not evaporate as rapidly as other solvents and
may require a substantially longer drying time. Because of the environmental and safety
benefits of these materials, however, they are gaining in popularity. Cleanup should be
done with detergents or soap solutions wherever possible. Solvents should be used only
for cleaning up inks and oils.
Water miscible solvents are another alternative worth exploring. They contain 100-
percent VOCs when purchased, but are cut to 50 percent with water, so at press contain
only 50 percent VOCs by content.
The benefit of using lower VOC solvents is the reduced VOC emissions, which
improves indoor and regional air quality.
Many alternative cleaning solutions require a substantially longer drying time.
Extra time is required for cleaning presses.
Water-Based Adhesives for Postpress Operations
Moderate
Technique: Water-based adhesives have long been used in printing shop operations in addition to
using solvent-based adhesives. However, an important trend in postpress
operations is the increasing use of water-based adhesives in place of
solvent-based adhesives, which contain toluene and methyl ethyl ketone,
two highly toxic chemicals.
Benefits: Reduces VOC and HAP emissions from solvent-based adhesives.
Reduces worker exposure to hazards.
Reduce Fountain Solution Temperature
Moderate/Challenging
Technique: This P2 technique is a good operating practice that will minimize waste paper and ink
generated from poor press runs, as well as significantly reduce VOC emissions. Whether
you use IPA or non-lPA fountain solution, you can maximize the efficiency of the fountain
solutions by maintaining them at their optimum operating temperature through cooling or
refrigeration. The optimum temperature may vary for different solutions.
Refrigeration units can be installed for large presses. The smallest press that can
typically accommodate a refrigeration unit is a 26-inch one-color press.
Benefits: A refrigeration unit with a filtration system can significantly extend the life of non-
IPA fountain solutions by removing ink and paper particles. Fountain solution life
may be extended to months instead of days.
Reduced fountain solution losses.
Increased employee safety by reduced exposure to VOC emissions.
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Costs: They do not work well in open fountains.
A fairly significant capital expenditure is required for the refrigeration unit and the
replumbing. A 5-gallon refrigeration unit costs approximately $2,400, and the
plumbing can cost approximately $1,000.
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7. How SHOULD I HANDLE SOLID WASTE?
Businesses across the United States generate
extremely large amounts of nonhazardous waste
daily. In New England, incinerators and, most
often, landfills are the final destination for most
of this waste. But many avenues exist for
diverting waste from a trash disposal facility that
may be in your community.
Solid waste reduction lowers energy
consumption and the emission of greenhouse
gases. Recycling programs take materials out of
the waste stream that can be remanufactured
into new products, creating new businesses and
putting people to work. Industrial waste
exchanges turn one company's trash into
another company's raw materials.
This chapter describes some solid waste
reduction and recycling opportunities for
lithographers. But because lithographic
processes differ from one shop to next, you will
be the best source of solid waste reduction ideas
for your shop. To begin, start with the ideas
listed in Section 7.1, and then contact the
resources listed in Section 7.2.
7.I REDUCTION AND RECYCLING
OPPORTUNITIES FOR SOLID
WASTE
Inefficiently managed solid waste can lead to
excessive and unnecessary expenses for your
company. The following list provides several
suggestions and resources to help you better
handle your company's solid waste.
Reduce materials used -- You can use
conservatively or eliminate completely a
number of input materials to reduce solid
wastes generated by your printing operations.
These materials include coatings that hinder
recycling of paper from your shop and paper.
Reuse materials -- While reducing the input
materials to your printing process is the most
effective means of pollution prevention,
reusing materials in your printing operations
can be an equally effective way of reducing
c
your solid waste stream. Try using returnable
materials containers and returnable plastic or
wood pallets. Check with your suppliers for
other suggestions on how you can reuse
materials that end up in your trash bin.
Recycle scrap - Many materials in a print
shop can be recycled, preventing them from
ending up in the local landfill. They include
packaging, paper (from test runs, scrap,
waste, outdated), empty containers,
cardboard, pallets,
outdated materials
(chemicals), plates,
film (used or spoiled),
and lubricating oils.
Consult your vendors
or local recycling firms
for more ideas.
In addition, the use of in-line finishing is a
worthwhile pollution prevention technique to
reduce solid waste. Finishing operations have
historically been labor-intensive operations,
handled either in-house or by a trade shop, and
were not integrated with the presses. Today,
equipment is available to perform almost all
major postpress operations, including cutting,
folding, perforating, trimming, and stitching in-
line. Web presses are often linked directly to
computer controlled in-line finishing equipment.
New to in-line finishing is demographic binding,
which is the selective assembly of a publication
based on a number of factors, such as
geographic area, family structure, income, or
personal interests. For example, a printer can
select an advertisement to appear only in those
copies of a magazine intended for distribution in
the advertiser's selling area. Demographic
binding has proven to be a successful marketing
tool, especially for major magazines.
This pollution prevention technique reduces
costs by reducing the number of operators and
workers required for off-line finishing operations
by almost half, while sometimes doubling or
tripling the rate of production. It can also be
used to prepare materials for mailing by using
computers. These computers can store and
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provide address labels, as well as address each
publication in zip code order.
7.2 NEW ENGLAND STATE SOLID
WASTE PROGRAMS
This section provides contact numbers and
information on New England solid waste
programs.
WasteCAP
WasteCAPs are independent not-for-profit
organizations located in Maine, Massachusetts,
and New Hampshire that assist and encourage
companies to effectively drive costs out of their
operations through improved production and
solid waste management practices. WasteCAPs
conduct free, confidential, on-site waste
assessments; provide technical assistance over
the phone; and publish quarterly newsletters to
support solid waste reduction. WasteCAPs can
also assist clients in designing or improving
recycling programs and establishing effective
materials procurement practices. This section
lists WasteCAP contacts for the New England
states.
CONNECTICUT
Administering Agency
Connecticut Department of Environmental
Protection
79 Elm Street
Hartford, CT 06106-5127
Waste Management Bureau
Solid Waste: (860) 424-3021
Office of Pollution Prevention: (860) 424-3297
Waste Planning and Standards Bureau
Source Reduction and Recycling: (860) 424-
3365
MAINE
Administering Agency
Maine Department of Environmental Protection
State House Station 17
Augusta, ME 04333
Hazardous Materials and Solid Waste Control
Bureau
Solid Waste: (207) 289-2651
State Planning Office
State House Station 38
Augusta, ME 04333
Recycling: (207) 287-5649
WasteCAP of Maine
Maine Chamber and Business Alliance
120 Exchange Street
Portland, ME 04112
(207)774-1001
MASSACHUSETTS
Administering Agency
Massachusetts Department of Environmental
Protection
One Winter Street
Boston, MA 02108
Division of Solid Waste Management, Bureau of
Waste Prevention
Solid Waste: (617) 292-5960
Recycling: (617)556-1021
WasteCAP of Massachusetts, Inc.
P.O. Box 763
222 Berkeley Street
Boston, MA 02117-07763
(617)236-7715
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NEW HAMPSHIRE
Administering Agency
New Hampshire Department of Environmental
Services
6 Hazen Drive
Concord, NH 03301
Waste Management Division
Solid Waste: (603)271-2900
Recycling: (603)271-3712
WasteCAP of New Hampshire
122 North Main Street
Concord, NH 03301
(603) 224-5388
RHODE ISLAND
Administering Agency
Rhode Island Department of Environmental
Management
235 Promenade Street
Providence, Rl 02908
Office of Waste Management/Site Remediation
Solid Waste: (401)277-2797
Office of Strategic Planning and Policy
Recycling: (401)277-3434
VERMONT
Administering Agency
Vermont Department of Environmental
Conservation
103 South Main Street
Waterbury, VT 05671
Waste Management Division
Solid Waste: (802)241-3888
Environmental Assistance Division
Recycling: (802) 241-3589
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8. How Do I RESPOND TO SPILLS AND PLAN FOR EMERGENCIES?
If there is a chemical or oil spill at your print
shop, you may be subject to many regulatory
requirements, depending on what spilled, how
much spilled, and where it was spilled. It is
critical that you contain chemical and oil spills
immediately and report them to the appropriate
authorities in a timely manner. Failure to
respond to spills appropriately could have dire
consequences for the environment in which you
and your employees live and work. The
consequences of not reporting a release when it
is required may be quite costly. And for the sake
of your community and its natural resources, you
should also comply with any additional chemical
reporting and emergency planning requirements
that may apply to your shop. It is just plain good
business sense.
Chapter 5 of this manual discusses spills of
hazardous waste covered by the Resource
Conservation and Recovery Act (RCRA) and the
associated planning requirements. If you have
developed a contingency plan and have followed
the procedures in place at your shop to address
RCRA chemical spills, you will have satisfied the
emergency planning and response requirements
for RCRA hazardous waste. Similarly, Chapter 4
discusses reporting requirements appropriate to
releases of RCRA hazardous and
nonhazardous waste to sewers and septic
systems.
Three other major laws, however, set out how
you should:
Report spills of chemicals other than RCRA
hazardous waste
Report some chemicals used in your shop
Plan for chemical emergencies and oil spills.
The laws are the Emergency Planning and
Community Right-to-Know Act (EPCRA), which
includes planning, reporting, and chemical spill
requirements; the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA, also known as the
Superfund law), which includes requirements
concerning spills of certain chemicals; and the
Oil Pollution Act, which details oil spill planning
and response requirements. The major
requirements imposed by these laws are
described below.
8.1 EMERGENCY SPILL REPORTING
Two major laws may affect you if a chemical is
spilled in your shop. The first is CERCLA which
authorizes the U.S. Environmental Protection
Agency (EPA) to respond to releases of
hazardous substances that may endanger public
health or the environment. The second is
Subtitle III of the Superfund law Amendments,
known as EPCRA.
If you spill a CERCLA
hazardous substance or an
EPCRA extremely
hazardous substance in an
amount equal to or in
excess of the reportable
quantities, your printing
shop must immediately
notify:
The National Response Center at (800) 424-
8802
Your State Emergency Contact -- See the
contact list below
Your Local Emergency Planning Committee
(LEPC) -- This information is available from
yourSERC.
You must also provide a written report on actions
taken and on any medical effects of the release
to these same organizations.
There is no penalty for making these phone calls
but there is a penalty for not making the calls.
So, do yourself a favor and make the calls if you
have any doubt about your requirements in the
event of a spill at your print shop.
The Title III List of Lists provides the list of
CERCLA hazardous substances or EPCRA
extremely hazardous substances and the
reportable quantities. You can obtain the List of
Lists by contacting the EPCRA Hotline at (800)
535-0202, the RCRA/Superfund Hotline at (800)
424-9346, or the EPA Chemical Emergency
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Preparedness and Prevention Office at
http://www.epa.gov/swercepp/.
New England State Emergency Contacts
CONNECTICUT
Administering Agency
Oil & Chemical Response Division
Connecticut Department of Environmental
Protection
79 Elm Street - 4th Floor
Hartford, CT 06106
Oil & Chemical Emergency Response:
(860) 424-3338
General Information: (860) 424-3231
MAINE
Administering Agency
Division of Response Services
Maine Department of Environmental Protection
State House Station 17
Augusta, ME 04333
Oil & Chemical Emergency Response (during
business hours): (800) 482-0777
Oil & Chemical Emergency Response (during
non-business hours): (207) 657-3030
General Information: (207)287-7190
Oil & Chemical Emergency Response (during
non-business hours): (508) 820-2121
General Information: (617)292-5801
NEW HAMPSHIRE
Administering Agency
New Hampshire Department of Environmental
Services
P.O. Box 95
Concord, NH 03302
Oil & Chemical Emergency Response (during
business hours): (603)271-3899
Oil & Chemical Emergency Response (during
non-business hours): (800) 346-4009
General Information: (603)271-3503
RHODE ISLAND
Administering Agency
Rhode Island Department of Environmental
Management
235 Promenade Street
Providence, Rl 02905
Oil & Chemical Emergency Response (during
business hours): (401)277-3872
Oil & Chemical Emergency Response (during
non-business hours): (800) 498-1336
General Information: (401)277-2234
MASSACHUSETTS
Administering Agency
Bureau of Waste Site Cleanup
Massachusetts Department of Environmental
Protection
1 Winter Street - 5th Floor
Boston, MA 02108
Oil & Chemical Emergency Response (during
business hours):
- Northeast Region (Woburn) - (617) 932-7600
- Southeast Region (Lakeville) - (508) 946-2850
- Central Region (Worcester) - (508) 792-7653
- Western Region (Springfield) - (413) 784-1100
VERMONT
Administering Agency
Hazardous Materials Management Division
Vermont Department of Environmental
Conservation
Waterbury State Complex
103 South Main Street
Waterbury, VT 05676
Oil & Chemical Emergency Response:
(800)641-5005
Waste Management Division: (802)241-3888
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8.2 EMERGENCY PLANNING AND
CHEMICAL REPORTING
EPCRA is the environmental law that sets out
the primary planning and reporting requirements
for chemicals that you may use in your shop.
The purpose of EPCRA is two-fold:
To encourage and support emergency
planning, by industry in coordination with state
and local governments, for responding to
chemical accidents
To provide local governments and the public
with information about possible chemical
hazards in their community.
There are civil and criminal penalties for failure
to meet these obligations, and there is a citizen
suit provision of this law, so do not be caught
unaware!
It is important to note that if you eliminate
EPCRA chemicals from your operations through
pollution prevention, you will also eliminate the
associated planning and notification
requirements for your print shop. This is an
excellent opportunity to decrease your shop's
regulatory burden through pollution prevention.
A. Emergency Planning
/ All facilities, no matter how small, that use
extremely hazardous substances listed under
EPCRA in excess of certain amounts (called
threshold planning quantities) must
participate in emergency planning. The
information submitted through these
emergency plans is used to help local
governments respond to spills or releases
and is made available to the public.
/ These same facilities must also appoint a
facility emergency coordinator who must
participate in the local emergency planning
process.
/ Your first step to determine if these
requirements apply to your shop is to
determine if you use chemicals regulated
under EPCRA and, if so, to determine what
amounts are present at your shop. The list of
EPCRA chemicals and their threshold
planning quantities is provided in the Title III
List of Lists and is available by contacting the
EPCRA Hotline at (800) 535-0202, the
RCRA/Superfund Hotline at (800) 424-9346,
or the EPA Chemical Emergency
Preparedness and Prevention Office at
http://www.epa.gov/swercepp. The EPCRA
hotline can also answer questions you may
have concerning how EPCRA may apply to
your print shop.
B. Hazardous Chemical
Reporting
y You must submit or prepare copies of your
print shop's Material Safety Data Sheets
(MSDSs) or lists of all hazardous chemicals
present at your print shop above threshold
quantities, regardless of location or use, to
the SERC, the LEPC, and local fire
department.
The threshold quantities are:
500 pounds and less for extremely
hazardous substances
10,000 pounds and more for hazardous
chemicals.
MSDSs are available from your vendors.
This reporting requirement is based on the
Occupational Safety and Health
Administration's (OSHA) definition of a
hazardous chemical, which is essentially any
chemical that poses physical or health
hazards. As many as 500,000 products
can fit this definition; therefore, it is highly
likely that this reporting requirement applies
to your shop.
/ You must also submit annual inventories of
these same hazardous chemicals to the
same three organizations - the LEPC, the
SERC, and the local fire department. These
inventories are due on March 1 of each year.
Although one of two forms can be used (Tier I
or Tier II), most states use Tier II forms for
reporting. Tier II forms ask for the amounts
and general location of specific chemicals.
Some states have their own form and may
allow electronic reporting (contact your state
office listed below).
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C. The Toxics Release Inventory
and Form R Reporting
EPCRA also establishes reporting requirements
for facilities that store and manage specified
chemicals. Facilities who must comply include
those that:
Are classified in Standard Industrial
Classification (SIC) codes 20 through 39
(Manufacturing), which includes printers, and
which meet the following criteria:
Have 10 or more full-time employees; and
Manufacture or process 25,000 pounds or
more of specified chemicals or use
quantities exceeding 10,000 pounds of
specified chemicals.
Facilities that meet these criteria must:
/ Submit a Form R report on yearly toxic
chemical releases to their states and EPA.
That is, covered facilities must estimate each
year the total amount of the listed chemicals
they release into the environment (either
accidentally or as a result of routine
manufacturing operations) or transport as a
waste to another location. The reports are
due on July 1 of each year for releases in the
previous calendar year.
EPA uses this information to establish a national
Toxic Chemical Release Inventory and makes
the information available to the public and
communities through a computerized database
called the Toxic Release Inventory (TRI)
database. This form is available from your state
EPCRA contact (see the next section).
Electronic reporting is also available.
CONNECTICUT
Administering Agency
State Emergency Response Commission
Connecticut Department of Environmental
Protection
79 Elm Street - 4th Floor
Hartford, CT 06106-5127
(860) 424-3373
Connecticut uses the standard federal Tier II
form for reporting and requires the submission of
facility floor plans as part of its reporting
specifications. You have the option to file
electronically. Connecticut requires reporting of
any chemical spill (liquid, gaseous, and solid) to
the Department of Environmental Protection, Oil
and Chemical Response Division at (860) 424-
3338. Connecticut also requires manufacturers
that use, keep, store, or produce any hazardous
material to file a report with the local fire
marshall. Contact your local fire department for
details on these reports.
MAINE
Administering Agency
State Emergency Response Commission
Maine Emergency Management Agency
State House Station 72
Augusta, ME 04333
(207) 287-4080
Maine uses a state-specific Tier II form for
reporting and has additional state-specific facility
planning requirements. A reporting fee is
calculated based on the size of the facility and
the amount of chemicals being reported.
New England State EPCRA Contacts and
Requirements
The following sections summarize the New
England state EPCRA requirements applicable
to print shops that are more stringent and/or
different than the federal requirements. The
sections also list state EPCRA contacts.
MASSACHUSETTS
Administering Agency
State Emergency Response Commission
Massachusetts Emergency Management
Agency
400 Worcester Road
Framingham, MA 01701
(508) 820-2000
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William Panos
Massachusetts Department of Environmental
Protection
Bureau of Waste Prevention
1 Winter Street
Boston, MA 02108
(617)292-5870
Massachusetts uses a standard Tier II form with
the option of filing electronically.
NEW HAMPSHIRE
Administering Agency
State Emergency, Response Commission
Governor's Office of Emergency Management
State Office Park South
107 Pleasant Street
Concord, NH 03301
(603)271-2231
New Hampshire uses a standard Tier II form for
reporting and requires that MSDSs be submitted
annually.
RHODE ISLAND
Administering Agency
State Emergency Response Commission
Rhode Island Emergency Management Agency
645 New London Avenue
Cranston, Rl 02920
(401)946-9996
Martha Delaney Mulcahey
Rhode Island Department of Environmental
Management
Division of Air Resources
235 Promenade Street
Providence, Rl 02908-5767
Attn: Toxic Release Inventory
(401)277-2808
Rhode Island has state-specific facility planning
requirements, and the Tier II reporting must be
submitted electronically.
VERMONT
Administering Agency
State Emergency Response Commission
Vermont Emergency Management Agency
103 South Main Street
Waterbury, VT 05676
(802) 244-8721
(800) 347-0488
Gary Gulka
Vermont Department of Environmental
Conservation
Waste Prevention Section
103 S. Main St.
Westbury, VT 05671-0411
(802)241-3626
Vermont uses a standard Tier II form for
reporting with a reporting fee based on the size
of the facility and the amount of chemicals being
reported.
8.3 OIL SPILL PREVENTION
CONTROL AND
COUNTERMEASURES
The Oil Pollution Act contains requirements that
may apply to your shop in two ways:
Any spill of oil large enough to cause a
sheen in a body of water must be reported to
the National Response Center at (800) 424-
8802 and to the appropriate state oil and
chemical emergency response number
identified in the Section 8.1.
These spills include releases to floor drains or
storm drains, as well as chronic leaks from
equipment or oil storage tanks.
If you have a single above ground heating oil
storage tank on your property that holds more
than 660 gallons of oil or any number of tanks
that hold more than 1,320 gallons of oil, you
must have a Spill Prevention Control and
Countermeasures (SPCC) Plan.
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Rhode Island has an Oil Pollution Control
Regulation governing the storage of oil. For
information on this program, call (401) 277-3872.
New Hampshire has a Control of above ground
Petroleum Storage Facilities rule pending. For
information on the rule, call (603) 271-3644.
8.4 ONE PLAN
The Integrated Contingency Plan Guidance
(discussed in Chapter 5) allows you to
consolidate multiple emergency response plans
into one functional emergency response plan.
This option could save you a great deal of time
and effort. To find out more about One Plan,
contact the EPCRA Hotline at (800) 535-0202,
the RCRA/Superfund Hotline at (800) 424-9346,
or the EPA Chemical Emergency Preparedness
and Prevention Office at
http://www.epa.gov/swercepp.
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9. RESOURCES
This section presents a list of state and federal contacts that you can
call if you are seeking additional information on a particular issue or
regulation. Remember that state contacts for wastewater, hazardous
waste, and air emissions are provided in the pocket at the end of this
manual.
9.1 CONNECTICUT
State Pollution Prevention and Regulatory Assistance Contacts
Mary Sherwin P2 Clearinghouse & On-Site Technical Assistance:
Pollution Prevention Coordinator Robert Brown
CT Department of Environmental Protection ConnTAP
79 Elm Street 50 Columbia Boulevard., 4th Floor
Hartford, CT 06106-5127 Hartford, CT 06106
(860) 424-3297 (860) 241-0777
Internet Address: www.state.ct.us
State Small Business Contact
Tracy Babbidge
Small Business Ombudsman
CT Department of Environmental Protection
79 Elm Street
Hartford, CT 06106-5127
(860) 424-3382
9.2 MAINE
State Pollution Prevention and Regulatory Assistance Contacts
Ann Pistell OR Office of Pollution Prevention
Technical Assistance Coordinator 1-800-789-9801
ME Department of Environmental Protection
State House Station 17
Augusta, ME 04333
(207) 287-7881
Internet Address: www.state.me.us/dep/mdephome.htm
State Small Business Contact
Brian Kavannah
Small Business Technical Assistance Coordinator
ME Department of Environmental Protection
State House Station 17
Augusta, ME 04333
(207)287-6188
In Maine: (800) 789-9802
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9.3 MASSACHUSETTS
State Pollution Prevention and Regulatory Assistance Contacts
George Frantz
Special Projects
MA Office of Technical Assistance
100 Cambridge Street, Room 2109
Boston, MA 02202
(617) 727-3260 ext. 631
P2 Clearinghouse:
Toxics Use Reduction Institute
University of Massachusetts - Lowell
One University Avenue
Lowell, MA 01854
(508) 934-3275
State Small Business Contact
George Frantz
Small Business Ombudsman
MA Office of Technical Assistance
100 Cambridge Street, Room 2109
Boston, MA 02202
(617)727-3260, ext. 631
Massachusetts Printers Partnership:
Nancy Wrenn
MA Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street
Boston, MA 02108
(617)292-5584
Internet Address:
www.magnet.state.ma.us/dep/dephome.htm
9.4 NEW HAMPSHIRE
State Pollution Prevention and Regulatory Assistance Contacts
Vince Perelli
Pollution Prevention Program Manager
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301-6509
(603)271-6460
Internet Address: www.state.nh.us
State Small Business Contact
P2 Clearinghouse:
Kathy Blake
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301-6509
(603)271-2902
Rudy Cartier, Jr., P.E.
Small Business Technical Assistance Program & Ombudsman
NH Department of Environmental Services
64 North Main Street
Concord, NH 03301-6509
(603)271-1379
(800) 837-0656 (in-state)
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9.5 RHODE ISLAND
State Pollution Prevention and Regulatory Assistance Contacts
Richard Enander
Pollution Prevention Program Manager
Rl Department of Environmental Protection
235 Promenade Street
Providence, Rl 02908
(401)277-3434, ext. 4411
Internet Address: www.state.ri.us/pg1txt.htm
State Small Business Contact
Richard Girasole
Rl Department of Environmental Protection
Rl Pollution Prevention Program, Small Business Contact
235 Promenade Street
Providence, Rl 02908
(401)277-3434, ext. 4414
9.6 VERMONT
State Pollution Prevention and Regulatory Assistance Contacts
Gary Gulka
Waste Prevention Section Chief
VT Department of Environmental Conservation
103 South Main Street
Waterbury, VT 05671 -0404
(802)241-3626
Internet Address: www.state.vt.us/anr
On-Site Assistance Program
David Boyer
Retired Engineers and Professionals (REAP)
P.O. Box 422
Randolph, VT 05060
(802) 728-1423 or (800) 363-REAP
State Small Business Contact
Kevin Bracey
Small Business Ombudsman
VT Department of Environmental Conservation
Air Pollution Control Division
103 South Main Street
Building 3 South
Waterbury, VT 05671-0402
(802)241-3841
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Anne Leiby
New England Environmental Assistance
Team
U.S. Environmental Protection Agency,
Region 1
JFK Federal Building (SPN)
Boston, MA 02203
(617)565-4974
e-mail: leiby.anne@epamail.epa.gov
9.7 FEDERAL RESOURCES IN NEW ENGLAND
EPA Regional Lithographic Printing Contacts
Sally Mansur
New England Environmental Assistance Team
U.S. Environmental Protection Agency, Region 1
JFK Federal Building (SPN)
Boston, MA 02203
(617)565-1378
e-mail: mansur.sally@epamail.epa.gov
EPA Pollution Prevention and Regulatory
Assistance Contacts
New England Environmental
Assistance Team (NEEATeam)
U.S. Environmental Protection Agency, Region 1
JFK Federal Building
Boston, MA 02203
(800) 90-NEEAT
Internet Address: www.epa.gov/region01
Research Library - EPA Region I employs a full-time research librarian who can assist you with
questions concerning solid waste. To reach the regional research librarian, call (617) 565-3282.
WasteWise - WasteWise is an EPA program that promotes voluntary waste reduction through
prevention, recycling, and the purchase of recycled goods. Companies that commit to a waste
reduction receive technical assistance in achieving their waste reduction goals. For more
information on the WasteWise program or other solid waste or recycling issues, call (800) 372-
9473.
Tips Hotline - EPA Region I operates a centralized environmental tip and complaint hotline for
use by the general public. The number is (888) EPA-TIPS.
Small Business Ombudsman -- Our Small Business Ombudsman is Dwight Peavey, who can
be reached at (617) 565-3230.
Environmental Leadership Program -- The Environmental Leadership Program is for
companies that have a demonstrated commitment to compliance and pollution prevention.
Participants agree to a one year project to test innovative approaches to environmental protection.
Call (617) 860-4ELP for information.
Project XL (Excellence in Leadership) -- Project XL encourages tests of innovative strategies
that achieve cleaner and cheaper environmental results than traditional regulatory approaches.
Call Anne Kelley at (617) 565-3426.
Energy Conservation - EPA runs the Green Lights program for companies that want to reduce
their lighting expenses (sometimes by half) by upgrading lighting without compromising quality.
Call Norman Willard at (617) 565-3702.
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9.8 OSHA
The Occupational Safety and Health Act (OSHA) imposes a wide variety of important requirements on
industry, including lithographic printers. A discussion of these requirements is beyond the scope of this
manual. Because the costs of non-compliance with OSHA regulations can be quite significant, you should
ensure compliance with OSHA regulations, just as you should with environmental regulations. This
section lists the OSHA contacts in the New England states.
State OSHA Contacts
Connecticut
James P. Butler
Commissioner
Connecticut Department of Labor
200 Folly Brook Boulevard
Wethersfield, CT 06109
(806)566-5123
Samuel Moore
7(c)(1) Project Manager
Connecticut Department of Labor
200 Folly Brook Boulevard
Wethersfield, CT 06109
(806) 566-4550
Maine
Alan C. Hinsey
Director
Maine Bureau of Labor Standards
State House State #82
Augusta, ME 04333
(207) 624-6400
Lester Wood
7(c)(1) Project Manager
Maine Bureau of Labor Standards
Division of Industrial Safety
State House State #82
Augusta, ME 04333
(207) 624-6460
Massachusetts
Christine Morris
Secretary
Executive Office of Labor
MA Department of Labor and Industries
1 Ashburton Place, Room 2112
Boston, MA 02108
(617)727-6573
Joseph LaMalva
7(c)(1) Project Manager
Commonwealth of Massachusetts
MA Department of Labor and Industries
1001 Watertown Street
West Newton, MA 02165
(617)727-3982
New Hampshire
Charles E. Danielson, M.D.,
Director
NH Department of Health
and Human Services
6 Hazen Drive
Concord, NH 03301-6527
(603)271-4501
MPH
Stephen Beyer
7(c)(1) Project Manager
NH Department of Health
Division of Public Health Services
6 Hazen Drive
Concord, NH 03301-6527
(903)271-2024
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Rhode Island
Patricia A. Nolan, M.D., MPH
Director
Rl Department of Health
3 Capital Hill
Providence, Rl 02908
(401)277-2231
Vermont
Mary S. Hooper
Commissioner
Vermont Department of Labor and Industry
120 State Street
Montpelier, VT 05602
(802) 828-2288
Marie Stoeckel
7(c)(1) Project Manager
Rl Department of Health
Division of Occupational Health
3 Capital Hill, Room 206
Providence, Rl 02908
(401)277-2438
Robert McLeod
7(c)(1) Project Manager
Vermont Department of Labor and Industry
National Life Building, Drawer #20
Montpelier, VT 05602
(802) 828-2765
9.9 OTHER SOURCES
Regional Resources
Northeast Waste Management Officials' Association (NEWMOA)
129 Portland Street, Suite 601
Boston, MA 02114
(617)367-8558
NEWMOA offers:
- Regional list servers for printers
- CD-ROM information on P2 for printers
- P2 clearinghouse
- State referrals.
Northeast Business Environmental Network (NBEN)
56 Island Street
P.O. Box 806
Lawrence, MA 01842
(508) 557-5475
Internet Address: www.nben.org
NBEN offers:
- Value-added networking
- Non-political atmosphere
- Online research librarian
- Partnering opportunities
- A forum for best management practices.
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PRINTING-RELATED HOME PAGE SITES ON THE INTERNET
Printers' National Environmental Assistance Center (PNEAC) - The PNEAC is jointly
sponsored by the Illinois Hazardous Waste Research and Information Center (HWRIC), the
University of Wisconsin's Solid & Hazardous Waste Education Center (SHWEC), the Graphic Arts
Technical Foundation (GATF), and Printing Industries of America (PIA). The goal of the Center is
to provide information about the environmental impacts of printing, and effective means to achieve
compliance with environmental regulations.
Internet Address: www.inhs.uiuc.edu/pneac/pneac.html
GATF Home Page -- The Graphic Arts Technical Foundation (GATF) home page provides
information about GATF membership, workshops, products, services, NSTF scholarships, etc.
Internet Address: www.gatf.lm.com
PIA Home Page -- The Printing Industries of America (PIA) home page provides information
about PIA membership and a search feature to locate local PIA members.
Internet Address: www.printing.org
PINE Home Page - Printing Industries of New England (PINE) offers Environmental, Safety and
Health visits to your shop, at no cost, to assist in your understanding and compliance with federal
and state regulations. The PINE homepage provides information about membership and other
services.
Internet Address: www.pine.org
NAPL Home Page -- The National Association of Printers and Lithographers (NAPL) home page
describes NAPL, lists NAPL resources, equipment vendors and manufacturers, etc.
Internet Address: www.napl.org/napl/home.html
Envirosense: Printing P2 - This home page contains case studies, pollution prevention
practices, regulations, and vendor information of interest to printers.
Internet Address: www.seattle.battelle.org/es-guide/print/print.htm
U.S. Screen Printing Institute (SPI) -- This home page lists SPI products, services, industry
suppliers, etc.
Internet Address: www.usscreen.com
Craftnet Web Site -- The International Association of Printing House Craftsmen home page
describes the Craftsmen's clubs, seminars, etc.
Internet Address: craftnet.eas.asu.edu/welcome.html
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VIDEO RESOURCES
Green and Profitable National Videoconference -- A 2-hour video of the May 17, 1996, national
videoconference explaining compliance requirements and waste prevention and pollution
prevention techniques for lithographic printers.
Green and Profitable Printing Video Training Series - Four video modules that explore
practical waste reduction strategies for small and medium lithographic printers. The fee for this
series and accompanying viewer notes is $35, prepaid.
Both videos can be obtained from the University of Wisconsin Extension. Contact:
Marilyn McDole
University of Wisconsin-Extension
Solid & Hazardous Waste Education Center
610 Langdon Street, Room 529
Madison, Wl 53703
(608)262-0910
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MASSACHUSETTS
As part of a pilot program called the Massachusetts Printers
Partnership, Massachusetts has developed a workbook
which explains environmental requirements and pollution
prevention opportunities applicable to commercial printers.
Massachusetts plans to incorporate the workbook
standards into regulations in mid-1997. The workbook, as well as the information regarding
regulatory developments, is available at: http://www.magnet.state.ma.us/dep.
For more information call:
Nancy Wrenn
Bureau of Waste Prevention
Massachusetts Department of Environmental Protection
(617)292-5587
Massachusetts Requirements
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