MULTIMEDIA COMPLIANCE/POLLUTION PREVENTION ASSESSMENT
GUIDANCE FOR LITHOGRAPHIC PRINTING FACILITIES
Office of Enforcement and Compliance Assurance
1200 Pennsylvania Avenue, N.W.
Washington, DC 20044
June 1996
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NOTICE
The statements in this document are
intended solely as guidance. This
document is not intended, nor can it be
relied on, to create any rights
enforceable by any party in litigation
with the United States. EPA and State
officials may decide to follow the
guidance provided in this document, or
to act at variance with the guidance,
based on an analysis of specific site
circumstances. This guidance may be
revised without public notice to reflect
changes in EPA's policy.
Mention of trade names or commercial
products in this document or associated
references does not constitute an
endorsement or recommendation for use.
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TABLE OF CONTENTS
Page
Printing Industry Overview 1
1.1 Printing Processes 2
1.2 Process Description 3
1.3 Image Processing 6
1.4 Plate Processing 7
1.5 Makeready 10
1.6 Printing 10
1.7 Finishing 11
Assessment Protocol 12
LIST OF TABLE
Table 1. Printing Ink Constituents and Potentially Regulated Constituents 4
LIST OF FIGURE
Figure 1. General Flowsheet for Lithographic Printing Artwork, Copy, or Other Image . . 5
LIST OF APPENDICES
Page
APPENDIX A. MULTIMEDIA COMPLIANCE/POLLUTION PREVENTION
ASSESSMENT CHECKLIST FOR LITHOGRAPHIC PRINTERS A-l
APPENDIX B. MULTIMEDIA COMPLIANCE/POLLUTION PREVENTION
ASSESSMENT REPORT FORM FOR PRINTING FACILITIES B-l
APPENDIX C1. SELECTED REFERENCES RELATED TO POLLUTION
PREVENTION AND INNOVATIVE TECHNOLOGY Cl-1
APPENDIX C2. ANNOTATED BIBLIOGRAPHY OF SELECTED REFERENCES IN
APPENDIX Cl C2-1
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CHAPTER 1
PRINTING INDUSTRY OVERVIEW
The printing industry is a very diversified industry composed of firms who perform
printing as well as firms who render services for the printing trade, such as platemaking and
bookbinding. The industry also includes firms engaged on publishing newspapers, books, and
periodicals (regardless of whether they do their own printing). Many firms, though not classified
as part of the printing industry, perform printing and related activities. These include firms
performing textile printing; manufacturers of products, especially packaging, that contain
incidental printing; and manufacturers of printed circuit boards.
The total number of printing establishments in the United States is estimated to be
approximately 100,000. While the industry accounts for a significant portion of the nation's total
volume of goods and services, it also represents the largest group of small businesses in the
domestic manufacturing sector. Most printing plants employ fewer than 20 people and serve local
or regional markets.
The definition of the printing industry is based primarily on the Bureau of the Census'
definition as set forth under Standard Industrial Classification (SIC) Code Major Group 27—
Printing, Publishing, and Allied Industry. Major Group 27 is comprised of firms engaged in
printing by one or more common processes, such as lithography, letterpress, flexography, gravure,
and screen printing, as well as those entities that perform printing related services, such a
bookbinding, typesetting, and photoengraving. It also encompasses firms who publish
newspapers, books, and periodicals.
The SIC subgroups under 27 include the following:
271 - Newspapers
272 - Periodicals
273 - Books
274 - Miscellaneous (e.g., atlases, maps, calendars)
275 - Commercial Printing
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276 - Manifold business forms
277 - Greeting cards
278 - Blankbooks, Looseleaf Binders, and Bookbinding and Related Work
279 - Service Industries for the Printing Trade (typesetting, platemaking and related
services)
As shown in the above listing, those entities primarily involved in printing fall into SIC
subgroup 275 (Commercial Printing).
1.1 Printing Processes
The five most common printing processes in order of market share are lithography,
gravure, flexography, letterpress, and screen printing. The printing processes are distinguished by
the method of image transfer and by the type of image carrier (or plate) employed. Printed
images are transferred to the substrate either directly or indirectly. A substrate is any material
upon which ink is pressed. Direct printing processes are gravure, flexography, letterpress, and
screen printing. In direct printing, the image is transferred directly from the image carrier to the
substrate. In indirect (or offset) printing, the image is first transferred from the image carrier to
an intermediate cylinder called a blanket cylinder and then to the substrate.
Two kinds of presses used in printing are categorized by the form of paper or other
substrate (medium) used. Web presses, which are used for larger printing runs, print the image
onto a continuous roll (web) of paper. After printing, the paper is then cut and trimmed to the
proper size. Sheet-fed presses print on individual sheets. A discussion of individual printing
processes, and the products associated with those processes, is presented below:
Lithography is the predominant printing process in the U.S., and accounts for
approximately 50% of all printing applications. Sheet fed lithography is used for
printing books, posters, greeting cards, labels, packaging, advertising flyers,
brochures, periodicals, and for reproducing artwork. Web offset lithography is used
for periodicals, newspapers, advertising, books, catalogs, and business forms.
Gravure printing is used for large volume runs and high speed runs for printing high-
quality publications, magazines, catalogs, and advertising. It also has large volume
applications in the printing of flexible packaging, paperboard boxes, and labels.
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Flexography is a form of letterpress that uses a flexible plastic or rubber plate in a
rotary web press. Flexography is used primarily for packaging (plastic wrappers,
corrugated boxes, milk cartons, foil, and paper bags), and for imprinting large surface
areas. The use of flexographic printing techniques has increased with the amount of
packaging used in the U.S.
Web letterpress is used for some printing of newspapers and magazines, however, its
use is declining as the use of lithographic printing increases. Sheet-fed letterpress is
used for some books, printed stationery, announcements, business cards, and
advertising brochures. Because individual changes can be made on a plate without
having to redo the entire plate, letterpress is particularly useful for price lists, parts
lists, and directories.
Screen printing can print on virtually any substrate, including wood, glass, fabrics,
plastics, and metals. It is used for specialty printing such as T-shirts, posters, banners,
decals, and wallpapers. This type of printing makes up a small but growing segment of
the printing industry. Screen printing is also used to print patterns on electric circuit
boards prior to etching.
The principal raw materials used in the printing industry are inks and substrates. Other
raw materials used by the industry include gravure cylinders, photographic films, photoprocessing
chemicals (developers, fixers, wash baths, reducers, and intensifiers), printing plates, plate
processing chemicals, fountain solutions, cleaning solvents, and rags.
1.2 Process Description
Each of the printing processes can be divided into three major steps: prepress, press, and
postpress. Prepress operations involve a series of steps during which the idea for a printed image
is converted into an image carrier (i.e., printing plate, cylinder, or screen). Photoprocessing
chemicals and solutions are the major types of chemicals used during prepress operations. Press,
the actual printing operations, involve inks and cleaning solvents. The possible constituents in
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Table 1. Printing Ink Constituents and Potentially Regulated Constituents1
Vehicles / Varnishes
Rosin ethers
Long-oil alkyd
Phenolic resin
Hydrocarbon resin
Modified resin
Waxes
Mineral oils
Soya /vegetable
Resin / solvent varnishes
Drying oils
Urethanes
Pigments
Organic Pigments:
Carbon black
Organically derived pigments:
Rhodamines
AZO pigments
Inorganic Pigments:
Cyan blue and green shade cyan
Whites
Yellows
Reds
Solvents
Aliphatic hydrocarbons
Aromatic hydrocarbons
Alicyclic hydrocarbons
Co-solvent mixtures
Commonly Used Chemical Formulations
Rosin and pentaerythritol
Phthalic anhydride and glycerol
Phenol and formaldehyde
Ethylene, butadiene and indine
Maleic acid and maleic anhydride
Natural and synthetic
Natural and synthetic
Linseed, tall, soybean and safflower oils
Variety of hydrocarbon solvents
Alkyd, urethanes and phenolic resins
Toluene diisocyanate and trimethylol propane
Graphite
Benzene, Naphthalene and Anthracene derivatives
Copper Phthalocyannine
Calcium carbonates, clays and titanium dioxide
Lead, chromium
Barium
Parafins
Benzene
Cycloparafins, terpenes
Alcohols and hydrocarbons
' Information for this figure derived from Chemistry For the Graphic Arts. Ellred, 1992. Environmental Law Index to Chemicals.
'Taken from University of Northern Iowa. Iowa Waste Reduction Center, 1995. Pollution Prevention Manual for
Lithographic Printers.
printing inks are shown in Table 1. Postpress involves the assembly of printed materials and
consists of binding and finishing operations. Large amounts of adhesives are often used in the
production of books and directories.
Figure 1 illustrates the steps involved in a typical offset lithographic printing operation.
Printing begins with the preparation of artwork or copy, which is photographed to produce an
image. A proof is made which is then used to compare with the printed product and make
adjustments to the press. The photographic image is transferred to a plate. In the platemaking
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step, the image areas of the plate are made receptive to the ink. In the printing step, ink is applied
to the plate, then transferred to a rubber blanket and then to the substrate.
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Film
Photoprocessing
Chemicals
(concentrate &
water)
Plats form Storage or Plate
Manufacturer
Plate Processing Chemicals
Ink
Paper
Fountain Soluicn
hk
Paper
Fountain Solution
Cleaning Solvent
Rags
Used Rim
Waste water
Silver Recovery
Trash
•ves
Platemaking
i
Imac
i
Make ready
Prinling and
Drying
Unfrimnned
Uhbound Products
Waste water
Trash
Paper to Recycling
VOCs
Waste Irk
Em ply Ink Containers
Paper Wrap to Trash
Paper to Recycling
VOCs
Waste Irk
Dirf Rags
Used Plates
Empty Ink Containers
Rubber Blankets
Finishing
Waste Paper Trimmings
VOCs
Waste Glue
Adapted from U.S. Environmental Protection Agency Guides to Pollution Prevention - The Commercial Printing Industry
(EPA/625/7-90/008), August 1990.
Figure 1. General Flowsheet for Lithographic Printing Artwork, Copy, or Other Image
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The substrate accepts the ink, reproducing the image. The substrate is then cut, folded,
and bound to produce the final product. Printing can generally be divided into five steps:
(1) image processing; (2) platemaking; (3) makeready; (4) printing; and (5) finishing. Each of
these steps is discussed in greater detail below.
1.3 Image Processing
Most printing operations begin with art and copy (text) preparation. Once the material is
properly arranged, it is photographed to produce transparencies. If an image is to be printed as a
full color reproduction, then color separations are made to provide a single-color image or record
which can then be used to produce the single color printing plate. (Multi-color printing is done by
passing the substrate through several single-color printing operations.) Once the film has been
developed and checked for accuracy it is sent to the plate- or cylinder-making operation.
The printing industry employs photography in the reproduction of both artwork and copy.
The materials used include paper, plastic film, or glass base covered with a light sensitive coating
called an emulsion. This emulsion is usually composed of silver halide salts. (Silver halides
include silver chloride, silver bromide, and silver iodide.)
After a photographic emulsion has been exposed, it must be developed. The exposed
emulsion is immersed in a developer, which converts the silver halides to metallic silver on the
film. Developers typically contain benzene derivatives, along with an accelerating agent (to speed
up the developing process), a preservative (to reduce oxidation damage to the developer), and a
restrainer (to prevent image "fogging").
The developing action is stopped by a fixing bath. Each time a photographic image is
immersed in a fixing bath, a small amount of silver enters the bath from the emulsion. Insoluble
compounds that are formed after the silver concentration reaches a certain level cannot be
removed from the emulsion, so the fixer must be diluted prior to reaching this level. The critical
silver concentration for fixing baths is 0.27 ounces per gallon (2 grams/liter).
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After the image has been fixed to the emulsion, it is washed to prevent residual chemicals
from reacting and damaging the image. Washes are usually water, with a temperature of 80 °F,
and a pH of 4.9 or higher. In some photoprocessing, chemicals are applied to the emulsion to
reduce or increase the image contrast. Reducers act by oxidizing some of the silver; intensifiers
add silver or mercury to the developed silver grains in the emulsion. A proof is produced after the
image processing step as a part of internal job control. The proof shows whether all the elements
are in line, whether the color is right, and how the job will look when it is printed. Press proofs
(used in multi-color printing) are more expensive because they require a press and printing plates
and cylinders. Press proofs are used with gravure and letterpress printing because the
platemaking and cylinder-making steps will affect tone reproduction. Off-press proofs, also used
for color printing, are usually produced photographically and are used to check camera and
scanner separations and corrections.
Image processing wastes typically include spent developer, spent fixer, contaminated wash
water, silver, waste paper, and associated photodeveloping chemicals.
An example of innovative technology in image processing is the electronic prepress, or
computer image processing. The objective of this technology is to use computer systems to
electronically construct a completely digital master copy. Text can be prepared using a computer
to create disk files, page layout, graphics and typesetting, while images can be scanned in or
created with digital cameras. The digital cameras digitize the image and store it or send it to a
computer for editing or enhancement.
1.4 Plate Processing
Printing involves the use of an image carrier, that is a plate or cylinder that accepts ink off
a roller and transfers the image to a rubber blanket. The blanket, in turn, transfers the image to
the substrate. The type of ink and press used, number and speed of impressions that can be
generated, and the characteristics of the image are all determined by the type of image carrier.
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The types of image carriers include the following:
Photomechanical plates—these image carriers use light sensitive coatings on which
images are produced photographically. Photomechanics is capable of reproducing
photographs and other pictorial objects. This is the most common form of
platemaking.
Electrostatic plates—an electrophotographic camera converts an image to a
lithographic plate used in a copier/duplicator. Electrostatic plates are also used for
laser platemaking and newspaper printing.
Mechanical plates—used mainly for relief printing where either a hot metal or
duplicate plate is etched or engraved. Mechanical plates are used for paper currency,
certificates, textiles, wallpaper, and plastics.
Manually set plates—hand set composition, wood cuts, linoleum blocks, copperplate
or steel-die engravings that are seldom used except for screen printing.
In lithographic printing, plates have image and non-image areas on the same plane with the
image areas being ink-receptive and the non-image areas being water-receptive. This is possible
through a chemical change on the coated plate surface, resulting from a photochemical process in
the light sensitive coating. Many printing facilities use pre-sensitized plates, where the light
sensitive coatings are applied by the manufacturer. Three methods used to make lithographic
plates are the following:
Surface plates—These plates have a light-sensitive coating that becomes ink-
receptive when exposed. In additive plates, the hardened areas become ink-receptive
through the addition of an oleophilic resin contained in an emulsion developer.
Chemicals used in this process are described below:
- Light-sensitive materials in coatings include azide compounds, hydrazine
derivatives, quinone diazides, and quinone esters.
Emulsion developer has a solvent phase containing oleophilic resin and pigment
and a water phase containing gum arable and acid.
Aluminum or anodized aluminum is often used for lithographic surface plates.
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Deep-etch plates—In these plates, the coating in the exposed non-image areas
hardens, while the unexposed image areas are soft. A developing solution washes the
image area away and the stencil remains. Chemicals used in this process are described
below:
- Developing solutions are generally calcium, zinc, or magnesium chloride combined
with a mild acid.
Image area is plated with copper and/or coated with lacquer (polyvinyl chloride,
polyvinyl acetate, and malic acid).
- Non-image areas are treated with a desensitizing etch and gummed with gum
arable solution.
These plates are generally not used because of cost, heavy metal toxicity, and
wastewater discharge problems.
Bimetal plates—These plates have a long lifetime because the image and non-image
areas are composed of two different metals. These plates are also generally not used
because of metal toxicity and wastewater discharge problems.
An example of innovative technology in printing processes is the waterless system. In this
system, plates are made of unanodized straight-grain aluminum coated with a light-sensitive
photopolymer layer followed by a thin silicone rubber layer. The rubber layer causes ink to be
repelled from the non-image area. The top layer of the plate is a thin transparent film that is not
removed during exposure. The plates are exposed to ultraviolet (UV) light in a vacuum frame,
where the UV light activates the photopolymer, breaking its bond with the silicon. After
exposure, the protective cover film is removed and the plates are processed in a special processor
or by hand. The waterless plate processor uses two specialized chemicals and tap water as the
developer. The developer contains a blue dye solution which is used only on the surface of the
plate and never discharged. In this process, a minimal amount of solution (i.e., 5 gallons) can
process 1,000 to 1,200 40-inch plates. The combination of silicone/photopolymer allows the plate
to print without water, etches or alcohol.
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Typical plate processing wastes include alkalis, solvents, plate coatings (dyes,
photopolymers, binders, resins, pigments, organic acids), plate developers (isopropanol, gum
arable, lacquers, caustics), wastewater (i.e., rinse water) and used plates.
1.5 Maker eady
Makeready refers to the last pre-printing step, where all the preparations are assembled
and tested prior to the printing run. In the makeready process, the inks, colors, plates, and other
preparations are put on the printing press and a small batch is run to ensure that everything is in
order. After the makeready run is completed, the product can be inspected, and any adjustments
to the press, colors, or plates can be made.
Makeready is the process that produces the largest amount of waste, mostly in the form of
paper and ink. This is due to the need to print any number of small runs to obtain the precise
alignment, color combination, and other requirements prior to commencing the printing run.
Other wastes generated in this process include volatile organic compounds (VOCs) and empty ink
containers.
1.6 Printing
After the plates have been prepared, printing can begin. Printing operations are generally
the same for each of the major processes (except screen printing). Preparation for printing begins
with attaching the plate cylinder to the press. Virtually all presses print from a cylinder, as
opposed to a flat plate. Each unit of a printing press prints a single color. To print a full color
illustration, units for magenta, cyan, yellow, and black are required.
After the plate has been attached to the cylinder, it is mechanically rotated and the non-
image area is treated with an ink-repelling solution. The plate is then coated with the ink, which
adheres only to that portion of the plate that contains the image. As the plate continues to rotate,
the inked image is transferred to the rubber blanket and then to the substrate. The two major
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forms of substrate in lithography are single sheets of paper (sheet-fed) and continuous rolls (web).
After printing, the substrate may pass through a drying operation depending upon the type of ink
used.
Typical printing wastes include: waste paper from off-specification printing runs, ink,
rags, solvents, wastewater from press washing, and miscellaneous printing chemicals.
1.7 Finishing
Finishing refers to the final treatment and handling of the product prior to delivery to the
client. Depending upon the requirements of the print run, finishing may involve only trimming the
excess paper from a web-press run, to laminating and heat treating a full color poster. Typical
finishing activities may involve any or all of the following steps: collating, binding, trimming,
embossing, flocking and die-cutting. Finishing also refers to any one of a variety of treatments
used on printed goods, including lacquers, waxes, and laminating.
The primary wastes involved in the finishing process include VOCs and waste paper.
VOCs are released during the drying process as the solvents contained in the inks volatilize and
escape into the atmosphere. Common solvents include benzene, toluene, naphthalene, acetone,
and alcohols. Waste paper is produced during the cutting, trimming, and final production.
Printing overruns also contribute to the waste paper stream. Ancillary wastes generated during
the finishing process may include scrap glues, fabrics, plastics, and laminates.
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CHAPTER 2
ASSESSMENT PROTOCOL
The primary purpose of the multimedia assessment protocol for printing facilities is to
determine compliance with regulations that apply to air emissions, hazardous wastes, industrial
wastewater and the use of toxic substances associated with printing processes. Determination of
compliance with any regulations that are not specifically associated with any of the printing
processes (e.g., the TSCA regulations on PCBs) is not part of this assessment protocol. The
assessment protocol also focuses on encouraging pollution prevention and innovative technology
by identifying potential pollution prevention and innovative technology opportunities that could
move the facility beyond compliance to overall improved environmental quality.
The multimedia assessment will utilize a process-based approach in which the inspector
identifies noncompliance with any applicable media or program specific regulation (air, water,
solid waste) as well as pollution prevention and innovative technology opportunities as part of the
assessment of individual printing processes.
This assessment protocol serves as a reference for the conduct of these assessments, and
includes procedures, an assessment checklist, and an example assessment report. It focuses on
lithographic printing facilities only, and addresses prepress (image processing and platemaking),
press (makeready and printing), and postpress (finishing) operations. An overview of lithographic
printing processes is contained in Section 1 of this guidance.
The following activities are part of the multimedia compliance assessment protocol:
• Pre-assessment preparation
On-site activities
Opening conference/discussion
Facility walk-through
— Materials storage area
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— Process areas
— Waste management areas
— Records/permits/documentation review
- Closing conference/discussion
• Preparation of assessment report
• Follow-up activities.
Each of these activities is briefly described in the assessment procedures discussed below.
During this multimedia compliance assessment, the inspector should generally follow
procedures outlined in EPA Basic Inspector's Training Manual.
Pre-Assessment Preparation
The inspector should review any existing information on the facility including any previous
noncompliance problems, and determine whether the facility is in a non-attainment area. Using
the available information, he/she should complete Section I, General Facility Information, of the
Assessment Checklist which covers general aspects of the regulatory programs to be covered
during this assessment (i.e., air, hazardous wastes, wastewater, and use and releases of toxic
substances). This information can then be verified during the assessment.
Prior to an assessment, the inspector should become familiar with lists such as (1) the
EPCRA list of extremely hazardous substances and their threshold planning quantities, (2) the
CERCLA list of hazardous substances and their Superfund reportable quantities, and (3) the
EPCRA list of toxic chemicals. Because these lists should also be available for reference (if
necessary) during an assessment, the inspector should carry a copy to the facility at the time of the
assessment.
On-site activities
Opening conference/discussion—During the opening conference/discussion, it is
important that the inspector point out that, in addition to the more traditional objective
of compliance evaluation, the assessment focuses on providing compliance assistance
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to the facility and identifying potential pollution prevention and innovative technology
opportunities. Thus, assessment questions will address raw materials used,
housekeeping procedures and process modifications as well as wastes generated.
The inspector should verify the information in Section I, General Facility Information,
of the checklist and obtain any missing information. These questions are intended to
obtain an overall general evaluation of the regulations that apply to the facility
(including whether the facility currently has any permits). In addition, the printing
processes at the facility should be discussed, and a schematic prepared.
Walk-through of facility—The Assessment Checklist is designed to walk-through the
facility in a process-oriented manner, addressing these activities sequentially:
General housekeeping/materials storage (including raw materials information)
- Image processing
Platemaking
Printing
Cleaning activities
- Waste handling and management.
For each of these areas, applicable media-specific compliance questions and pollution
prevention, innovative technology and recycling questions are included in the checklist.
General Housekeeping/Materials Storage
General housekeeping/materials storage is a separate section of the checklist, although
evaluation of these activities should be ongoing throughout the assessment of the facility.
Specifically, the inspector should be observing operation and maintenance and housekeeping
throughout the facility walk-through in the storage areas, process areas, and waste management
areas. The walk-through of the facility should begin at the receiving area and storage area for raw
materials.
Image Processing, Platemaking, Printing, Cleaning Activities, and Finishing
For each process or activity listed in the checklist, the inspector should verify the
following for each process or activity (using the checklist questions):
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• Description
• Types and amounts of materials used
Types and amounts of wastes generated
General condition.
The checklist contains notes for the inspector regarding compliance issues with respect to
individual wastes.
For each type of waste generated by the process or activity, the inspector should inquire
about general or specific pollution prevention techniques and innovative technology as presented
in the checklist.
When examining the process or activity areas, the inspector should document any evidence
of noncompliance that presents an imminent threat to human health or the environment (e.g., leaks
or spills of hazardous materials). He/she should take immediate action to notify (1) the facility of
the situation and (2) the appropriate program office for follow-up action.
The checklist is meant only as a guide for questions, and the inspector should ask any
other questions to obtain additional information or clarify answers.
The inspector should note any transfer of wastes from one media to another resulting from
process operations.
Waste Handling and Management
The waste handling and management section of the checklist is organized by type of waste
being managed and includes wastewater, hazardous solid wastes, and air emissions. This part of
the assessment will generally involve hazardous wastes storage containers, wastewater treatment
equipment, and air pollution control equipment. However, silver recovery units, may be examined
as part of image processing, depending on where the silver recovery unit(s) are located in the
facility.
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For the waste handling and management areas, the inspector should verify the following
(using the appropriate checklist questions):
• Air and wastewater:
Any existing permits and permit requirements
Type of treatment process
- Condition of treatment equipment
Any noncompliance.
• Hazardous solid wastes:
Any existing permit (if TSD facility)
- Condition of storage containers and storage area
Length of storage
Waste transportation
Any noncompliance.
Evaluation of these areas will also involve records review. For example, if a facility has a
wastewater permit, the inspector should review the permit for selected requirements (e.g., limited
parameters and self-monitoring frequency) and then assess compliance with these requirements.
All violations should be documented. The sections in the checklist that will likely require records
review are appropriately marked.
The inspector should identify any media transfer of wastestreams resulting from pollution
control/management practices (e.g., generation of sludges from wastewater treatment or
generation of scrubber water from air pollution control equipment).
• Closing Conference/Discussion
As part of the closing conference/discussion, the inspector should do the following:
- Convey the results of the assessment to the facility including all obvious violations
noted
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Clarify information obtained and ask any outstanding questions
Discuss general potential pollution prevention and innovative technology
opportunities
Distribute general or printing-specific compliance assistance literature
Distribute general or printing-specific pollution prevention or innovative
technology literature
Distribute list of selected references (Appendix C in this guidance)
Provide contacts at appropriate agencies that give compliance or technical
assistance (e.g., hotlines, technical assistance offices).
The inspector should communicate to the facility that all results are preliminary until
follow-up review is completed.
Preparation of Assessment Report
After the assessment, the inspector should complete the assessment report form in
Appendix B. This form contains sections for results of both compliance assessment and
identification of pollution prevention and innovative technology opportunities:
Compliance assessment sections—The inspector should note any actual and
potential violations identified during the assessment.
Pollution prevention sections—The inspector should at a minimum provide a list of
opportunities identified based on the checklist questions. However, the checklist
questions do not cover the full range of potential opportunities for printing processes.
If the inspector has additional time and the appropriate references [such as those listed
in the selected reference list (Appendix Cl)], he/she can identify other potential
opportunities that can be listed in the assessment report.
Follow-Up Activities
After the assessment, the inspector will be responsible for recommending what follow-up
actions should be taken. At a minimum, the inspector should provide a report to the facility
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(example report form shown in Appendix B) that contains a compliance assessment (with list of
actual or potential violations) and list of pollution prevention opportunities (including innovative
technology). Additional potential follow-up actions to be taken include the following:
• Referral to specific program office for comprehensive follow-up inspection
• Referral to technical assistance office for follow-up assistance
• Follow-up inspection to determine if facility implemented pollution prevention
techniques.
After conferring with his/her supervisor, the inspector may take one or more of these
actions depending on the particular findings of the assessment. In some States there are special
programs targeted at printing facilities. For example, the Washington Department of Ecology has
a program called Snapshots in which inspectors provide compliance assistance during visits to
printing facilities and also provide the facility with a summary report containing actions that it
should undertake. The State is planning follow-up inspections to determine if the facilities have
completed these actions.
In some situations the inspector may decide that it is appropriate to refer the facility to a
media-specific program office because violations that could potentially pose a significant risk to
human health or the environment were found during the assessment. In any case, the appropriate
follow-up actions should be determined in coordination with the inspector's supervisor and
applicable enforcement policies.
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APPENDIX A
MULTIMEDIA COMPLIANCE/POLLUTION PREVENTION
ASSESSMENT CHECKLIST FOR LITHOGRAPHIC PRINTERS
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION
A. General Facility Operations
(1) When did the facility begin operations?
(2) Have there been previous printing operations at this location?
(3) What are the facility's hours of operation?
(4) What types of printing is done at the facility?
Heatset
Nonheatset Sheet
Nonheatset Web
Yes
No
(5) Describe the printing system. Complete schematic on page A-2 by listing raw materials used and
wastes generated for each process/activity. If possible, obtain a copy of a schematic or process
diagram from the facility.
Complete Table 1 (pages A-3 and A-4) by listing wastes generated by process/activity, quantity
generated, disposal method, and whether the waste is hazardous or nonhazardous.
A-l June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
A. General Facility Operations (Continued)
Schematic of Printing Operations (Example Diagram Included)
Raw Materials Wastes Generated
Image
Processing
Proof
Platemaking
Makeready
Printing and
Drying
Finishing
Final Product
Housekeeping
A-2
June 1996
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Table 1. Summary of Wastes Generated, Quantity, and Disposal Methods
Type of Wastes Generated (including EPA and
State code if applicable)
Quantity Generated
per Month
Disposal Method(s)
Hazardous or
non-hazardous ?
General Housekeeping/Materials Storage
Image Processing
Platemaking
s
n
-------
Table 1. Summary of Wastes Generated, Quantity, and Disposal Methods (Continued)
3
n
Q.
Type of Wastes Generated (including EPA and
State code if applicable)
Quantity Generated
per Month
Disposal Method(s)
Makeready/Printing
Cleaning Activities
Finishing
n
o
o_
5'
n
n^
^
o
o
*0
i
n
n
p^-
o'
n
«-f-
n
Sf
n
n
*•
Total Hazardous Waste Generated Per Month
Total Acute Hazardous Waste Generated Per Month
-------
Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
A. General Facility Operations (Continued)
(7) Has a pollution prevention or waste minimization plan been developed by the facility?
If yes, under which program(s)?
Yes
No
Yes
No
(8) Has the facility evaluated which wastes are probable candidates for reductions
through pollution prevention activities (i.e., has the facility identified or
implemented any process chemical changes to reduce air emissions or hazardous
waste generation)
If yes, list the wastes and describe pollution prevention activities currently being undertaken.
(9) What type of training activities are conducted at the facility?
(10) Have employees been trained in the fundamentals of pollution prevention?
Yes
No
B. Wastewater
(1) Does the facility discharge wastewater into:
Surface Water?
Municipal Sewer?
Subsurface
System?
Receiving Stream
NPDES Permit No.
Name of WWTP
Permit No. (if applicable)
Type
A-5
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
B. Wastewater (Continued)
(2) In the following table, indicate the volume of wastewater discharged by type and dis
Wastewater
Type
Sanitary
Process(es)
Noncontact Cooling
Storm Water
Other
Total
Surface
Water
Municipal
Sewer
Disposal
Subsurface
System
posal method.
Other
Notes to Inspector:
If the facility does not know the volume of its sanitary waste discharge, it can be estimated by multiplying
the number of employees by the residential equivalent units estimate of 25-35 gallons per day per worker.
Storm water discharges only apply to outdoor, exposed industrial areas. Industrial areas are defined as
areas where material handling equipment or activities, raw materials, intermediate products, final products,
waste materials, by-products, or industrial machinery are exposed to storm water.
C. Air
Yes No
(1) Is the facility located in an area designated as nonattainment for the National Ambient
Air Quality Standard for Ozone?
(2) Is the facility designated as a major source of:
• VOCs?
• NOx?
• Hazardous Air Pollutants (HAPs)?
Yes No
A-6
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
C. Air (Continued)
(3) If yes, is the facility subject to applicable Reasonably Available Control Technology
(RACT) requirements for lithographic printers?
Yes
No
(4) Indicate types and estimated amounts of air emissions (e.g., VOCs) from various sources.
Type of Emissions
(e.g., VOCs)
Source
(e.g., Cleaning Tank)
Amount
Notes to Inspector:
The mass balance method can be used to estimate VOC emissions. An example of a mass balance to
calculate VOC emissions is presented below:
Example: A printer's chemical usage for one year is ink (10,000 Ibs, 15% VOC content), alcohol (1,000
gallons, density 6.0 Ibs/gallon), and press wash (1,000 gallons, 50% VOC and specific gravity 0.7). 100 Ibs
of ink are disposed of in waste shipments.
First, determine how many pounds of each chemical is used.
ink = 10,000 Ibs
alcohol = 1,000 gallons x 6 Ibs/gallon = 6,000 Ibs
presswash = 1,000 gallons x (0.7 x 8.34 Ibs/gal) = 5,838 Ibs
Next, determine the annual amount of VOCs used by multiplying the pounds used by the VOC fraction.
ink = 10,000 Ibs x 0.15 = 1,500 Ibs
alcohol = 6,000 Ibs x 1.0 = 6,000 Ibs
press wash = 5,838 Ibs x 0.5 = 2,919 Ibs
Emissions of VOCs can now be estimated by subtracting the disposed amount (or the amount remaining with
the product) from the amount used.
discarded ink = 100 Ibs x 0.15 = 15 Ibs
1,500 Ibs (from second step) - 15 Ibs = 1,485 Ibs
press wash disposed of in
cleaning cloths = 500 Ibs
2,919 (from second step) - (500 Ibs x 0.5) = 2,669 Ibs
Total VOC emissions are 1,485 Ibs (ink) + 6,000 Ibs (alcohol) + 2,669 Ibs (press wash) = 10,154 Ibs
A-7
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I.
c.
(5)
GENERAL FACILITY INFORMATION (Continued)
Air (Continued)
i
Was equipment installed under New Source Review requirements?
tes No
If yes, to which of the following is the equipment subject? Check the one that applies.
| ( Major source best available control technology (BACT) requirements under prevention of
significant deterioration (PSD)
| j Lowest achievable emission rate (LAER) requirements for nonattainment areas
| Minor source State or local new source review (NSR) requirements
(6)
i
Does the facility have a permit?
Permit ID
tes No
If yes, does the permit cover any of the following activities? Check any that apply.
| ( Construction/operation of presses, control devices, distillation units and proofing and/or
binding equipment
| Operation of existing presses, control devices, distillation units and/or proofing and binding
equipment
| ( Modification of existing equipment or changing materials (e.g., inks, fountain solutions,
cleaning solvents, etc.)
D.
(1)
(2)
Emergency Planning and Community Right-To-Know
i
Does the facility have on-site any of the Extremely Hazardous Substances (EHS) in
excess of the established threshold planning quantities?
If yes, list substances.
If hazardous chemicals are present in excess of 10,000 Ibs., have the material N/A ^
safety data sheets (MSDS) (or a list of chemicals) and chemical inventory forms
departments?
tes No
tes No
A-8
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
D. Emergency Planning and Community Right-To-Know (Continued)
N/A
(3) Was the State Emergency Response Commission ^SERCj and Local
Emergency Planning Committee (LEPC) notified of the presence of hazardous
chemicals for local planning purposes?
(4) Has the facility released an extremely hazardous substance (EHS) or a CERCLA
hazardous substance in excess of the Superfund reportable quantity?
• If yes, was notification of the release provided?
• To whom?
Yes
No
Yes
No
• Was notification oral or written?
• Was oral notification followed up by written notification?
(5) Does the facility have Material Safety Data Sheets (MSDS) readily available for all
hazardous chemicals used? (OSHA requirement)
Yes
No
Yes
No
E. EPCRA Section 313 - Toxic Release Inventory
(1) Does the facility have ten or more full-time employees?
(2) Did the facility use more than 10,000 Ibs. of at least one toxic chemical
during a previous calendar year?
N/A
If yes, did the facility file a Section 313 Toxic Chemical Release Inventory
Yes
No
Yes
No
Yes
No
Form R for the chemical(s)?
F. Hazardous Wastes
(1) Does the facility generate hazardous wastes from printing activities?
Yes
No
A-9
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
F. Hazardous Wastes (Continued)
Yes
No
(2) Does the facility have an EPA ID No. ?
EPA ID No.:
Yes
No
(3) Is the facility's waste determination method (i.e., to determine whether
a waste is hazardous or nonhazardous) adequate?
(a) Does the facility determine if its waste is excluded from regulation under Part
261.4(b) (i.e., solid wastes which are not hazardous wastes, such as household
waste)?
(b) If no, does the facility determine if the waste is listed in Part 261, Subpart D
(examples of listed wastes typically found in the printing industry include
tetrachloroethylene, methylene chloride, xylene, and acetone)?
If yes, does the facility determine if the waste has been excluded from the
lists in Subpart D or Part 261.3 in accordance with 260.20 or 260.22
(which allows petitions to amend Part 261 to exclude a waste produced at
a particular facility)?
If no, does the facility determine if the waste exhibits any of the
characteristics specified in Part 261, Subpart C (for example,
characteristics of ignitability, corrosivity, reactivity, and EP toxicity)?
(4) Is the facility a
Yes
No
Yes
No
Yes
No
Yes
No
Large quantity generator?
Small quantity generator?
Conditionally exempt small quantity (CESQG) generator?
A-10
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
F. Hazardous Wastes (Continued)
Notes to Inspector:
Check amounts in Table 1 to determine appropriate classification for facility.
Large quantity generator (LQG) generates 1000 kgs (2200 Ibs) of hazardous waste (HW) or more per
month. The waste must be shipped in 90 days and there is no limit to the amount that may be accumulated.
Small quantity generator (SQG) generates between 100kg (220 Ibs) and 1000kg (2200 Ibs) nonacute HW
in a calendar month. The waste must be shipped in 180 days and is limited to accumulating no more than
6000kg (13200 Ibs) HW on-site.
A conditionally exempt small quantity generator (CESQG) generates no more than 100kg (220 Ibs) HW in
a calendar month and accumulates less than 1000kg (2200 Ibs) on-site; OR, generates less than 1kg (2.2
Ibs) acute HW in a calendar month and accumulates less than 100kg (220 Ibs) acute HW.
(5) Excluding CESQGs, are the hazardous wastes at the facility consistent with
generator notification records (i.e., are wastes generated for which the facility
has not notified State or EPA?)
(6) What are the hazardous wastes management practices? Check all that apply.
On-site: Satellite Accumulation [ |
N/A
Yes
No
Container storage
Tank storage
Treatment
Disposal
Other
D
D
A-ll
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
F. Hazardous Wastes (Continued)
(7) Does the facility generate wastes that are restricted from land disposal
(i.e., liquid hazardous wastes having a pH < 2.0; liquid hazardous wastes containing
halogenated organic compounds at > 1,000 mg/L)?
If yes, does the facility comply with Part 268 for land disposal restricted wastes?
Yes
No
Yes
No
G. Toxic Substances Control
(1) Does the facility import any chemical substances (e.g., ink)?
If yes, has the facility completed the appropriate certification statement?
Yes
No
N/A
Yes
No
II. PROCESS EVALUATION
A. General Housekeeping/Materials Storage
Note to Inspector:
Check Table 1 (i.e., Summary of Wastes Generated, Quantity, and Disposal methods) to verify wastes
generated as you complete this section of the checklist.
(1) Note any potential or actual problems regarding housekeeping and storage (e.g., air emissions,
hazardous and nonhazardous solid wastes, and wastewater).
(2) Is the shop clean and orderly to prevent accidents and spills?
(3) Does the facility use spigots and pumps when dispensing raw materials?
Yes
No
Yes
No
A-12
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
A. General Housekeeping/Materials Storage (Continued)
(4) Does the facility use funnels for transferring wastes to storage containers?
(5) Does the facility implement dry methods for cleanup whenever possible?
(6) Does the facility have a spill prevention plan?
Yes
No
Yes
No
Yes
No
Note to Inspector:
Some POTWs may require printing facilities to develop spill prevention (or slug control) plans that include
the following:
• Description of discharge practices, including non-routine batch discharges
• Description of stored chemicals
• Procedures for immediately notifying the POTW of slug discharges
• Procedures to prevent adverse impacts from spills
(7) Does the facility have any floor drains leading directly to the sewer where the solvent
or ink is stored?
Yes
No
If yes, in the event of a spill, will contaminants enter the floor drains?
N/A
Yes
No
If yes, what is the characteristic of wastewater contained in the floor drains and where do the floor
drains discharge?
(8) Does the facility use a "first-in first-out" policy to avoid the expiration of raw
materials?
(9) Are infrequently used materials ordered in small containers?
Yes
No
Yes
No
A-13
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
A. General Housekeeping/Materials Storage (Continued)
(10) Are frequently used materials ordered in large containers?
(11) Can the facility store products in locations that will preserve their shelf life?
(12) If materials have exceeded their shelf life, are alternative uses considered before
discarding?
(13) Does the facility purchase materials from manufacturers that will accept
returned materials if shelf life is exceeded?
Yes
No
Yes
No
N/A
Yes
No
N/A
Yes
No
B. Image Processing
a. General
(1) Is image processing done at the facility?
Yes
No
Note to Inspector:
Check Table 1 (i.e., Summary of Wastes Generated, Quantity, and Disposal Methods) to verify wastes
generated as you complete this section of the checklist.
Typical wastes from image processing include the following: used film, process solutions containing
photographic chemicals (fixer and developer) and silver (dissolved from processing film).
Typical hazardous wastes generated from image processing include: developers and fixers. Most developers
contain levels ofhydroquinone. If disposed of as an unused product it may be defined as a hazardous waste
in applicable State regulations due to the concentration ofhydroquinone. If the hydroquinone is consumed
during use and does not show up in used developer, it is not considered hazardous. Fixers which allow
silver to dissolve out of the film and paper can contain up to 4,000 ppm silver. Any solutions containing
silver at concentrations greater than 5 ppm are considered hazardous wastes.
In addition, some POTWs may have limits for silver in industrial discharges that are below 5 ppm. The
facility should be aware of the applicable silver limits for its discharge.
A-14
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
B. Image Processing (Continued)
(2) Note any potential or actual problems regarding image processing with respect to air emissions,
nonhazardous and hazardous solid wastes, and wastewater.
b. Process Solutions
(1) List the chemicals/solutions and amounts used for:
Type
Developer
Fixer
Stop Bath
Amount
(2) How are bath solutions currently monitored?
(3) Are bath solutions changed on a set schedule?
If yes, what is the schedule?
Yes
(4) With respect to the process bath, does the facility do any of the following:
Add ammonium thiosulfate to silver-contaminated baths to extend the allowable
build-up of silver?
Prolong the potency of oxidation process baths by reducing their exposure to air?
Routinely monitor pH?
Yes
Yes
Yes
No
No
No
No
A-15
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
B. Image Processing (Continued)
(5) Does the facility use squeegees following all processing solutions and washes in
automatic processing machines?
Yes
No
Note to Inspector:
Squeegees can significantly reduce the amount of solution carried out of the bath on the film. This reduces
bath changeouts and replenishment rates. Types of squeegees include wiper blades, air squeegees, vacuum
squeegees, wringersling squeegees, and rotary-buffer squeegees.
(6) Does the facility use water recirculation units to reduce water use and wastewater
generation?
(7) If the facility uses multiple rinses, is counter current rinsing used?
N/A
Yes
Yes
No
No
Note to Inspector:
If no, water recirculation units can reuse photoprocessing bath waters but filters from water recirculation
units require disposal and may be considered hazardous wastes.
N/A
Yes
Yes
(8) Is an automatic film processor used?
If yes, is a continuous rinse used?
How often are the processor's chemical tanks cleaned out?
c. Silver Recovery
(1) Does the facility use any of the following on-site silver recovery techniques to reduce silver
concentrations in the discharge? (Check any that apply.)
No
No
Electrolytic silver recovery
Automatic recirculating silver recovery
Metallic replacement canisters
Ion exchange units
Other (specify)
A-16
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
A-17 June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
B. Image Processing (Continued)
(2) Does the facility ship wastes for off-site silver recovery?
Yes
No
Notes to Inspector:
Several on-site and off-site silver recovery methods are available.
• On-site units include the following: electrolytic silver recovery (ESR) and metallic replacement units.
Silver removed from the ESR and the metallic cartridges and fixer solutions are hazardous wastes and
must be handled properly.
• Off-site silver recovery includes sending fixer bath solutions to a fixer recycler to recover silver and
possibly regenerate the fixer or processing off-site cartridges from an on-site metallic replacement
canister.
d. Used Film
(1) Has the facility explored the use of silverless films?
If yes, which type? (Check any that apply.)
Diazo
Yes
No
Photopolymer
Electrostatic
N/A
Has the use of these films reduced the amount of silver contaminated fixing or
wash solutions?
(2) Does the facility recycle photographic film?
e. Innovative Technology (Web Printing)
(1) Has the facility considered installing waterless paper and film developing units to
reduce the volume of fixer waste?
Yes
No
Yes
No
Yes
No
A-18
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
B. Image Processing (Continued)
(2) Does the facility use electronic imaging?
Yes
No
C. Platemaking
a. General
(1) Is platemaking done at the facility?
Yes
No
Notes to Inspector:
Check Table 1 (i.e., Summary of Wastes Generated, Quantity, and Disposal Methods) to verify wastes
generated as you complete this section of the checklist.
Typical wastes from platemaking include the following: used plates, developed film, acids, alkalis, solvent,
plate coatings, plate developers, andwastewater.
Typical hazardous wastes generated from the platemaking process may include: plate developers and
activators.
(2) Note any potential or actual problems regarding platemaking with respect to air emissions, hazardous
and nonhazardous solid wastes, and wastewater.
A-19
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
C. Platemaking (Continued)
(3) What type
| j Pre
| | Las
| | Ele
| | Dif
| | Phc
| | Dir
(4) How many
(5) What mate
(6) Are plates
(7) Does the ft
b. Waste
(1) Is the plate
(2) What are tl
of plates are used?
sensitized
,er Imaged
ctrostatic
'fusion Transfer
)to Direct
ect Image
plates are developed?
rial(s) are the plates made from?
Yes No
recycled?
Yes No
icility use two-sided plates to reduce the number of plates used?
Solutions
Yes No
maker a self-contained system?
le types and quantities of coatings and developers used?
Type Quantity
A-20
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
C. Platemaking (Continued)
(3) Is the developer washed off the plates to the sewer?
If no, what is done with the developer?
c. Innovative Technology
(1) Has the facility considered laser imaged platemaking?
Yes
No
Yes
No
If yes, note the status of its use (e.g., currently using for approximately 50% of business) and any
impediments to its use.
D. Printing
a. General
Notes to Inspector:
Check Table 1 (i.e., Summary of Wastes Generated, Quantity, and Disposal Methods) to verify wastes
generated as you complete this section of the checklist.
Typical wastes from printing processes include the following: paper, volatile organic compounds, waste
ink, empty ink containers, and used plates.
Typical hazardous wastes generated from the printing process include: ink/ink skins and fountain solutions.
Used printing inks can contain materials that would be considered hazardous wastes. For some chemicals
the -wastes are hazardous at any concentration while for other chemicals, the -wastes are hazardous if they
exceed specific regulatory limits.
Some agencies have requirements on the maximum VOC content for printing inks.
Fountain solutions are made up of water and chemical additives. The most common additive is IP A and is
a volatile organic compound. To avoid VOCs, alternative chemicals may be used. Certain alternatives, such
as ethylene glycol (>10%) could be a hazardous waste (under State regulations) if spent solutions are
disposed.
A-21
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
(1) Note any potential or actual problems regarding printing with respect to air emissions, hazardous and
nonhazardous solid wastes, and wastewater.
b. Waste Ink and Empty Ink Containers
(1) Do any of the inks contain hazardous materials such as solvents or heavy metals
(i.e., fluorescent/bright-colored inks frequently contain higher concentrations of heavy
metals)?
List the hazardous constituents.
Yes
No
(2) Does the facility use any of the following less hazardous inks? (Check any that apply.)
Vegetable/soy inks
Ultraviolet curable inks
Electron beam curable inks
Water washable ink system
Waterless inks
A-22
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
(3) Does the facility do any of the following? (Check any that apply.)
Fill ink fountains according to need as opposed to routine filling?
Use automatic ink levelers?
Clean ink fountains between runs?
Properly reseal ink containers (or cover with a lid or wax paper) after use to reduce skinning
and to maintain ink quality?
• Use any other measures to prevent drying ink or formation of skins inside the
fountain?
If yes, describe the measures:
Yes
No
Use anti-skinning aerosols to prevent ink dry-up during shutdowns?
If yes, list type of aerosol used:
Yes
No
Note to Inspector:
A-23
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
(4) Does the facility use any of the following measures to reduce cleaning?
'Check any that apply.)
ae
Use a standard ink sequence
Run similar jobs on the same day or schedule jobs using light colored inks before darker ones
Dedicate one press for inks containing hazardous pigments or solvents
(5) Does the facility do any of the following with unused portions of ink? (Check any that
apply.)
Save for house colors
Offer customer discounts on leftover inks
Use on donated jobs
If no, what do they do with the unused inks?
Yes
No
(6) Does the facility do any of the following with waste inks? (Check any that apply.)
Reuse
Recycle
Return to the manufacturer
(7) Does the facility purchase ink in bulk containers that may be returned to the supplier
for refilling?
Yes
No
A-24
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
c. Fountain Solutions
(1) What type of VOC fountain solution is used?
(2) Does the facility use compliant (low-VOC) fountain solutions to meet regulatory
requirements?
Yes
No
Notes to Inspector:
Most regulations offer the option of low-VOC fountain solutions or air pollution control devices. The EPA
recommended levels of control for reasonably available control technology (RACT) are as follows:
• Heatset web: No greater than 1.6percent alcohol by volume or no greater than 3.0percent alcohol by
volume if the solution is refrigerated to less than 60 °F. Higher levels of control are possible using
alcohol substitutes or less alcohol in the fountain solution.
• Sheetfed: No greater than 5.0 percent alcohol by volume or no greater than 8.0 percent alcohol by
volume if the solution is refrigerated. Higher levels of control are possible using alcohol substitutes or
less alcohol.
• Nonheatsetweb: Nonalcohol additives or alcohol substitutes can be used to make the final solution less
than 3.0percent additive by volume.
N/A
(3) Have alternative fountain solutions been tried?
(4) Has the facility considered refrigerating fountain solutions to maximize the
efficiency of isopropyl alcohol (IPA) and non-IPA solutions?
(5) Does the facility fill ink fountains based on the run or shift?
(6) Does the facility use permanent total enclosures (PTEs) to caputure press emissions?
Yes
No
Yes
No
Yes
No
Yes
No
A-25
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
d. Paper Wastes
(1) Is paper use minimized by proper pre-production planning and lay-out?
(2) Does the facility utilize improved start-up procedures to reduce paper waste to a
minimum?
(3) Is waste paper and trash sent to a recycler?
(4) Does the facility view jobs on a personal computer before printing?
(5) What are the most common causes of off-specification printing?
Yes
Yes
No
No
Yes
Yes
No
No
Yes
No
(6) Does the facility monitor press performance continuously to minimize bad runs and
waste?
(7) Has the facility evaluated press performance by integrating the amount of waste
generated per process?
e. Other
(1) Does the facility generate any waste oils from the presses?
Yes
No
Yes
No
If yes, is waste lube-oil sent to a recycler?
(2) Are used oil storage tanks and containers in good condition?
N/A
Yes
No
N/A
Yes
No
A-26
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
(3) Are the storage tanks labeled "used oil?"
(4) Are there any used-oil spills or leaks to the environment?
f. Innovative Technology (Web Printing)
(1) Is an automatic web splicer used to save time and reduce paper waste?
(2) Do the presses employ web break detectors to prevent damage to the press?
N/A
Yes
Yes
N/A
Yes
N/A
Yes
No
No
No
No
E. Cleaning Activities
a. General
(1) What type of cleaning activities does the facility perform and how often are they performed?
Notes to Inspector:
Check Table 1 (i.e., Summary of Wastes Generated, Quantity, and Disposal Methods) to verify wastes
generated as you complete this section of the checklist.
Typical wastes from cleaning activities include: waste cleaner with residual ink, waste ink from the ink
fountain, rags or shop towels containing cleaner and ink, empty solvent containers, and VOC emissions from
cleaners.
Typical hazardous wastes generated from cleaning activities may include: parts washer solvents, shop
towels, press washes, and ink cleanup sludges. Parts washer solvents typically become hazardous when they
can't be used any longer. Shop towels may be considered a hazardous waste depending on the materials
they are in contact with (e.g., inks, solvents) and how they are handled (e.g., thrown away). Press washes
have a high VOC content and may contain F listed RCRA chemicals that would make them hazardous when
disposed. Ink cleanup sludges are generated from press cleaning operations and are considered hazardous
when they are mixed.
Tear-down and repair of equipment can produce large quantities of cleaning waste as compared to waste
produced during normal operation.
A-27
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
E. Cleaning Activities (Continued)
(2) Note any potential or actual problems regarding cleaning activities with respect to air emissions,
nonhazardous and hazardous solid wastes, and wastewater.
b. Spent Cleaner
(1) List the type of solvents or other solutions used as cleaners.
(2) Has the use of less hazardous cleaning solvents been attempted (e.g., soaps and
detergents) for cleaning?
If yes, list type of solvent.
Yes
No
Note to Inspector:
Citric-acid and aqueous-based cleaners may replace petroleum-based solvents and those containing
aromatic compounds.
(3) Has the facility worked with its vendor to find the lowest VOC press wash that still
works effectively?
(4) Does the facility have a solvent management plan to reduce solvent waste at the
facility?
Yes
No
Yes
No
A-28
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
A-29 June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
E. Cleaning Activities (Continued)
(5) Does the facility have solvent containers or tanks?
If yes, are solvent container lids tight fitting and in place when not in use?
(6) Are solvent tanks equipped with emission control equipment?
If yes, specify the type of equipment.
Yes
Yes
No
No
N/A
Yes
No
(7) Has the facility considered using automatic cleaning equipment (e.g., an automatic
blanket cleaner)?
(8) Is the roller blade kept in good condition and its angle checked for most effective
cleaning?
(9) Does the facility segregate spent solvents according to color or ink?
(10) How are waste solvents handled? (Check any that apply.)
Discharged to drains
Captured as liquid
Associated with rags, shop towels, or other absorbent materials
(11) Does the facility reuse or recycle solvents?
If yes, how is it reused or recycled?
Yes
No
Yes
No
Yes
No
Yes
No
A-30
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
E. Cleaning Activities (Continued)
(12) If solvents are recycled on-site:
Does the solvent recycling process generate cooling water?
N/A
Yes
What procedures are used to ensure cooling water is not contaminated from equipment leaks?
c. Shop Towels
(1) How are rags handled? (Check one that applies.)
Washed on premises
Picked up by commercial laundry:
(name of laundry)
(2) Does the facility use press wipes as long as possible before discarding or laundering?
(3) Does the facility implement procedures to remove excess solvents or inks in the rags
so they can be cleaned by an industrial laundry?
Yes
Yes
No
No
No
Note to Inspector:
A variety of approaches can be used to minimize the amount of solvents or inks in rags. These include:
• Changing clean up procedures so that solvent levels are kept to a minimum in the rags
- Use practices that limit the worker's ability to soak rags in solvent (plunger cans, squeeze bottles, daily
solvent allocations, directly pour solvent waste into labeled drums, etc...)
• Developing a procedure to separate a majority of the ink and solvent from soaked rags
- Centrifugal extractor or wringer
• Using parts washing equipment as an alternative to rags for cleaning trays that collect solvents and inks
below each roller of the press.
A-31
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
F. Finishing
(1) What type of finishing operations are done at the facility?
Note to Inspector:
Check Table 1 (i.e., Summary of Wastes Generated, Quantity, and Disposal Methods) to verify wastes
generated as you complete this section of the checklist.
(2) Note any potential or actual problems regarding finishing operations with respect to air emissions,
nonhazardous and hazardous solid wastes, and wastewater.
Note to Inspector:
Typical wastes from the finishing process include the following: waste paper trimmings, VOCs, andwaste
glue.
(3) Does the facility incorporate pollution prevention techniques or use innovative
technology to reduce finishing wastes?
If yes, describe the techniques or technology.
Yes
No
A-32 June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
III. WASTE HANDLING AND MANAGEMENT
A. Wastewater Management
(1) List the expected pollutants in the facility's wastewater discharge.
(2) Does the POTW have sewer use limits for any of these pollutants?
If yes, list the pollutants.
(3) Does the facility have a current wastewater discharge permit?
If no, has the facility applied for a permit?
(4) If the facility has a wastewater discharge permit, complete the following:
List the parameters limited in the facility's permit.
Parameter
Limit
Is the facility in compliance with the following requirements in its permit?
Permit limits
Sampling location
Sampling frequency
Parameters analyzed
Analytical methods
Reporting
Recordkeeping
Yes
N/A
N/A
Yes
Yes
N/A
Yes
No
No
No
No
A-33
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
III. WASTE HANDLING AND MANAGEMENT (Continued)
A. Wastewater Management (Continued)
If no is checked for any of the above items, describe the potential or actual noncompliance with
specific permit requirements.
(5) Describe any observable impact of the wastewater discharge. (For example, is the discharge clear
and free of solids or are there any unusual odors?)
(6) Describe any wastewater treatment employed at the facility. (Note: This does not include any
recovery systems.)
Yes
No
(7) Is wastewater treatment sludge generated on-site?
If yes, how is it disposed?
If applicable, where does the water, removed from the sludge dewatering process, return to the
facility?
(8) For facilities that discharge to POTWs, did the facility notify the POTW if any
substances discharged by the facility would be a hazardous waste under 40 CFR Part
261?
Yes
No
B. Hazardous Solid Wastes Management
(1) Is hazardous waste accumulated in containers at or near the point of generation (i.e., in
the process areas)?
Yes
No
If yes, is the capacity of the containers less than 55 gallons or is the quantity of
wastes accumulated less than 55 gallons?
N/A
Yes
No
A-34
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
III. WASTE HANDLING AND MANAGEMENT (Continued)
B. Hazardous Solid Wastes Management (Continued)
Is excess accumulation removed within 3 days?
(2) Does the facility have a hazardous waste storage area?
(3) Are the waste storage containers indoors or in covered areas to prevent moisture from
seeping in?
(4) Are the hazardous wastes containers managed as follows? (Check all that apply.)
| Containers in good condition (no rusting, defects or evidence of leaks)
Yes
Yes
Yes
No
No
No
| ( Containers properly labeled as "Hazardous Waste" and start date of accumulation
| Containers compatible with waste
| ( Containers closed when not in use
| Containers opened, handled, and stored in a manner not to cause a leak
| ( Containers storing incompatibles kept separate
| Containers appropriately stored for:
j j 90 days or less
| 180 days or less
j j 270 days or less
For items not marked, please describe the problem.
(5) Is there adequate secondary containment capacity for free liquid wastes stored in a
storage area?
Yes
No
A-35
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
III. WASTE HANDLING AND MANAGEMENT (Continued)
B. Hazardous Solid Wastes Management (Continued)
(6) Are any hazardous wastes shipped off-site?
If yes, does the facility use a manifest system?
(7) Do the manifest records contain the following? Check all that apply.
| ( Generator EPA ID number
| Generator name, address, phone number
| ( Transporter name, EPA ID number
| Designate facility name, address, phone number, and EPA ID number
| ( Alternate facility identified
| Five digit document number
| ( DOT shipping name, hazard class, waste code, and RQ
| Containers: number, type, quantity, unit wt/vol
| ( Proper certification, including waste minimization
| Dates and signatures
(8) Have exception reports been required?
If yes, have they been submitted?
(9) Are manifest records maintained for 3 years?
N/A
Yes
No
Yes
No
Yes
No
Yes
No
N/A
Yes
No
A-36
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
III. WASTE HANDLING AND MANAGEMENT
B. Hazardous Solid Wastes Management (Continued)
(10) If wastes are reclaimed, does facility have a copy of the contractual agreement
with reclaimer?
(11) Has the facility determined and submitted notifications of hazardous waste
restricted from land disposal?
If yes, do the notifications contain the following? (Check all that apply.)
| ( EPA hazardous waste number (e.g., F002)
| The corresponding treatment standard(s) (see 40 CFR 268.7(a)(l)(ii) for
| ( The manifest number associated with the shipment of waste
| Waste analysis data, where available
(12) If land disposal restricted wastes are treated on-site, does facility have records
documenting that wastes meet land disposal restriction treatment standards?
N/A
N/A
Yes
Yes
No
No
details)
N/A
Yes
No
C. Air Emissions Management
(1) Does the facility have any of the air pollution control technologies?
If yes, check any that apply.
| | Incinerator
j J Carbon Absorption Unit
| | Condenser
j J Ventilation Capture System
Yes
No
A-37
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Checklist
III. WASTE HANDLING AND MANAGEMENT
C. Air Emissions Management (Continued)
Note to Inspector:
Air pollution control technologies include the following:
• Incinerators (including catalytic) — Incineration of exhaust gas is widely used in the printing industry.
Often, heat is recycled back into the building (i.e., heat-set offset) or process dryers. Compliance is
monitored by incineration temperature or change in temperature across the catalytic surface.
• Carbon Absorption — Carbon beds capture exhaust VOCs that are purged with steam. On-site
distillation can be used to recover the solvent. Presses/facilities utilizing a single solvent can efficiently
recover solvent for on-site use. This method is typically used on larger presses with hydrocarbon
monitors to confirm efficiency.
• Condensers - Refrigerated coils are used to cool exhaust gas and cause solvent to condense for
recovery. Condensers are not widely used in the graphics arts industry.
• Ventilation/capture Systems — VOCs are emitted primarily from fountain solutions, rollers and dryers
on presses. Depending upon the design, these may or may not be enclosed parts of the press. The
control efficiencies discussed below generally are based upon capture and control. Capture efficiency
describes the ability of the system to pick-up VOC emissions and transfer them to the control device.
(2) Does the facility have an air permit?
If no, has the facility applied for a permit?
Yes
No
Yes
No
(3) If the facility has an air permit, is it in compliance with the following requirements in its permit?
Emissions limits
Emissions monitoring
Analytical methods
Reporting
Recordkeeping
Other (describe):
N/A
Yes
No
(4) If no is checked for any of the above items, describe any actual or potential violations with specific
permit requirements.
A-38
June 1996
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Acronyms
BACT
CERCLA
CESQG
EHS
EPCRA
ESR
HAB
IPA
LAER
LEPC
LQG
MSDS
NPDES
NSR
P2
POTW
PSD
PTE
RACT
RCRA
SERC
SQG
VOC
WWTS
best available control technology
Comprehensive Environmental Response, Compensation, and Liability Act
conditionally exempt small quantity generator
extremely hazardous substance
Emergency Planning and Community Right-to-Know Act
electrolytic silver recovery
hazardous air pollutant
isopropyl alcohol
lowest achievable emission rate
Local Emergency Planning Committee
large quantity generator
material safety data sheet
National Pollutant Discharge Elimination System
new source review
pollution prevention
publicly owned treatment works
prevention of significant deterioration
permanent total enclosure
reasonably available control technology
Resource Conservation and Recovery Act
State Emergency Response Commission
small quantity generator
volatile organic compound
wastewater treatment plant
June 1996
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MULTIMEDIA COMPLIANCE/POLLUTION PREVENTION ASSESSMENT
CHECKLIST FOR LITHOGRAPHIC PRINTERS
Date and Time of Assessment:
Facility Name And Address
Facility Contact
(Name, title, and phone)
Inspector(s):
Name
Title/Affiliation
Phone Number
June 1996
-------
TABLE OF CONTENTS
Page
I. GENERAL FACILITY INFORMATION A-l
A. General Facility Operations A-2
B. Wastewater A-5
C. Air A-6
D. Emergency Planning and Community Right-to-Know A-8
E. EPCRA Section 313 - Toxic Release Inventory A-9
F. Hazardous Wastes A-9
G. Toxic Substances Control A-12
II. PROCESS EVALUATION A-12
A. General Housekeeping/Materials Storage A-12
B. Image Processing A-14
a. General A-14
b. Process Solutions A-15
c. Silver Recovery A-16
d. Used Film A-17
e. Innovative Technology (Web Printing) A-17
C. Platemaking A-18
a. General A-18
b. Waste Solutions A-19
c. Innovative Technology A-20
D. Printing A-20
a. General A-20
b. Waste Ink and Empty Ink Containers A-21
c. Fountain Solutions A-24
d. Paper Wastes A-25
e. Other A-25
f. Innovative Technology (Web Printing) A-26
E. Cleaning Activities A-26
a. General A-26
b. Spent Cleaner A-27
c. Shop Towels A-29
F. Finishing A-30
III. WASTE HANDLING AND MANAGEMENT A-31
A. Wastewater Management A-31
B. Hazardous Solid Wastes Management A-32
C. Air Emissions Management A-35
June 1996
-------
ACRONYMS
BACT best available control technology
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CESQG conditionally exempt small quantity generator
EHS extremely hazardous substance
EPCRA Emergency Planning and Community Right-to-Know Act
ESR electrolytic silver recovery
HAP hazardous air pollutant
IPA isopropyl alcohol
LAER lowest achievable emission rate
LEPC Local Emergency Planning Committee
LQG large quantity generator
MSDS material safety data sheet
NPDES National Pollutant Discharge Elimination System
NSR new source review
P2 pollution prevention
POTW publicly owned treatment works
PSD prevention of significant deterioration
PTE permanent total enclosure
RACT reasonably available control technology
RCRA Resource Conservation and Recovery Act
SERC State Emergency Response Commission
SQG small quantity generator
VOC volatile organic compound
WWTP wastewater treatment plant
111
June 1996
-------
GLOSSARY
Best Available Control Technology (BACT)
Technology required pursuant to Part 165 on new major sources and major modifications subject to
prevention of significant deterioration (PSD) requirements, which reflect best controls in use taking
into account costs and other non-air quality factors.
Lowest Achievable Emission Rate (LAER)
Degree of control required pursuant to Part 173 on new major sources and major modifications in
nonattainment areas; technology must be best in use or most stringent in any State Implementation
Plan.
Major Source
Stationary source in an ozone transport region that emits or has the potential to emit at least 50 tons
per year of volatile organic compounds (VOCs).
New Source Review (NSR)
Program for pre-construction review of new major sources and major modifications under prevention
of significant deterioration (PSD) and nonattainment requirements.
Nonattainment
Program established pursuant to Part D of Title I requiring controls necessary to attain National
Ambient Air Quality Standards (NAAQSs) in areas currently not meeting them.
Prevention of Significant Deterioration (PSD)
Program established under Part C of Title I to preserve air quality in areas already meeting National
Ambient Air Quality Standards (NAAQSs).
Reasonably Available Control Technology (RACT)
Technology required pursuant to Part 172 to be installed on existing major sources in nonattainment
areas; reflects controls EPA has identified in control technique guidelines (CTGs) or other guidance.
iv June 1996
-------
Acknowledgements
A special thanks is extended to the following facilities that participated in a pilot test of the
draft Multimedia Compliance/Pollution Prevention Assessment Guidance:
All Night Printery of Federal Way, Washington
Litho Craft, Inc. of Seattle, Washington
Seattle Times of Seattle, Washington and
Trojan Lithographic Corporation of Kent, Washington.
Their participation was extremely useful in preparation of the final guidance.
-------
APPENDIX B
MULTIMEDIA COMPLIANCE/POLLUTION PREVENTION
ASSESSMENT REPORT FORM FOR PRINTING FACILITIES
-------
Multimedia Compliance/Pollution Prevention Assessment Report Form
FACILITY NAME AND
LOCATION:
MAILING ADDRESS:
(if different)
FACILITY CONTACT(S):
Name
ASSESSMENT DATE:
INSPECTOR(S):
Name
REASON FOR VISIT:
AREAS VISITED:
DATE FORM COMPLETED:
Title/Affiliation
Phone Number
Title/Affiliation
Phone Number
B-l
June 1996
-------
Multimedia Compliance/Pollution Prevention Assessment Report Form
I.
Provide a general description of the facility (e.g., building age, length of business at this location,
previous owners/operators at the site, printing capacity, brief description of processes, brief
overview of wastes generated and disposal methods used, and status of P2 implementation efforts).
B-2 June 1996
-------
Multimedia Compliance/Pollution Prevention Assessment Report Form
II. COMPLIANCE ASSESSMENT
Wastewater
Describe any observed or potential violations:
Referral to other program office
Air Quality
Describe any observed or potential violations:
Referral to other program office
Emergency Planning and Community Right-to-Know Act (EPCRA)
Describe any observed or potential violations:
Referral to other program office
Hazardous Waste [Resource Conservation and Recovery Act (RCRA)]
Describe any observed or potential violations:
Referral to other program office
Toxic Substances Control
Describe any observed or potential violations:
Referral to other program office
B-3 June 1996
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Multimedia Compliance/Pollution Prevention Assessment Report Form
III.
List each waste at the facility with any associated P2 and innovative technology opportunities. Use
additional sheets for more information.
Process - Image Processing
Raw Materials or Waste Description
Process - Platemaking
Raw Materials or Waste Description
B-4
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Report Form
III.
List each waste at the facility with any associated P2 and innovative technology opportunities. Use
additional sheets for more information.
Process - Printing
Raw Materials or Waste Description
Process - Other
Raw Materials or Waste Description
B-5
June 1996
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Multimedia Compliance/Pollution Prevention Assessment Report Form
IV.
A. Compliance Violations and/or Issues [add regulatory references (i.e., 40 CFR 261.30)].
B. Potential P2 Opportunities and Innovative Technologies. (These are only suggestions and not
regulatory requirements.)
C. Follow-up Responses to Compliance Questions Asked During On-Site Assessment. (This section
should include responses to compliance questions asked during the on-site assessment that the
inspector was unable to answer.)
B-6 June 1996
-------
Glossary
Best Available Control Technology (BACT)
Technology required pursuant to Part 165 on new major sources and major modifications
subject to prevention of significant deterioration (PSD) requirements, which reflect best
controls in use taking into account costs and other non-air quality factors.
Lowest Achievable Emission Rate (LAER)
Degree of control required pursuant to Part 173 on new major sources and major
modifications in nonattainment areas; technology must be best in use or most stringent in
any State Implementation Plan.
New Source Review (NSR)
Program for pre-construction review of new major sources and major modifications under
prevention of significant deterioration (PSD) and nonattainment requirements.
Nonattainment
Program established pursuant to Part D of Title I requiring controls necessary to attain
National Ambient Air Quality Standards (NAAQSs) in areas currently not meeting them.
Prevention of Significant Deterioration (PSD)
Program established under Part C of Title I to preserve air quality in areas already meeting
National Ambient Air Quality Standards (NAAQSs).
Reasonably Available Control Technology (RACT)
Technology required pursuant to Part 172 to be installed on existing major sources in
nonattainment areas; reflects controls EPA has identified in control technique guidelines
(CTGs) or other guidance.
June 1996
-------
APPENDIX Cl
SELECTED REFERENCES RELATED TO
POLLUTION PREVENTION AND INNOVATIVE TECHNOLOGY
-------
APPENDIX C2
ANNOTATED BIBLIOGRAPHY OF SELECTED REFERENCES
IN APPENDIX Cl
-------
APPENDIX Cl
SELECTED REFERENCES RELATED TO
This is not meant to be a comprehensive list of pollution prevention resource materials
on printing process. Rather, it contains a range of references that could be used for
initial review by the inspector. Many of these documents also contain reference lists.
In addition, discussion of specific pollution prevention techniques and innovative
technologies, or mention of trade names on commercial products, in these documents
does not constitute an endorsement or recommendation for use by EPA.
Alaska Health Program. April 1991. Waste Reduction Assistance Program. Waste
Reduction Guide: Printing Business.
California Department of Health Sciences. May 1988. Waste Audit Study: Commercial
Printing Industry. Prepared for the Alternatives Technology Section, Substances
Control Division, California Department of Health Sciences. Sacramento, CA.
Connecticut Technical Assistance Program. August 1992. On-Site Waste Ink Recycling:
The Hartford Courant. Hartford, CT.
Hawaii Department of Health. Solid and Hazardous Waste Branch. September 1993.
Hazardous Waste Minimization News: Waste Minimization in Action - Printing
Operations.
New York State Department of Environmental Conservation. September 1991. Hazardous
Waste Management for Printers.
State of Montana, Department of Health and Environmental Sciences. June 1988. The Small
Quantity Generator's Handbook for Managing RCRA Wastes - Printing and
Publishing.
1 995 Updated version: Small Businesses Handbook for Managing Hazardous Wastes.
U.S. Environmental Protection Agency. January 1976. Environmental Aspects of Chemical
Use In Printing Operations. Office of Toxic Substances. Washington, DC. EPA-
560/1-75-005 [call # PB25 1406].
U.S. Environmental Protection Agency. October 1983. Summary of Available Information
on the Levels and Control of Toxic Pollutants Discharges in the Publishing and
Printing Point Source Category. Effluent Guidelines Division. Washington, D.C.
EPA 440/1-83-400 [call # PB92231703].
Cl-1 June 1995
-------
Selected References Related to Pollution Prevention and Innovative Technology
U.S. Environmental Protection Agency. January 1988. Title III Section 313 Release
Reporting Guidance; Estimating Chemical Releases From Printing Operations.
Office of Pesticides and Toxic Substances. Washington, DC. EPA 560/4-88-004b
[call #PB93205979].
U.S. Environmental Protection Agency. February 1988. Title III Section 313 Release
Reporting Guidance: Estimating Chemical Releases From Roller, Knife, and
Gravure Coating Operations. Office of Pesticides and Toxic Substances.
Washington, DC. EPA/560/4-88-004J [call # PB93206050].
U.S. Environmental Protection Agency. October 1989. Pollution Prevention in Printing and
Allied Industries: Saving Money Through Pollution Prevention (Draft). ORD
Pollution Prevention Office, Washington, DC.
U.S. Environmental Protection Agency. Office of Pollution Prevention. November 1989.
Case Studies from the Pollution Prevention Information Clearinghouse (PPIC):
Printing. Washington, D.C.
U.S. Environmental Protection Agency. August 1990. Guides to Pollution Prevention: The
Commercial Printing Industry. Office of Research and Development. Washington,
DC. EPA/625/7-90/008.
U.S. Environmental Protection Agency. September 1991. Achievements in Source
Reduction and Recycling for Ten Industries in the United States. Office of Research
and Development, Washington, D.C. EPA/600/S-91/051 [call # PB92137470].
U.S. Environmental Protection Agency. May 1992. Waste Reduction Activities and Options
at a Printer of Forms and Supplies for the Legal Profession. Risk Reduction
Engineering Laboratory. Cincinnati, OH. EPA/600/S-92/003.
U.S. Environmental Protection Agency. July 1993. Design for the Environment Printing
Project. Office of Pollution Prevention and Toxics. Washington, DC. EPA 744-F-
93-003.
U.S. Environmental Protection Agency. September 1993. Control of Volatile Organic
Compound Emissions From Offset Lithographic Printing. Office of Air Quality
Planning and Standards. Research Triangle Park, NC [call # PB95201422].
U.S. Environmental Protection Agency. September 1993. Waste Minimization Assessment
for a Manufacturer of Rotogravure Printing Cylinders. Risk Reduction Engineering
Laboratory. Cincinnati, OH. EPA/600/S-93/009.
U.S. Environmental Protection Agency. Design for the Environment Printing Project: Case
Study. Design for the Environment Program; Office of Pollution Prevention and
Toxics. EPA744-K-93-001.
Cl-2 June 1995
-------
Selected References Related to Pollution Prevention and Innovative Technology
U.S. Environmental Protection Agency. Design for the Environment Printing Project:
Screen Printing. Design for the Environment Program; Office of Pollution Prevention
and Toxics. EPA 744-F-93-015.
U.S. Environmental Protection Agency. March 1994. Federal Environmental Regulations
Potentially Affecting the Commercial Printing Industry. Office of Pollution
Prevention and Toxics. EPA 744-B-94-001.
U.S. Environmental Protection Agency. April 1994. Practical Pollution Prevention
Techniques for Lithographic Printers. U.S. EPA Region IX. and California
Protection Agency Department of Toxic Substance Control. San Francisco, CA.
U.S. Environmental Protection Agency. June 1994. Abstracts of Pollution Prevention Case
Study Sources. Office of Pollution Prevention and Toxics. Washington, DC. EPA
742-R-94-001.
U.S. Environmental Protection Agency. June 1994. Printing Industry And Use Cluster
Profile. Prevention, Pesticides, and Toxic Substances. EPA 744-R-94-003.
U.S. Environmental Protection Agency. June 1994. Summary of Focus Group Discussion
with Screen Printers and Lithographers for the Design for the Environment Printing
Project. Office of Pollution Prevention and Toxics. Washington, DC. EPA 742-R-94-
004.
U.S. Environmental Protection Agency. September 1994. Cleaner Technologies Substitutes
Assessment: Executive Summary; Industry: Screen Printing; Use Cluster; Screen
Reclamation. Office of Pollution Prevention and Toxics. Washington, DC.
EPA-744R-94-005.
U.S. Environmental Protection Agency. Printing and Publishing Information Packet.
University of Northern Iowa. Iowa Waste Reduction Center. 1995. Pollution Prevention
Manual for Lithographic Printers.
Virginia Department of Environmental Quality. September 1993. Printers Win Through
Pollution Prevention (Video). Waste Reduction Assistance Program.
Virginia Waste Reduction Assi stance Program. 1991. Waste Reduction Fact Sheet: Waste
Reduction for the Commercial Printing Industry. Vol. 1, Issue 2.
Cl-3 June 1995
-------
APPENDIX C2
ANNOTATED BIBLIOGRAPHY OF SELECTED REFERENCES
IN APPENDIX Cl
Alaska Health Program. April 1991. Waste Reduction Assistance Program. Waste Reduction
Guide: Printing Business.
Manual designed to assist the printing business in identifying and implementing waste
reduction opportunities.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
California Department of Health Sciences. May 1988. Waste Audit Study: Commercial Printing
Industry. Prepared for the Alternatives Technology Section, Substances Control Division,
California Department of Health Sciences. Sacramento, CA.
Study identifying waste minimization techniques available to printers. Recommendations
and findings are included as well as checklists that can be used by printers to perform their
own waste audits.
Available From: California Department of Health
Department of Toxic Substances Control
Office of Pollution Prevention Technology and Development
Document #303—Limited to existing stock
(916) 324-1087
Connecticut Technical Assistance Program. August 1992. On-Site Waste Ink Recycling: The
Hartford Courant. Hartford, CT.
In-depth case study of how one large newspaper developed a waste ink recycling program.
The project addressed product quality, waste reduction, and the economic issues involved
in recycling press ink. Information on testing and comparison of virgin and recycled ink are
documented. Economic information regarding the resulting cost savings is provided.
Available From: CONNTAP
50 Columbus Blvd., 4th Floor
Hartford, CT 06106
(203) 241-0777
C2-1 November 1995
-------
Annotated Bibliography of Selected References in Appendix Cl
Hawaii Department of Health. Solid and Hazardous Waste Branch. September 1993. Hazardous
Waste Minimization News: Waste Minimization in Action - Printing Operations.
Newsletter featuring tips and ideas on reducing hazardous wastes generated at printing
operations.
Available From: Hawaii Department of Health
Solid and Hazardous Waste Branch
919 Ala Moana Blvd., Rm. 212
Honolulu, Hawaii 96814
(808) 586-4373
New York State Department of Environmental Conservation. September 1991. Hazardous Waste
Management for Printers.
Pamphlet providing information regarding hazardous wastes, waste reduction and recycling
strategies, information available from the State of New York, and information on how to
categorize waste streams (i.e., hazardous, nonhazardous).
Available From: New York State Department of Environmental Conservation
Division of Hazardous Substance Regulation
50 Wolf Road
Albany, NY 12233-7253
(212) 637-4100
State of Montana, Department of Health and Environmental Sciences. June 1988. The Small
Quantity Generator's Handbook for Managing RCRA Wastes -Printing and Publishing.
This is a handbook developed for the printing and publishing industry to comply with RCRA
requirements. The manual also provides insight into waste management strategies for
minimizing waste quantities. Information was compiled through site visits to various
printing shops. The handbook also summarizes the RCRA regulations that apply to printers.
Available From: State of Montana
Division of Wastes
(406) 444-1430
Also available is a 1995 Updated Version: Small Business Handbook for Managing
Hazardous Wastes.
C2-2 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
U.S. Environmental Protection Agency. January 1976. Environmental Aspects of Chemical Use In
Printing Operations. Office of Toxic Substances. Washington, DC. EPA-560/1 -75-005
[call #PB251406].
This document contains the proceedings for the conference on " Environmental Aspects of
Chemical Use in Printing Operations." Papers presented covered types of printing
processes, emissions regulations, and health hazards from printing effluents.
Available From: National Technical Information Service
5285 Port Royal Road
Springfield, Virginia
(703) 487-4650
U.S. Environmental Protection Agency. October 1983. Summary of Available Information on the
Levels and Control of Toxic Pollutants Discharges in the Publishing and Printing Point
Source Category. Effluent Guidelines Division. Washington, D.C. EPA 440/1-83-400 [call
#PB92231703].
Summary of information used to develop the effluent guidelines for printers. Includes
information on data gathering, water usage, toxic pollutant discharge data, and control and
treatment technologies employed in printing industry.
Available From: National Technical Information Service
5285 Port Royal Road
Springfield, Virginia
(703) 487-4650
U.S. Environmental Protection Agency. January 1988. Title III Section 313 Release Reporting
Guidance; Estimating Chemical Releases From Printing Operations. Office of Pesticides
and Toxic Substances. Washington, DC. EPA 560/4-88-004b [call # PB93205979].
This document was designed to assist printers in completion of Part III (Chemical Specific
Information) of the Toxic Chemical Release Inventory Reporting Form. General
information on toxic chemicals used, process wastes generated, and examples of data needs
and methodologies are included.
Available From: National Technical Information Service
5285 Port Royal Road
Springfield, Virginia
(703) 487-4650
C2-3 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
U.S. Environmental Protection Agency. February 1988. Title III Section 313 Release Reporting
Guidance: Estimating Chemical Releases From Roller, Knife, and Gravure Coating
Operations. Office of Pesticides and Toxic Substances. Washington, DC. EPA/560/4-88-
004j [call#PB93206050].
This document was designed to assist those using roller, knife, and gravure coating
equipment in the completion of Part III of the Toxic Chemical Release Inventory Reporting
Form. General information on toxic chemicals used, process wastes generated, and
examples of data needs and methodologies are included.
Available From: National Technical Information Service
5285 Port Royal Road
Springfield, Virginia
(703) 487-4650
U.S. Environmental Protection Agency. October 1989. Pollution Prevention in Printing and Allied
Industries: Saving Money Through Pollution Prevention (Draft). ORD Pollution Prevention
Office, Washington, DC.
Intended to provide a brief introduction to pollution prevention, including what it is, how it
can help save money, and where you can get additional assistance. Example technical
options available to printing and allied facilities are included.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, B.C. 20460
(202) 260-1023
C2-4 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
U.S. Environmental Protection Agency. Office of Pollution Prevention. November 1989. Case
Studies from the Pollution Prevention Information Clearinghouse (PPIC): Printing.
Washington, D.C.
Provides short (1-2 page) case studies of pollution prevention activities conducted at
printing establishments. Details regarding costs to implement practices and cost savings are
presented.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
(202) 260-1023
U.S. Environmental Protection Agency. August 1990. Guides to Pollution Prevention: The
Commercial Printing Industry. Office of Research and Development. Washington, DC.
EPA/625/7-90/008.
This guide was designed to provide commercial printers with guidelines and options to
minimize both hazardous and non-hazardous wastes. Worksheets for use in developing
waste minimization options for a facility are included.
Available From: Center for Environmental Research Information
Document Distribution Center (G-72)
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
(513) 569-7562
U.S. Environmental Protection Agency. September 1991. Achievements in Source Reduction and
Recycling for Ten Industries in the United States. Office of Research and Development,
Washington, D.C. EPA/600/S-91/051 [call # PB92137470].
A collection of source reduction and recycling case studies presented to U.S. EPA as success
stories. The document includes two studies related to printing processes.
Available From: National Technical Information Service
5285 Port Royal Road
Springfield, Virginia
(703) 487-4650
C2-5 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
U.S. Environmental Protection Agency. May 1992. Waste Reduction Activities and Options at a
Printer of Forms and Supplies for the Legal Profession. Risk Reduction Engineering
Laboratory. Cincinnati, OH. EPA/600/S-92/003.
This research brief presents the findings of a waste minimization assessment at a printer of
forms and supplies for the legal profession. The majority of opportunities to reduce waste
and costs were identified for the etching process. Options for reducing solvent usage are
presented.
Available From: Center for Environmental Research Information
Document Distribution Center (G-72)
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
(513) 569-7562
U.S. Environmental Protection Agency. July 1993. Design for the Environment Printing Project.
Office of Pollution Prevention and Toxics. Washington, DC. EPA 744-F-93-003.
A fact sheet describing the Design for the Environment Printing Project.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
(202) 260-1023
U.S. Environmental Protection Agency. September 1993. Control of Volatile Organic Compound
Emissions From Offset Lithographic Printing. Office of Air Quality Planning and Standards.
Research Triangle Park, NC [call # PB95201422].
This guide addresses reasonable available control technology for control of VOC emissions
form offset lithographic printing. It is the first document in a series of at least eleven
documents.
Available From : National Technical Information Service
5285 Port Royal Road
Springfield, Virginia
(703) 487-4600
C2-6 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
U.S. Environmental Protection Agency. September 1993. Waste Minimization Assessment for a
Manufacturer of Rotogravure Printing Cylinders. Risk Reduction Engineering Laboratory.
Cincinnati, OH. EPA/600/S-93/009.
This research brief presents the findings of a waste minimization assessment of a
manufacturer of Rotogravure Printing Cylinders. The findings indicate that the most
significant cost savings could be realized recovering xylene.
Available From: Center for Environmental Research Information
Document Distribution Center (G-72)
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
(513) 569-7562
U.S. Environmental Protection Agency. Design for the Environment Printing Project: Case Study.
Design for the Environment Program; Office of Pollution Prevention and Toxics. EPA 744-
K-93-001
First in the series of case studies that illustrates the Design for the Environment (Dfe) theme.
The study describes the successful pollution reduction program of a printing company in
Minnesota. The company searched for safer alternatives to managing solvents and wipes.
The case study explains the methodical evaluation of the problem leading to solutions aimed
at reducing the creation of pollutants at their source.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
(202) 260-1023
C2-7 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
U.S. Environmental Protection Agency. Design for the Environment Printing Project: Screen
Printing. Design for the Environment Program; Office of Pollution Prevention and Toxics.
EPA744-F-93-015
Second in the series of case studies that illustrates the Dfe theme. This study describes a
successful pollution reduction program at a screen printer in Wisconsin.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
(202) 260-1023
U.S. Environmental protection Agency. March 1994. Federal Environmental Regulations
Potentially Affecting the Commercial Printing Industry. Office of Pollution Prevention and
Toxics. EPA744-B-94-001.
This document presents a discussion of Federal environmental statutes potentially affecting
the commercial printing industry. It provides an overview of the regulations and the specific
chemicals used in the industry that may trigger particular regulatory requirements. This
document is intended for information purposes only and is not an official EPA guidance
document.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
(202) 260-1023
U.S. Environmental Protection Agency. April 1994. Practical Pollution Prevention Techniques for
Lithographic Printers. U.S. EPA Region IX. and California Protection Agency Department
of Toxic Substance Control. San Francisco, CA.
This document is targeted for the largest group of printers, those having fewer than 25
employees. It is an easy-to-use reference for practical information on pollution prevention
techniques, technologies, and clean products that broadly apply within the industry.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
(202) 260-1023
C2-8 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
U.S. Environmental Protection Agency. June 1994. Abstracts of Pollution Prevention Case Study
Sources. Office of Pollution Prevention and Toxics. Washington, DC. EPA 742-R-94-001.
This document provides sources for pollution prevention case studies. It is intended to serve
as a reference guide for locating pollution prevention case studies with economic
information. Each source listing contains a short description of the contents, a contact
name and telephone number, and a price for the document.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, B.C. 20460
(202) 260-1023
U.S. Environmental Protection Agency. June 1994. Summary of Focus Group Discussion with
Screen Printers and Lithographers for the Design for the Environment Printing Project.
Office of Pollution Prevention and Toxics. Washington, DC. EPA 742-R-94-004.
This report presents the methodology used to conduct the focus groups, provides an overview
of findings, and then summarizes the findings of screen printing focus groups and
lithography focus groups separately. Individual summaries of each focus group, the
facilitator's guides and the "mockups" presented at the focus groups are attached as
appendices.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
(202) 260-1023
U.S. Environmental Protection Agency. June 1994. Printing Industry and Use Cluster Profile.
Prevention, Pesticides, and Toxic Substances. EPA 744-R-94-003.
This report presents a profile of the printing industry and defines a use cluster. It presents
an overview of the chemicals, technologies, and processes used in the printing industry.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
(202) 260-1023
C2-9 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
U.S. Environmental Protection Agency. September 1994. Cleaner Technologies Substitutes
Assessment: Executive Summary; Industry: Screen Printing; Use Cluster; Screen
Reclamation. Office of Pollution Prevention and Toxics. Washington, DC. EPA-744R-94-
005.
The CTSA for Screen Printing Screen Reclamation focuses on the use cluster of screen
reclamation and is structured to evaluate such systems. The assessment evaluates the
products used in the system and chemicals that make up the products. Five individual
methods and technologies through which screen reclamation can be formed are summarized.
Available From: Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, B.C. 20460
(202) 260-1023
U.S. Environmental Protection Agency. Undated. Printing and Publishing Information Packet.
Compilation of information on printing and publishing.
Available From : Pollution Prevention Clearinghouse
Environmental Protection Agency
401 M St., SW (3401)
Washington, D.C. 20460
University of Northern Iowa. Iowa Waste Reduction Center. 1995. Pollution Prevention Manual
for Lithographic Printers.
Handbook covering all aspects of lithographic printing and the opportunities that exist for
pollution prevention and innovative technologies. Includes a bibliography, case studies, and
a list of resources for further contact.
Available From: Cathy Zeman
University of Northern Iowa
(319) 273-2079
C2-10 November 1995
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Annotated Bibliography of Selected References in Appendix Cl
Virginia Department of Environmental Quality. September 1993. Printers Win Through Pollution
Prevention (Video). Waste Reduction Assistance Program.
"Real Life" pollution prevention options for printers are highlighted in this video. A list of
vendors and associations that may provide information beneficial to printers accompanies
the video.
Available From: Waste Reduction Assistance Program
Virginia Department of Environmental Quality
Office of Pollution Prevention
P.O. Box 10009
Richmond, VA 23240-0009
(804) 762-4344
Virginia Waste Reduction Assistance Program. 1991. Waste Reduction Fact Sheet: Waste
Reduction for the Commercial Printing Industry. Vol. 1, Issue 2.
Short fact sheet on steps to reduce waste, and the toxicity of waste streams from printers.
Available From: Virginia Department of Environmental Quality
Office of Pollution Prevention
P.O. Box 10009
Richmond, VA 23240-0009
(804) 762-4344
C2-11 November 1995
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