Printers’National

EnvironmentalAssistance

Center

PNEACFlexographic Technical Foundation

National Satellite Videoconference

Produced by the University of Wisconsin-Extension

on behalf of

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Order Form For

PNEAC / FTA Videoconference Materials

High Performance Flexo:

Printing with a Cleaner, Greener Image

The following materials will be available after the videoconference to support your further training needs: Videotape of High Performance Flexo videoconference. Includes VHS tape of entire 4/27/00 national videoconference (2-1/2 hours), complete with course notebook. Price is $25 prepaid. I would like to order ___________ Videotape(s) @$25.00 each. Total enclosed $______________ High-Performance Flexo Workshop Packet: Includes videotape with case studies and supporting written materials to help a facilitator guide discussion about how the ideas presented in the case studies can be applied at participants= companies. An excellent resource for in-house discussions/workshops at flexo printing companies. Price is $25 prepaid. I would like to order ___________ Workshop Packet(s) @$25.00 each. Total enclosed $______________ Name:__________________________________________________________________________ Organization:____________________________________________________________________ Street Address:___________________________________________________________________ City, State , Zip Code:_____________________________________________________________ Payment must accompany order. All orders will be shipped at the lowest U.S. Postal Service rate unless payment is included for other shipping method. All foreign orders must add shipping. Payment must be in U.S. funds. Make check payable to University of Wisconsin-Extension and mail to:

Kimberly Swanson University of Wisconsin-Extension

Solid & Hazardous Waste Education Center 610 Langdon Street, Room 535

Madison, WI 53703 phone: 608-262-0910

fax: 608-262-6250

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Acknowledgements Development of this national videoconference has been made possible by the support from the following sources:

Grant funding to the Printers’ National Environmental Assistance Center from:

EPA Office of Enforcement and Compliance Assurance EPA Design for the Environment (DfE) Program EPA Air Pollution Distance Learning Network

Additional labor contributed by the University of Wisconsin-Extension’s

Cooperative Extension Distance Education Unit Solid & Hazardous Waste Education Center

Extensive assistance in developing, promoting and producing this program was graciously provided by the Flexographic Technical Association (FTA). Promotional support provided by the Illinois Waste Management and Research Center and the Graphic Arts Technical Foundation.

National and Regional Co-Sponsors The development, promotion and delivery of this program nationally was made possible through the collaborative efforts of the following organizations: Flexographic Technical Association Graphic Arts Technical Foundation Illinois Waste Management and Research Center National Pollution Prevention Roundtable Printing Industries of America Printers’ National Environmental Assistance Center Small Business Development Centers State Small Business Ombudsmen and Assistance Centers University of Wisconsin-Extension University of Wisconsin Solid and Hazardous Waste Education Center U.S. Environmental Protection Agency We would also like to thank all those organizations who generously allowed us to reprint portions of their materials, factsheets, or other documentation for use in this packet. Flexographic Technical Association Graphics Arts Technical Foundation (GATF) U.S. Environmental Protection Agency

Design for the Environment Program Office of Pollution Prevention, Pesticides and Toxics

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PERFORMANCE

INDIVIDUAL CREDITS:

EPA Project Officers Ginger Gotliffe and Tracy Back, OECA; Karen Doerschug and Bill Hanson, DfE

Program Design and Management Wayne Pferdehirt and Keith West,

PNEAC/SHWEC/UWEX; Doreen Monteleone, FTA Downlink Network and Logistics Kimberly Swanson, PNEAC/SHWEC Videoconference Producer Jim Leser, UWEX Course Notebook Development Keith West and Robert Gifford,

PNEAC/SHWEC/UWEX; Doreen Monteleone, FTA; Karen Doerschug, EPA. World Wide Web Promotions Robert Gifford, PNEAC/SHWEC/UWEX; Todd Schumacher, PNEAC/WMRC Videoconference Technical Support Jeff Finlay, Donna Anderson and Bill Lawrence, UWEX Instructional Design Advisor Nadeen Thompson, UWEX

Order Form For

PNEAC / FTA Videoconference Materials

High Performance Flexo:

Printing with a Cleaner, Greener Image

The following materials will be available after the videoconference to support your further training needs: Videotape of High Performance Flexo videoconference. Includes VHS tape of entire 4/27/00 national videoconference (2-1/2 hours), complete with course notebook. Price is $25 prepaid. I would like to order ___________ Videotape(s) @$25.00 each. Total enclosed $______________ High-Performance Flexo Workshop Packet: Includes videotape with case studies and supporting written materials to help a facilitator guide discussion about how the ideas presented in the case studies can be applied at participants= companies. An excellent resource for in-house discussions/workshops at flexo printing companies. Price is $25 prepaid. I would like to order ___________ Workshop Packet(s) @$25.00 each. Total enclosed $______________ Name:__________________________________________________________________________ Organization:____________________________________________________________________ Street Address:___________________________________________________________________ City, State , Zip Code:_____________________________________________________________ Payment must accompany order. All orders will be shipped at the lowest U.S. Postal Service rate unless payment is included for other shipping method. All foreign orders must add shipping. Payment must be in U.S. funds. Make check payable to University of Wisconsin-Extension and mail to:

Kimberly Swanson University of Wisconsin-Extension

Solid & Hazardous Waste Education Center 610 Langdon Street, Room 535

Madison, WI 53703 phone: 608-262-0910

fax: 608-262-6250

PERFORMANCE

This Page is Blank

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Acknowledgements Development of this national videoconference has been made possible by the support from the following sources:

Grant funding to the Printers’ National Environmental Assistance Center from:

EPA Office of Enforcement and Compliance Assurance EPA Design for the Environment (DfE) Program EPA Air Pollution Distance Learning Network

Additional labor contributed by the University of Wisconsin-Extension’s

Cooperative Extension Distance Education Unit Solid & Hazardous Waste Education Center

Extensive assistance in developing, promoting and producing this program was graciously provided by the Flexographic Technical Association (FTA). Promotional support provided by the Illinois Waste Management and Research Center and the Graphic Arts Technical Foundation.

National and Regional Co-Sponsors The development, promotion and delivery of this program nationally was made possible through the collaborative efforts of the following organizations: Flexographic Technical Association Graphic Arts Technical Foundation Illinois Waste Management and Research Center National Pollution Prevention Roundtable Printing Industries of America Printers’ National Environmental Assistance Center Small Business Development Centers State Small Business Ombudsmen and Assistance Centers University of Wisconsin-Extension University of Wisconsin Solid and Hazardous Waste Education Center U.S. Environmental Protection Agency We would also like to thank all those organizations who generously allowed us to reprint portions of their materials, factsheets, or other documentation for use in this packet. Flexographic Technical Association Graphics Arts Technical Foundation (GATF) U.S. Environmental Protection Agency

Design for the Environment Program Office of Pollution Prevention, Pesticides and Toxics

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PERFORMANCE

INDIVIDUAL CREDITS:

EPA Project Officers Ginger Gotliffe and Tracy Back, OECA; Karen Doerschug and Bill Hanson, DfE

Program Design and Management Wayne Pferdehirt and Keith West,

PNEAC/SHWEC/UWEX; Doreen Monteleone, FTA Downlink Network and Logistics Kimberly Swanson, PNEAC/SHWEC Videoconference Producer Jim Leser, UWEX Course Notebook Development Keith West and Robert Gifford,

PNEAC/SHWEC/UWEX; Doreen Monteleone, FTA; Karen Doerschug, EPA. World Wide Web Promotions Robert Gifford, PNEAC/SHWEC/UWEX; Todd Schumacher, PNEAC/WMRC Videoconference Technical Support Jeff Finlay, Donna Anderson and Bill Lawrence, UWEX Instructional Design Advisor Nadeen Thompson, UWEX

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Table of Contents

I. Program Goals and Agenda

II. Speakers’ / Program Notes �� Doreen Monteleone, Environmental Issues: Land Mines or Leverage for

Improvements �� Ink Management / Inside Flexo Video �� Case Study: Highland Supply Corp. �� Wayne Pferdehirt: Solvents, Wipes and Towels: Issues and Choices �� Case Study: Anagram International, Inc. �� Jim O’Leary: Update on Management of Used Shop Towels and Wipes �� Flexo Platemaking: Making Sense of Current Choices

1. Dan Owenby, Solvent & Aqueous Plate Processing 2. Brad Taylor, Digitally-Imaged Plates

�� Case Study: OEC Graphics, Inc. III. Supplementary Fact Sheets and Articles IV. Biographical Sketches of Presenters and Panelists V. Additional Sources of Information and Assistance

PHONE NUMBERS TO USE DURING THE PROGRAM Live Question and Answer Period: 1-800-442-4613 Fax Number: 1-800-348-9529

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PERFORMANCE

Goals �� Review and explain environmental compliance issues that directly

affect flexo printers. �� Explore how flexo printers are using innovative techniques and

recent technological advances to expand and improve their quality while eliminating environmental headaches.

�� Reveal how flexo printers are decreasing hazardous waste costs, improving indoor air quality, and reducing air permit problems by cutting down on solvent use, changing ink systems and evaluating their prepress technology.

�� Provide a guided investigation by flexo printing industry experts of recent and future technological breakthroughs that can improve day-to-day business while at the same time enhancing the environmental quality of operations.

�� Identify valuable contacts and resources for future information needs and technical assistance.

Agenda

High Performance Flexo: Printing With a Cleaner, Greener Image

(Times listed are Central Daylight Time)

9:00 Registration 9:15 Welcome and Introduction Local Host 9:30 National Broadcast Begins Welcome and Introductory Remarks Michael McCabe , Deputy Administrator, US EPA Bill Dowdell, President, FTA Wayne Pferdehirt, Co-director, PNEAC 9:39 Environmental Issues: Land Mines or

Leverage for Improvements? Doreen Monteleone, Director, Environmental Affairs, FTA

This overview explores the key environmental management issues that flexographic printers should be aware of and how these concerns can create either liabilities or opportunities to improve overall business performance.

PHONE NUMBERS TO USE DURING THE PROGRAM Live Question and Answer Period: 1-800-442-4613 Fax Number: 1-800-348-9529

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9:49 Ink Management

This session will concentrate on how important ink selection and management are when it comes to successfully reducing air emissions and hazardous wastes at flexo printing facilities. Footage will feature excerpts from Inside Flexo: A Cleaner Run for the Money, produced by US EPA DfE Program.

Case Study: Highland Supply Company, Highland, IL Get a glimpse into one flexographic printer’s journey into successfully converting to water-based inks. This practical, real-world case study will give participants a realistic view of the challenges involved in making the switch.

10:08 Pause for Developing Questions by Fax or Phone

A brief pause will allow downlink sites to develop questions on the preceding sessions that can be faxed or phoned into the studio for the panel’s response.

10:10 Live Question-and-Answer Session

Participants can use this opportunity to ask follow-up questions of Mike Klemme, Highland Supply Company; Doreen Monteleone, FTA; and Keith West, PNEAC. The panel will also include Dave Argent of Progressive Ink and Karen Doerschug of US EPA DfE.

10:24 Solvents, Wipes and Towels Wayne Pferdehirt, Co-director, PNEAC

The selection and management of solvents along with the choice and management of shop towels or wipes is an important environmental concern. This session will take a look at the key issues every flexo printer should consider in order to make an informed decision.

10:32 Case Study: Anagram, Inc., Eden Prairie, MN

Anagram, Inc. is a flexographic printer of Mylar balloons. Go inside the plant and see how the company improved the management of its solvent-based inks and cleanup solvents, drastically reducing emissions and hazardous wastes, while at the same time saving money.

PHONE NUMBERS TO USE DURING THE PROGRAM Live Question and Answer Period: 1-800-442-4613 Fax Number: 1-800-348-9529

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10:43 Update on Regulation and Management of Used Shop Towels and Wipes Jim O’Leary, Senior Policy Analyst, US EPA

This is the perfect opportunity to get the latest news on the US EPA’s efforts to develop national guidelines on the management of used shop towels and wipes - an issue that flexo printers are faced with daily. Jim O’Leary leads the US EPA’s drive to evaluate the need for national policy and regulations on this issue. He will present the up-to-the-minute developments regarding recent and pending regulatory changes and how they are likely to affect your day-to-day operations.

10:57 Pause for Developing Questions by Phone or Fax

A brief pause will allow downlink sites to develop questions on the preceding sessions that can be faxed or phoned in to the studio for the panel’s response.

11:01 Question-and-Answer Session/Discussion

Participants can use this opportunity to ask follow-up questions of industry experts including Sigmond Singramdoo, Anagram, Inc.; Jim O’Leary, US EPA; Dave Argent, Progressive Ink; Doreen Monteleone, FTA; and Wayne Pferdehirt, PNEAC.

11:16 Flexo Platemaking: Making Sense of Current Choices

This informative overview of flexo platemaking will reflect on the relative benefits of the technology with a special eye toward the impact on emissions and wastes. Some of the methods considered:

�� Solvent-washed Plates: Dan Owenby, Chemence �� Water-washed Plates: Dan Owenby �� Digitally-imaged Plates: Brad Taylor, DuPont

11:31 Case Study: OEC Graphics, Oskosh, WI

This progressive flexo platemaker is developing digitally-imaged plates for day-to-day operations. See how he has helped flexo printers to improve quality and performance while reducing photochemical and film wastes.

PHONE NUMBERS TO USE DURING THE PROGRAM Live Question and Answer Period: 1-800-442-4613 Fax Number: 1-800-348-9529

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11:38 Pause for Developing Questions by Phone or Fax

A brief pause will allow downlink sites to develop questions on the preceding sessions that can be faxed or phoned in to the studio for the panel’s response.

11:40 Question-and-Answer Session/Discussion

Participants can use this opportunity to ask follow-up questions of panelists Tom Underwood, OEC Graphics; Dan Owenby, Chemence; Brad Taylor, DuPont; Doreen Monteleone, FTA; and Wayne Pferdehirt, PNEAC.

11:55 Program Wrap-up and Evaluation

12:00 National Broadcast will end at Noon, Central Time. Local follow-up presentations and discussion where scheduled. PHONE NUMBERS TO USE DURING THE PROGRAM Live Question and Answer Period: 1-800-442-4613 Fax Number: 1-800-348-9529

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PERFORMANCE

II. Speakers’ / Program Notes

Doreen Monteleone Environmental Issues: Land Mines or Leverage for Improvements . . . . . II-3

Ink Management / Inside Flexo Video . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-9

Case Study: Highland Supply Corp. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-11 Fact Sheet: Reducing VOCs in Flexography: Highland Supply Corp., DfE . . . . .II-13

Wayne Pferdehirt

Solvents, Wipes and Towels: Issues and Choices . . . . . . . . . . . . . . . . . . II-19 Case Study: Anagram International, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-23 Fact Sheet: Anagram Saves Over $68,000 through Waste Reduction, MNTAP . . II-25

Jim O’Leary

Update on Management of Used Shop Towels and Wipes . . . . . . . . . . . . . II-29

Flexo Platemaking: Making Sense of Current Choices 1. Dan Owenby, Solvent & Aqueous Plate Processing. . . . . II-35 2. Brad Taylor, Digitally-Imaged Plates . . . . . . . . . . . . . . . II-43

Case Study: OEC Graphics, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-47

PHONE NUMBERS TO USE DURING THE PROGRAM Live Question and Answer Period: 1-800-442-4613 Fax Number: 1-800-348-9529

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Environmental Issues: Land Mines or Leverage for Improvement?

Doreen M. Monteleone, Ph.D.Director of Environmental Affairs

Flexographic Technical Association

Regulations

• Clean Air Act Amendments of 1990• Clean Water Act• Resource Conservation and Recovery Act• Comprehensive Environmental Response,

Compensation and Liability Act• Emergency Planning and Community Right-

to-Know• Safe Drinking Water Act• Toxic Substances Control Act

Different Presses

Different Substrates

Different Ink

Systems

Different Printers

Waste Can be Reduced Almost Anywhere in a Print Shop

Where Do I Begin?

• Do a facility walk through.• Develop a plan to:

– Reduce VOC emissions.– Reduce waste.– Improve environment inside

plant and outside.– Save money.

• Use environmental requirements as leverage for change.

Environmental Compliance

• Know your requirements.• All environmental regulations have thresholds

which mandate action or dictate requirements.

• Compliance begins with “lowest” governmental agency’s requirements.

Basic Principles of Compliance

Permit Requirements Control RequirementsReduce pollutants as close to the source as possible.

Reducing VOCs

• Evaluate ink alternatives.

• Evaluate your solvent use.

Using Solvent Inks

• Lowest VOC content possible - consult with ink manufacturer.

• Solvent reduction techniques - press operation and clean-up.

• More compatible with porous substrates.

• Use of corona treater on films.

• Wastewater management.

Converting to Water-Based Inks

Converting to UV Inks

• UV inks emit virtually no VOCs.• Technology has not been perfected in wide

web operations.• Continuing research.

Printing Plates• Perc alternative solvents (PASs).• Water washable flexo plates.• Digitally imaged flexo plates.

Used Shop Towels

• State policies dictate if/when used shop towels are considered hazardous waste.

• A national policy is being developed.

Carpe Diem(Seize the Day)

• Comply with regulations, print a quality product, improve the environment, increase your efficiency and save money.

• It’s never too late to begin.• Keep it a process of continual improvement.

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Inside Flexo: Ink Management Notes:

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This portion of the videoconference was prepared using segments from Inside Flexo: A Cleaner Run for the Money, a video produced through funding from the US EPA’s Design for the Environment (DfE) Flexography Project. For a free copy of the entire 19-minute video, please contact: Pollution Prevention Information Clearinghouse (PPIC) US EPA 401 M Street SW (7407) Washington DC 20460 Ph: 202-260-1023 Fax: 202-260-4359 e-mail: ppic@epa.gov

Please visit the DfE web site: www.epa.gov/dfe

PERFORMANCE

Case Study: Highland Supply Corp.

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Notes:

Case Study: Highland Supply Corp.

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Notes Continued:

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A Cooperative Projectbetween the U.S. Environmental Protection Agencyand the Printing TradeAssociationsNationwide

March 1997EPA 744-F-96-013 Flexography Case Study 1

FORTHEENVIRONMENT

Reducing VOCs inFlexography

This case study highlights the experience ofone wide-web flexographic printer thatsuccessfully reduced volatile organiccompound (VOC) emissions and hazardouswaste by switching inks. While every facility isunique, it is hoped that the informationprovided can help even very differentflexographic printers. In particular, this casestudy shows:� how a water-based ink system and

water-based cleaning procedure canreduce VOC emissions, hazardouswaste, operating costs, and workerhealth risks

� how the printer overcame challenges toprint successfully with water-based inks

Case Study Highlights� Highland Supply Corporation:

Company Background� Using Water-Based Inks� Environmental Benefits� Economic Benefits� Other Benefits� Commitment From Management and

Employees� About the DfE Flexography Project

Also in this case study:� Highland Supply Corporation:

Facility Profile� Eliminating Solvents in Other Areas

of the Facility

DfE Flexography Case Study 1: Reducing VOCs in Flexography p. 2 of 5

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Facility Profile Highland Supply Corporation,Highland, IL

No. of Employees150 to 250 (depending upon the season)

Output125 to 150 million linear feet annuallyfromflexographic presses

Main ProductDecorative packaging for the floralindustry

Plant Size50,000 square feet

PrintingPressesFive flexographic and ten rotogravurepresses

Primary InkWater-based ink (100% of product sales)

Primary SubstratePolypropylene (85% of product sales)

Type of PrintingReverse and surface; Line and processwork

Company Background

Highland Supply Corporation (HSC), at its Highland,Illinois facilities, manufactures decorative packagingproducts for the floral industry. Its product line includesprinted and laminated films, foils, and paper. In 1988,HSC made it company policy to reduce or eliminate airemissions and hazardous waste generation. HSC focusedon reducing one of its primary emissions, VOCs, for tworeasons. First, HSC was aware that VOCs can beharmful to worker health and the environment. Second,HSC predicted that federal and state environmentalregulations for VOCs would become more stringent inthe future.

The company found that its solvent-based inks (50%VOCs by weight) were the primary source of its VOCemissions. To reduce these emissions, the companyinitially looked into installing air pollution controlequipment such as solvent recovery or oxidizers. But iffuture regulations were to require further VOCreduction, these units could not be easily adapted. Inaddition, the electricity and natural gas required to runthem would be expensive. HSC decided instead toreduce its VOC emissions by replacing its solvent-basedink system with a water based system.

Water-Based Ink SystemIn 1989, HSC began using a new water-based ink on tworotogravure presses. The following year, water-basedinks were tested on the flexographic presses. By 1991,HSC was using the water-based ink on all its presses.Water-based inks now account for 100% of the total inkused in the facility.

When HSC first used the water-based ink system, thecompany encountered a number of new challenges,including some adverse customer response to the printquality of the inks. However, HSC was dedicated to thesystem and conducted many hours of research andtesting. The company modified presses and changedinternal color standards. Some other challenges HSCencountered, and the corresponding solutions, are listedbelow:

DfE Flexography Case Study 1: Reducing VOCs in Flexography p. 2 of 5

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Challenges Encountered with theWater-based Ink

HSC’s Solution

Drying of the ink was incomplete Improved drying systems by loweringtemperature and increasing air flow rates

Water fastness was insufficient Continuously improved ink formulations andadditives

Print quality was variable Monitored the pH and viscosity of the inks

Ink adhesion was insufficient Installed a corona treater

Printing metallic inks was difficult Continuously improved ink formulations andadditives

Printing UPC symbols was difficult Printed the white UPC symbol backgroundwith a water-based, high density ink

Cleaning the anilox rolls and plateswas difficult because the water-basedinks would not resolubilize

Installed an ultrasonic cleaner; switched to acitrus-based cleaner; allowed more time forcleaning

Environmental Benefits

VOC EMISSIONS WERE DRAMATICALLYREDUCED. In 1989, HSC’s water-based ink contained 10% to 12% VOCsby weight. By 1996, the average VOC content for water-basedink formulas was down to 0.71% VOCs by weight, accordingto HSC. The few VOCs remaining in the water-based inks arefrom dispersions and surfactants. HSC recently bought newequipment to use in creating its own VOC-free dispersions.

This reduction in the VOC content of the inks, along with theelimination of solvents in other areas of the facility, had adramatic effect on HSC’s total VOC emissions. The followinggraph shows the company’s annual VOC emissions for 1989,1991, 1993, 1995, and 1996, as reported to the IllinoisEnvironmental Protection Agency.

HAZARDOUS WASTE WAS ELIMINATED. The water-based ink system contributed to another importantbenefit. HSC reports that it completely eliminated hazardouswaste from waste ink and cleaning operations in 1994, 1995,and 1996. HSC generates a small amount of nonhazardoussolid waste from disposable cleaning wipes.

Eliminating Solvents InOther AreasHighland SupplyCorporation has stoppedusing traditional solvents inadhesive, cleaning, andmaintenance. For example:

In 1992, HSC installed anultrasonic cleaner to cleananilox and plate cylinders.

In 1993, HSC replaced othertraditional solvent-basedcleaners (methyl ehtylketone, methyl isobutylketone, and toluene) with amixture of water andd-limonene (a citrus-basedcleaner).

DfE Flexography Case Study 1: Reducing VOCs in Flexography p. 2 of 5

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RECYCLING WASTE INK. HSC also reduced the amount of total waste generated by recycling its water-based ink. When thecompany first used water-based inks, the waste ink was solidified and sent to a landfill under anonhazardous waste permit. Recycling of the water-based inks began in 1992. By 1995, HSCrecycled 99% of its waste water-based inks. Press return ink is stored in a separate containerlabeled with the formula ID number until it can be blended back into virgin ink of the same color.New colors can also be made, and hard-to-match waste ink can be made into dark green andblack inks. HSC also added a computer with a colorimeter and scanner to facilitate betterblending of the recycled inks.

Economic Benefits

REDUCED INK COSTS. HSC's new water-based inks cost less per unit area printed. This isbecause HSC's water-based inks have a higher ink mileage than the previously-usedsolvent-based inks.

HAZARDOUS WASTE DISPOSAL COSTS ELIMINATED. Since hazardous waste is nolonger generated, HSC spends very little on disposal costs. Solid nonhazardous waste disposalcosts totaled less than $1,000 in 1996.

LABOR HOURS SAVED. When HSC switched to water-based inks, some permittingrequirements were eliminated. HSC avoided the labor costs needed to meet these requirements. IfHSC was still using solvent-based inks today, more than 100 tons of VOCs would be emittedeach year, making HSC a "major source" under Title V of the 1990 Clean Air Act Amendments.Since HSC is not a "major source," it has avoided spending significant labor hours to prepare andfile initial permit applications, and will save additional labor hours every year in years to come.

In addition, HSC reduced flammable liquid usage below Occupational Safety and HealthAdministration (OSHA) reporting thresholds (Process Safety Management, OSHA 1910:119).Being exempt from this regulation saves HSC significant labor hours in the first year andadditional labor hours in subsequent years.

DfE Flexography Case Study 1: Reducing VOCs in Flexography p. 2 of 5

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Other Benefits

Additional benefits that improve HSC's safety, working conditions, marketing, and public imageinclude:� Eliminated health risks related to VOC exposure� Reduced fire hazard� Eliminated need for expensive explosion-proof storage� Improved public image and community relations

Commitment From Management and Employees

Comapny-wide commitment was essential to the success of HSC's switch to water-based inks. Tostrengthen this commitment, management integrated recycling and pollution prevention standardsinto the job descriptions for each employee, implemented aggressive health and safety programs,and conducted an internal pollution prevention assessment.

With a commitment from management and continuous improvement in the printing process, yourcompany can also realize the benefits of reducing VOC emissions and hazardous waste.

About the Design for the Environment Flexography Project

The goal of the Design for the Environment (DfE) Flexography Project is to provideflexographers with information that can help them design an operation which is moreenvironmentally sound, safer for workers, and more cost effective.

The partners of the DfE Flexography Project, in a voluntary cooperative effort, are evaluatingthree different ink technologies: solvent, water-based, and UV-cured. Information is beinggathered on the performance, cost, and health and environmental risk trade-offs of several inkswithin each technology.

In addition to the Flexography Project, similar DfE projects are currently underway with both thescreen printing and lithography industries.

To obtain additional copies of this or other bulletins and case studies, or for more informationabout EPA's Design for the Environment Program, contact:

Pollution Prevention Information Clearinghouse, (PPIC) U.S. Environmental Protection Agency 401 M Street, SW (7409) Washington, DC 20460 Phone: (202) 260-1023 Fax: (202) 260-4659 E-mail: ppic@epamail.epa.gov

Direct questions or problems regarding this page to: oppt.homepage@epamail.epa.gov

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Solvents, Wipes and Towels:Issues and Choices

Wayne PferdehirtCo-Director, PNEAC

Problems You Want to Avoid

• Hazardous Waste Costs and Liabilities• Expansion Restricted by Emissions

Reaching Permit Limits• Compliance Fines• Unnecessary Production Costs

Questions

• What Do Regulations Require?• How to Minimize Costs?

– Purchase– Handling and Use– Disposal

• How to Best Manage Risk?

Solvent Selection

• Inks and Solvents Work as System• Will Used Solvent be Hazardous

Waste?• What are Emissions and Effects on

Permits?• Storage Requirements?• Worker Health Impacts?

Comparing Alternative Solvents

• VOCs• HAPs• Vapor Pressure• Flash Point• Hazardous Constituents

Reducing Solvent Costs and Wastes

• Control Purchasing, Storage and Distribution• Minimize Number of Solvents Used• Modify Cleaning Procedures

– Reduce amount used– Reduce required frequency of cleaning

• Keep All Containers Covered• Look for Reuse & Recycling Opportunities

Comparing Disposable Wipes and Reusable Towels

• Costs• Performance• Regulatory Requirements for

Managing Used Towels and Wipes• Liabilities• Local Circumstances

– Disposal options– Laundry services

Reusable Towels

• Minimize Your Liability from Damages at Landfill

• Use Reputable, Properly Permitted Laundry Service

• Be Aware of State/Local Requirements for Managing Used Towels

• May Need Special Arrangements with Laundry to Ensure Cleanliness of Towels

Disposable Wipes• Offer Convenience and Purity (from lint and

contamination from previous uses)• Before Sending to Landfill, Be Sure to Know:

– Local regulations– Solvent(s) used– Nature of other residues on wipes– Names and quality of landfill facilities used by

hauler

• Consider Other Disposal Options to Reduce Liabilities– fuel blender– Municipal incinerator

Ingredients for Successful Change

• Expressed Priority and Commitment by Top Management

• Broad Teamwork in Identifying Problems and Opportunities

• Training in Use of New Materials and Practices

• What Gets Measured Gets Changed

Charting a Path

• What Does the Law Require?• What Can I Do to Best Manage

Potential Risks?• Start at the Source: Ink and Solvent

Selection and Use

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Case Study: Anagram International, Inc. Notes:

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Case Study: Anagram International, Inc. Notes Continued:

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Printing Environmental Technology

FACT SHEET

Anagram Saves Over $68,600 through Waste Reduction Reducing Solvent and Ink Purchases and Waste

in the Flexographic Printing Industry

Intern Project Summary, Minnesota Technical Assistance Program, University of Minnesota Intern Project Date: Summer 1996 Intern: Qui Hong, University of Minnesota, Chemical Engineering Senior Company: Anagram International, Inc., Eden Prairie, Minnesota Project: Reduce solvent and ink waste Results: Waste reduced by 30% Process Background Anagram International, Inc. manufactures products made of synthetically-based films. Their products include Mylar7 balloons, self-sealing valves, consumer gift packaging and industrial packaging. Anagram employs approximately 400 people and operates 24 hours a day, seven days a week. Anagram uses three six-color and one eight-color flexographic printing presses. Flexographic printing uses flexible raised-image printing plates and rapid-drying fluid inks to carry out direct rotary printing. Solvent is used to thin inks, clean the presses and wipe up ink spills. Used solvent is sent out for recycling then purchased back at less than virgin-solvent costs. The recycled solvent is used primarily to clean the printing decks. Incentives for Change The printing manager established a goal to reduce hazardous waste 25 percent by the end of 1996 as a cost cutting effort. Anagram=s printing operation generated most of their hazardous waste. At the start of the intern project, they generated 34 drums of hazardous waste a month. Waste from cleaning the printing decks made up about 75 percent (1,400 gallons) of the total.

MnTAP Fact Sheet: Anagram Saves Over $68,600 through Waste Reduction p. 2 of 4

II - 26

Options Implemented Multiple Stage Cleaning Every printing press had five to six buckets of pump-wash solvent nearby to clean each press' six to eight printing decks. One of these buckets would be randomly selected to flush the ink from the decks. Press cleaning was modified to an organized three-stage cleaning process.

Stage 1: Majority of the ink is removed using dirty solvent. Stage 2: Ink, left after the first stage, is removed using partially dirty solvent. Stage 3: Any remaining ink is removed by the cleanest solvent.

Using all three stages takes an extra four to six minutes per deck, but often using only the first two stages cleans sufficiently. When the solvent in the stage-1 bucket becomes too thick, it is emptied. Solvent is replenished by the subsequent stage (i.e., the solvent used as stage 2 becomes stage 1) and stage 3 is filled with fresh solvent. Solvent use decreases because the solvent is used longer before it is discarded. To make the system easy, each printing press has a cart with three buckets that are clearly labeled so employees know when each bucket should be used. Employee training on using the system and on its benefits, along with making the system easy to use were essential to the success of multiple-stage cleaning. Savings: $28,200 per year in solvent purchases and disposal costs. Reduces solvent waste by almost 120 drums per year. Shutdown Procedure During press shutdown, the ink pumps are placed in individual buckets of pump-wash solvent to prevent any solvent or ink from drying inside them. Fresh solvent was usually obtained to soak the pumps. Now, solvent buckets are dedicated for press shutdown and are not used for cleaning. The solvent remains fairly clean and is used indefinitely. Buckets of pump wash, designated by the signs that say APump wash used only to soak pumps@ are placed by each printing press and the press workers are trained on their proper use. Savings: Included in multiple-stage cleaning savings. Deck Draining Before a printing deck is cleaned, the ink from the ink chamber and hoses is drained into a bucket. Because of the layout of the pump and hoses, about two pounds of ink remains in the hoses of the bottom printing decks. When solvent is flushed through the system, more solvent is needed to clean out this wasted ink. Before cleaning, the ink is recovered by elevating the entrances to the hoses for ten seconds. Savings: $15,400 per year in ink purchases.

MnTAP Fact Sheet: Anagram Saves Over $68,600 through Waste Reduction p. 3 of 4

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Printing Deck Hose Length and Size Hoses between the ink pumps and the printing decks varied in length and often were longer than necessary, causing slack in the lines. During a color change, ink was lost when it did not drain completely. The intern determined the optimal hose length for each level of the printing decks. Now, a sign that lists the correct lengths and a ruler are located by the extra hose so employees can easily cut the correct lengths. Savings: Not determined. Recycled Solvent for Thinning Ink Anagram sends out their used solvent for recycling and purchases back the recycled solvent for use as press wash. Recycled solvent is now combined with virgin solvent (1:4) to thin the inks and it has no affect on printing quality. Savings: $16,800 a year in virgin solvent purchases. Recycled Ink Experiments determined that contaminated ink, which does not contain any white ink, can be reworked into the black ink. Contaminated ink is now added at ten percent to the black ink without affecting quality. Savings: $8,200 a year in ink purchases and disposal costs. Additional Options Floor Washings Anagram combines their waste from washing the floor with ink and solvent waste. Separating out the floor washings (2-3 drums per month) may permit them to be sewered. Anagram is reviewing this with their wastewater treatment authority. Savings: Not determined. On-site Solvent Distillation An on-site solvent recovery system was investigated. The system must use a vacuum in order to distill nitrocellulose, an ink component, which can be explosive when dry. The use of a solvent recovery system would eliminate the purchase of recycled solvent and would reduce the amount of waste being shipped out by over 75 percent. Potential savings: $29,100 annually in recycled solvent purchases and disposal costs. Would reduce hazardous waste by 240 drums per year.

MnTAP Fact Sheet: Anagram Saves Over $68,600 through Waste Reduction p. 4 of 4

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Results Implementing the options identified above has reduced Anagram=s hazardous waste by 30 percent. This will save them over $68,600 a year. Greater savings are possible if additional options are implemented. Anagram has completed other hazardous waste reduction projects as well. In eight months, they exceeded their goal - ahead of schedule - and reduced hazardous waste by 50 percent. More Information MnTAP has a variety of technical assistance services available to help Minnesota companies to manage and reduce their industrial waste. If you would like assistance or more information about MnTAP's Intern Program, call 612/627-4646 or 800/247-0015 from greater Minnesota. Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/or local regulatory agencies.

UPDATE ON MANAGEMENT OF USED SHOP TOWELS AND WIPES

Jim O’LearySenior Policy Analyst

US Environmental Protection Agency

Goals

• Describe current federal regulations• Give update on EPA efforts to revise

regulations

Current Federal Regulation

• Wipe or towel can be classified as hazardous waste if solvent or residue is hazardous

• Hazardous– If it exhibits a hazardous characteristic

(e.g., toxic, flammable)– If waste is a “listed waste”

EPA Deferred Interpretation to Regions and States

• EPA regions and nearly all states subject disposable wipes to regulation as hazardous waste

• Some regions and most states have allowed exemption of reusable shop towels from regulation as hazardous waste

Use of Towels and Wipes by Printers

• Typically use large numbers of towels or wipes

• Relatively large amounts of solvent per towel/wipe

• Many use solvents with flammable or toxic constituents

• Greater use of reusable towels than disposable wipes

Amount of Solventin Used Towels

• Two to three times the weight of towel• Typically 40 to 50 grams per towel

Reasons Argued for Exempting Reusable Towels

• Materials do not pose a risk to human health or environment

• Materials were being recycled

Key Question:Do solvent-contaminated towels and

wipes pose unacceptable risks to human health or environment?

• How should materials be managed?– At point of generation– During transportation– At handling facilities

• Should we be more concerned about certain handling practices over others?

Two Options Being Considered by EPA

• Option One: Not Considered Hazardous if– Stored in covered containers– Transported in closed, labeled containers– No free liquids– Shipped to industrial laundry or permitted

solid waste facility

Two Options Being Considered by EPA

• Option Two: Not Considered Hazardous if– Stored in covered containers– Transported in closed, labeled containers– No free liquids

and

Two Options Being Considered by EPA

• Option Two (continued)One of the Following Management Options Must be Used:– Disposed at permitted landfill

• Must be dry (less than 5 grams)• May not contain solvents on a list to be determined

– Recycled at permitted industrial laundry• Laundry to have specified weight limit on solvent-

contaminated towels received per yearor

• Laundry must assure that towels are dry (less than 5 grams solvent)

continued

Two Options Being Considered by EPA

• Additional Management Options Under Option Two – Industrial dry cleaner

• Permitted under CWAor

• Zero discharger

– Permitted municipal waste combustor– Safe solvent recycling facility– State-approved facility

Draft Language of Options being Evaluated by EPA

1. Industrial towels, wipes and rags that contain hazardoussolvents are not hazardous wastes subject to regulationunder 40 CFR parts 260, 261 to 266, 268 and 270 so long as

A. These materials are stored in covered containers at the generation site, and if transported off-site, thesematerials are stored in closed containers labeled “solvent-contaminated shop towels” or “solvent-contaminated wipes” or “solvent-contaminated rags”,

B. Prior to being transported off-site, these materials do not release any liquid when wrung, and

C. The materials go to an industrial laundry or to a facility allowed by state law to accept solid waste.

2. Industrial towels, wipes and rags that contain hazardoussolvents are not hazardous wastes subject to regulationunder 40 CFR parts 260, 261 to 266, 268 and 270 so long as

A. These materials are stored in covered containers at the generation site, and if transported off-site, thesematerials are stored in closed containers labeled “solvent-contaminated shop towels” or “solvent-contaminated wipes” or “solvent-contaminated rags”,

B. Prior to being transported off-site, these materials do not release any liquid when wrung, and

(continued)

Option 2 continued:

C. These materials are either:1. disposed of in a MSWLF or a Subtitle C landfill

after they are shown to be dry (less than 5 gramsper wipe, rag, or towel, on average) and they donot contain one of the following solvents found in Table X (to be determined),

2. recycled in an industrial laundry subject to CWArequirements, and the industrial laundry eitherreceives less than XX lbs (to be determined) of solvent-contaminated shop towels annually, or (2)assures that the shop towels are dry (less than 5 grams of solvent) before entering the launderingprocess, (continued)

Option 2 continued:

3. managed in an industrial dry cleaner subject to CWA requirements, or is a zero discharger ofdry cleaning waste water pollutants,

4. managed in a municipal waste combuster subjectto CAA requirements,

5. managed in a facility safely recycling the hazardoussolvents, or

6. managed in state-approved facility.

Anticipated Effects on Operations on Printers

• No free liquids• Shipment in marked, enclosed

containers• Laundries will act to reduce amount of

solvent in incoming towels– Centrifuging/wringing at laundry– Requiring control by customers

Comments from Printers

• Proposed changes could decrease inconsistencies in regulations

• Could foster more pollution prevention, reuse and recycling

• Concerns about clarity, flexibility and certainty of wording in rule

Dan OwenbyTechnical Service Manager

Chemence, Inc.

Topics to Cover

• Role of solvents in platemaking• Usage• Disposal

Solvents in Platemaking

• Part of making photopolymer printing plates

• Used to process photopolymer plates after imaging

Plate Washout

• Plates are washed out in solvent to remove uncured polymer to form a relief image on the surface

Plate Washout -Process

• Uncured polymer before washout

• Plate washing in solvent

• Plate after washing

Plate Processors

• Three main types of processors– Rotary

• Mainly solvent processing– Orbital

• Mainly aqueous processing– In-Line

• Used for both solvent & aqueous

Rotary Processor

Drum

Brushes

Solvent

Fumes

Orbital Processor

Solution

Platen

Brushes Plate

Rotary/Orbital Processors

• Washes plates on a rotating drum/oscillating platen

• Must be opened to mount/demount plates

• Fumes are readily breathable• Physical contact with solvent

highly likely during rinse and blot

In-Line Processor

Airflow

Airflow

Plate washing cassette

Rinsing brushBlotting brushes

Pre-drier

Vent stackto outside

Blower

Fumes

In-Line Processor

• Self contained• Closed to most fumes• Little physical contact with solvent• All washout operations done automatically

The Solvents

• Solvent: PAS Solvents (Hydrocarbon based)

• Aqueous: Lactic Acid/H2O• Aqueous: Surfactant/H2O

Solvent-Usage

• Is a replacement for perc.• Washout superior to perc.

– Is formulated to wash plates - not clean paint brushes, do laundry, etc.

• Is not a carcinogen• Can be used in most

existing perc processors

Solvent - Disposal

• Can be distilled for recovery & reuse

• Solid still bottoms typically can be landfilled

• Liquid still bottoms must be incinerated or fuels blended SOLVENT

Surfactant Solutions-Usage

• Specialized soap(s)• Defoamer(s)• Deionized water

– If needed• Suspends polymer

in washout solution

Solution Disposal -Continuous

Washout chamber

Mixing cone

To mixingcone

To filterbags

To sewer

Lactic Acid-Usage

• Lactic acid/water solution w/pH 2.0-2.5

• Used as an alternative to solvents

• Water wash formulation plates only

Lactic Acid-Disposal

• Spent solution ultra-filtered to separate water from polymer

• Polymer can typically be landfilled if dry

• Effluent reused or discharged to sewer after pH balance if local ordinances allow

SpentSolutionTank

Filter

EffluentTank

Economic Benefits-Aqueous

• No Solvent Cost• No Solvent Recovery Cost• No Hazardous Waste Cost• High Productivity

The Polymers

• Liquid• Sheet

Liquid-Usage

• Used to cast plates• Cures with UV lights• Washes out in water

and specialized soap(s), defoamer(s)

• Inert in cured, solid form

Liquid - Disposal

• Can be landfilled after curing solid

• Liquid to treatment, storage & disposal facility for incineration/fuel blending

Sheet-Usage

• Semi-solid sheet• Cures with UV lights• Washes out in solvent• Inert in cured form

Sheet - Disposal

• Can be landfilled after curing solid

Digitally-Imaged Plates

Brad Taylor, DuPont Corp.

Conventional Plate Making

Raw Plate

Film

UV Light

PolymerizePolymerizePolymerizePolymerize

Photopolymer Plate Processing

Washout DryLight

Finishing

FinishedRelief Plate

Cross-section

Digital Plate Structure

Photopolymer Plate

IntegralMask

Photopolymer plate with laser imageable mask

Digital Plate Imaging

Write image in black integral mask with laser

UV Light

PolymerizePolymerizePolymerize

Digital Plate Processing

Washout DryLight

Finishing

Cross-section

FinishedRelief Plate

Digital Plates Print Better !

Consistency

Small Features

Dot Sharpening

Exposure Latitude

White Highlights/Open Shadows

Offset Cut-Back

Plate Making Waste Comparison

Digital

• < 5 grams integral mask material

Waste Per Color for a 1 Square Meter Job:

Conventional• 1 liter chemistry (500 cc fixer, 500 cc developer)

• 2 square meters polyester film

II - 46

PERFORMANCE

Case Study: OEC Graphics, Inc.

II - 47

Notes:

PERFORMANCE

Case Study: OEC Graphics, Inc.

II - 48

Notes Continued

III- 1

PERFORMANCE

III. Supplementary Fact Sheets and Articles

Environmental Management of Photopolymer Flexographic Printing Plates, PNEAC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-3

Use of Blast Media to Clean Press Parts, PNEAC . . . . . . . . . . . . . . . . . . . . . . . . III-9

How to Read and Use an MSDS for Environmental Purposes, PNEAC . . . . . . . III-11 What is a Hazardous Waste?, PNEAC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-17 Basic RCRA Recordkeeping Requirements for Printers, PNEAC . . . . . . . . . . . . III-27 Understanding Air Pollution Permits, PNEAC . . . . . . . . . . . . . . . . . . . . . . . . . . III-31 Silver Recovery Systems and Waste Reduction Photoprocessing,

North Carolina Department of Environment, Health and Natural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-37

Environmental Compliance Checklist for Printers, GATF . . . . . . . . . . . . . . . . . III-43 Federal Environmental Regulations Potentially Affecting The Commercial

Printing Industry, DfE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-59 When Plates Go Bad! , Dan Owenby. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-65

The following are available at www.pneac.org under Fact Sheets/Case Studies: 1. Management of Aqueous Waste from Water-Based Flexographic Printing

Processor, FTA 2. Hood Flexible Packaging Saves $50,000 by Reducing Film Scrap, MNTAP 3. Learning from Three Companies that Reduced VOC Emissions, DfE 4. Water and Ink Waste Reduction at F.C. Meyer Company, Massachusetts Office of

Environmental Affairs 5. Replacement of Hazardous Material in Wide Web Flexographic Printing Process,

USEPA

PHONE NUMBERS TO USE DURING THE PROGRAM Live Question and Answer Period: 1-800-442-4613 Fax Number: 1-800-348-9529

III - 2

III - 3

Printers’ National Environmental Assistance Center

Printing Environmental Technology CASE STUDY

PNEAC www.pneac.org

1-888-USPNEAC

ENVIRONMENTAL MANAGEMENT OF PHOTOPOLYMER FLEXOGRAPHIC PRINTING

PLATES The defining characteristic of flexographic printing is the flexographic printing plate. Flexographic plates have the printing image in relief, which means the image area is raised relative to the non-image area. As with any industry, technological evolution has brought changes in flexographic plates. Plates made from light sensitive photopolymers are now being used throughout the industry. Photopolymer plates are similar to traditional rubber plates in that they are flexible and resilient, but their use poses different environmental concerns. In this fact sheet, environmental considerations are described in the use of various photopolymer flexographic plate development processes. CONVENTIONAL PHOTOPOLYMER PLATES Conventional photopolymer plates are either viscous liquids or solid sheets of various thickness. The photopolymer is exposed to ultraviolet light through a film negative and the unexposed areas are washed out by means of a solvent or water wash Figure 1. The result is the relief plate that is capable of transferring ink from the anilox roll to the substrate.

PNEAC Case Study: Environmental Management of Photopolymer Flexo Printing Plates, p. 2 of 5

III - 4

There are several steps to making conventional photopolymer plates. Though the process may differ slightly from system to system, they all require the following: • Back exposure of the plate base to UV light to harden (cure) the floor and establish relief

depth. • Face exposure of the plate surface to UV light through a film negative to harden (cure)

printed images. • Washout in appropriate solvent or water to remove unexposed polymer leaving printing

images in relief. • Dry to remove absorbed solvent. • Post exposure to UV light for a final cure of the floor and to establish character shoulders of

the raised image. • Finish plate with water, solvent or UV light to remove residual tackiness. In conventional photopolymer plate making, waste is created when the film is developed. Film processors use developer and fixer solutions which in most cases, can be discarded to the sewer after silver recovery is performed on the used fixer solution. In some regions of the country there is strict control of the waste silver. Both developer and fixer solutions can be removed, recycled and replaced by a film chemistry service. Rinse waters contain low concentrations of silver. Although there is little economic benefit to recovering silver from rinse waters, the Clean Water Act and stringent state/ local discharge regulations can trigger application of silver recovery on untreated wash water if the silver concentration exceeds regulatory limits. On-site recovery of silver involves metallic replacement, electrolytic recovery and chemical precipitation. After silver recovery, effluent is generally discharged into the drain where it goes to the publicly owned treatment works (POTW) for treatment and eventual release back to the environment. Processing solutions must not be discharged to a septic system and instead must be collected and shipped for processing. After use, the films must be discarded or, sometimes, recycled. Perchloroethylene (PERC, PCA), a Hazardous Air Pollutant (HAP), was traditionally used as a solvent to wash photopolymer plates. The regulation of chlorinated solvents due to air contamination, health hazards and hazardous waste has promoted the introduction of alternative solvent and water washable plates. For any type of flexographic printing plate, purchasing the right size sheet or using the correct amount of liquid, based on negative film size, will minimize waste of unexposed photopolymer. If waste is still generated, it is recommended to save unused strips as test plates for the resetting of exposure and washout conditions. For both solvent and water systems, filtered polymer, unexposed photopolymer plates and processed photopolymer plates are normally classified as non-hazardous wastes. Cured plates may be incinerated, or alternatively, sent to a landfill that is authorized to accept the material. However, they should be qualified to determine if they are hazardous wastes by exhibiting the characteristics of toxicity. Ask the plate supplier for details on what is a hazardous waste

PNEAC Case Study: Environmental Management of Photopolymer Flexo Printing Plates, p. 3 of 5

III - 5

Solvent Washable Plate Specifics Percholorethylene alternative solvents (PAS) are now being used by many platemakers. Drying times using PASs have improved significantly over earlier versions. PASs can be used to develop almost any solvent washable photopolymer plate. PASs are volatile organic compounds (VOCs) comprised of hydrocarbons and alcohol which can be eye and respiratory irritants. Therefore, adequate ventilation must be provided while PASs are being used. Also, safety glasses or goggles and gloves should be worn when handling these chemicals. PASs typically have a flashpoint of 150-200�F and are stable under normal room temperature and storage conditions. Solvent can be recycled, but its useable lifetime depends on the number and size of the plates and the amount of material removed. Once the solvent is spent, it can either be sent to an off-site distiller, or equipment can be purchased to distill the solvent on-site. PASs can be recycled by using vacuum distillation. PASs that are mixtures may require balancing (with chemicals) after distillation to get back to the correct ratio of components. Still bottoms generated from distillation are usually incinerated, but can be landfilled depending on local requirements. It also is possible to use still bottoms for fuel blending. It is advised to run the appropriate tests to determine if waste products are classified as hazardous wastes. If they are determined to be hazardous wastes, then they can not be landfilled without prior treatment. Information and test results should be available from the supplier to help with this determination. Water Washable Plates Specifics Water washable plates largely reduce or eliminate many of the concerns of solvent washable plates including emissions of VOCs; flammability because of lower flash point; hazardous waste; and influence on human health. The use of these more environmentally friendly water washable plates enhances corporate image with regulators, customers and the public. By switching to these types of plates, the need to purchase and install pollution control equipment may be reduced or avoided. Water washable plates come in two versions: sheet and liquid photopolymer. Early versions of water washable sheet plates had some limitations in their application. Recently, the qualities of water washable plates have been much improved. Water washable sheet plates are prepared with almost the same procedure as that used for solvent washable sheet plates. The biggest difference in process equipment between solvent washable plates and water washable plates is the washout unit, which is usually accompanied with a washout water treatment unit. A washout water treatment unit is designed to satisfy the requirements of most local POTWs. Analytical data of filtered washout water should be available from the plate supplier. However, before discharging filtered washout water into a sanitary drain, the local sewer authority should be contacted to determine if such discharge is permissible. Sometimes, secondary treatment may be required to pass strict limits along with the need to obtain a permit.

PNEAC Case Study: Environmental Management of Photopolymer Flexo Printing Plates, p. 4 of 5

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Water washable plates are also available as a viscous liquid. Liquid photopolymer resins (LPRs) are completely curable materials that are developed in a totally aqueous medium. Their main environmental advantage (over sheet material) is that unexposed portions of the plate can be reclaimed manually with a squeegee and reused. This is especially beneficial when a relatively large plate with minimal impressions is required. These materials are not regulated as hazardous substances or as toxic chemicals and are therefore not regulated as hazardous waste if discarded. LPRs contain no chemicals that are regulated as priority pollutants under the Clean Water Act (CWA). After the available unexposed liquid resin is recovered, the residual material is removed in an aqueous bath containing additives such as detergents, defoamers, stabilizers and water treatment agents. Spent washout solutions should be acceptable to most conventional POTWs that use typical biological treatment technology. Extracting uncured resin from the waste water requires the use of organic solvents which may indicate the presence of oil and grease. In some operations for which effluent would not meet local discharge limits prior to entering the sewer, pretreatment, such as flocculation, coagulation and clarification may be required. Before discharging any waste water, it is important to contact the local sewer authority to determine if the discharge is acceptable. Most discarded liquid resin systems are not regulated as hazardous wastes or as CWA priority pollutants. However, manufacturers recommend careful handling of the waste resin as LPRs can act as a skin irritant. Waste resins can be incinerated at a licensed treatment and disposal facility or they may be cured and disposed of as plate material. Contact the supplier for information and data to support the nonhazardous classification. DIGITAL PHOTOPOLYMER PLATES Traditional plate processing requires the use of film using developer and fixer chemicals and generates silver bearing waste. A significant environmental advantage of digitally imaged sheet photopolymer flexographic platemaking is that it uses no film during the production process. This eliminates used film and processing chemicals as well as the need for silver recovery equipment. First introduced in 1995, digital flexo plate imaging technology incorporates a very thin layer of material, termed the integral mask, that is not transparent to UV light. An imaging device (much like an imagesetter) using a high-power infrared laser(s) removes, or ablates, the integral mask in an imagewise fashion, revealing the uncured photopolymer underneath Figure 2a. The underlying photopolymer does not absorb the infrared laser radiation, and thus it is not affected by the laser ablation.

PNEAC Case Study: Environmental Management of Photopolymer Flexo Printing Plates, p. 5 of 5

III - 7

The digital plate receives a main ultraviolet exposure after laser ablating which images through the integral mask Figure 2b. The remaining black layer absorbs the ultraviolet radiation. The ultraviolet radiation polymerizes the underlying photopolymer where the black layer has been removed. The plate is washed, dried and finished with the same process as a conventional solvent washable photopolymer plate.

Today's digital plates are all solvent washable technology and like conventional processes using PASs, the solvent is handled, distilled and reused as discussed above for PASs. Water washable digital plates are in development. Like conventional photopolymer plates, filtered polymer, unexposed photopolymer plates and processed photopolymer plates are normally classified as non-hazardous wastes. However, they should be examined to determine if they exhibit the characteristics of toxicity. Characteristics of ignitability, corrosivity and reactivity may also need to be examined under RCRA. Ask the plate supplier for information and data to support the nonhazardous classification. Additional Information Author: Doreen Monteleone, PNEAC / Flexographic Technical Association For additional information on flexographic printing plates and environmental issues impacting flexographic printers, contact the Flexographic Technical Association at http://www.fta-ffta.org or call(516) 737-6020. For further guidance on managing photoprocessing waste water, contact the Silver Council at http://www.silvercouncil.org or call (301) 664-5150 and request information on the Code of Management Practice; Guide for Commercial Imaging. Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/or local regulatory agencies.

III - 8

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Figure 1. The parts cleaner features convenient access through fourglove ports on the front cabinet

Printers’NationalEnvironmentalAssistanceCenter

Printing EnvironmentalTechnology

CASE STUDY

PNEACwww.pneac.org

1-888-USPNEAC

Use of Plastic Blast Media to Clean Press PartsThe flexographic packaging industry has made great strides in reducing the total amount of solventsconsumed and emitted into the atmosphere. The reduction in the amount of volatiles in solvent inksand the conversion to water-based inks have allowed many companies to grow while reducing theiroverall emissions. Regulations have dictated the need for solvent-capture systems that are costly,but also greatly reduce total emissions. (See editor’s notes at the end of the article.)

Solvents and soak tanks are still common in packaging for cleaning press parts such as ink trays,pumps and buckets. However, a new blasting technology uses a unique plastic media to eliminatethe need for harsh chemistries and soak tanks. Using this technology, several companies havegreatly reduced chemical expenditures, disposal costs and operator exposure to the corrosive

chemistry.

Alliance Packaging (formerlyFlex Pack) in SacramentoCA, has taken advantage ofthe parts cleaner shown inFigure 1 to clean ink pumps,pans and other presscomponents. Alliance's LouFiguera estimates they havecut the consumption ofcleaning chemistry in half,resulting in savings of about$500 per week. Use ofammonia, various soaps andpH conditioners have been allbut eliminated using the parts

cleaner.

“Reducing operator exposure to harsh chemicals was a primary concern” states Figuera. “Eliminating the risk of exposure or injury was a major motivation to move toward the blasttechnology”

The plastic blast media will remove dried-on ink, without risk of damage to the part's surface. The72"x36" unit is totally enclosed, with four rubber gloves providing access through the cabinet front.

PNEAC Case Study: Use of Plastic Blast Media to Clean Press Parts p. 2 of 2

III - 10

Figure 2. A close-upof the plastic mediaused by the partscleaner.

The blast stream is initiated with a foot pedal, and a hand-held nozzle then focuses the blast on theparts requiring cleaning. The plastic media used in this system is similar to the plastic media usedin anilox cleaning systems, but is somewhat larger in particle size and more effective.

Once the blast has occurred, the plastic is returned to a reclaim unit. Thereturned media is sent through an elaborate air wash system, removing finedust particles from the dried-on ink. The good media returns to the blastunit again.

Over an extended period of time, (100-200 uses), the plastic media shownin Figure 2 begins to break down and becomes too fine for cleaning. Thisspent media, along with the fine dust from the ink, is captured in collectionbags and deposited in a tray for disposal as a non-hazardous waste (as longas the material removed from the parts is non-hazardous) .

At Alliance Packaging, the reduction of 150 to 175 gallons of chemical cleaning waste per week hassignificantly reduced disposal costs. A filtration system reduces six or seven barrels of liquid wasteto one 55-gallon drum of solid waste, but the cost for disposal of the solid is still $150 to $200 perbarrel. Those with different filtration systems may experience greater savings.

Cost-efficiency is only one benefit of this system. “Cleaned parts are now available for use in lessthan an hour, where previously they required an overnight soak, then lots of ‘elbow grease’ to clean”concludes Figuera. This provides a quicker cleaning process, one that reduces press downtime andcontributes to greater operating efficiency for the entire company.

Author: Dale Patterson, President of Absolutely Micro*Clean, LLC.This article first appeared in FLEXO magazine, July, 1998, p. 54-55, as ‘EnvironmentallyFriendly Cleaning’.

PNEAC Editor’s Notes: Mention of trade names of commercial products does not constitute endorsement or recommendationfor use by PNEAC or USEPA. Micro*Clean is listed in the PNEAC vendors list,<www.pneac.org/vendors/vendhome.html>.

The described process removes solvent-based inks best. It works well on both water-based and UV-cured inks. No cleaning solvent is introduced into this process. Printers using water-based or UVinks can see larger solvent emission reductions than those who clean with solvent reclaimed fromsolvent-based inks. Dry and brittle residue is removed better than wet or rubbery material.

Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor thetechnical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation.The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, workpractices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/orlocal regulatory agencies.

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Printers’ National Environmental Assistance Center

Printing Environmental Compliance Fact Sheet

PNEAC www.pneac.org

1-888-USPNEAC

How to Read and Use an MSDS for

Environmental Purposes OSHA mandates that each product used commercially which contains any hazardous ingredient must be accompanied by a Material Safety Data Sheet or MSDS upon entering a facility if there is one or more people employed at that location. The MSDS was initially designed to convey important safety hazard information and measures to protect persons who may come in contact with a product, including employees, fire fighters, etc. Current, revised, and obsolete MSDS must be kept on file at a facility for 30 years or as long as the company is in business (whichever comes first). The MSDS also serves to provide important environmental compliance information, including VOC content, hazardous chemical ingredients and their CAS numbers, product density, and vapor pressure. This information is required for hazardous air pollutant (HAPs) and VOC emission calculations, as well as other annual record keeping and reporting requirements, such as SARA 311 and 312 reporting There is currently no required format for a MSDS, but the most common is the OSHA Form 174 which contains 9 different sections. Other formats may illustrate the same required information, but in an alternative location on the sheet. This guide follows the same sequence as the OSHA Form 174. Each section of OSHA Form 174 is listed and environmental information or description is provided where applicable. Section I. Basic Product Information 1. Trade Name or Synonym. This name may not reflect the product's use or the name the product is referred to in your facility. It is recommended that the facility mark on the MSDS the department or application of the product if it is unclear on the MSDS. 2. Manufacturers Name and Address. This may be different than product source or supplier. It is advised that if the product supplier is different write their name and phone number on the MSDS sheet. 3. Emergency Telephone Number. There must be 24 hour telephone access to a company representative in case of a spill, release, or

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personal injury. Many suppliers of hazardous materials contract out to an emergency answering service provider such as Chemtrec. 4. Chemical Name of Product. Refers only to products that are single substances, such as methyl ethyl ketone. This information may be omitted if the product is a mixture or proprietary. 5. Date Prepared. Signifies the date the original MSDS information was compiled or last updated. This information should be used to verify whether a new MSDS has been updated or is a duplicate of current MSDS on file. 6. Signature of Preparer. Optional information, name and/or signature of the person who prepared the MSDS. Section II: Hazardous Ingredients This section lists the chemical name, CAS (chemical abstract service) number, and the quantity of the chemical within the product expressed in percent by volume or weight. This information is needed to calculate the chemical usage and storage quantities for SARA Section 311, 312, and 313 compliance as well as calculating HAPs and VOC emissions from the product for air permitting calculations or quantity of chemical released. Some state air operating permits specify how the VOC information must be calculated and the printer may need to work with the supplier to provide the VOC information in the correct units of measure. Many MSDS omit the VOC containing products in this section, but will list the total volatile content of the product. The printer will need to consult the supplier to obtain a product data sheet which provides information about the actual chemical and its concentration that is a VOC. A supplier may list chemical content as a range due to proprietary concerns, for example 10-15%. In this case the printer should verify the VOC content with the product supplier. If the actual VOC content cannot be verified, consider the higher percentage when calculating total concentration of VOC or HAP. VOC emission calculations and certification that the information is correct is the responsibility of the printer. In other words it is the printer's responsibility to verify that the VOC information that the supplier provided is correct. One way to assure that the information is correct is to request that the supplier determine the VOC content of their products through EPA Test Method 24 or Method 24A, which are analysis protocols for determining VOC content of liquids established by U.S. EPA. Section III: Physical Data 1. Boiling Point: The temperature in degrees F at which a liquid boils under normal atmospheric conditions.

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2. Vapor Pressure: The pressure of saturated vapor above the liquid in mercury at 68 degrees F. Boiling point (bp) and vapor pressure (vp) indicate how rapidly the material evaporates or how much VOC and HAPs are in the product. For example, Isopropyl alcohol has a boiling point of 180 degrees F and a vapor pressure of 33 mm Hg. Where as ethylene glycol has a bp of 379 degrees F and a vp of 0.1 mm Hg. Products with a low boiling point, vapor pressure and vapor density typically are high VOC products. Some state air regulations limit the vapor pressure of certain printing products, such as blanket wash or fountain solution (used in offset printing). When considering alternative products in order to reduce VOC emissions, the vapor pressure of a solution is a key factor. It is best to select products with low VOC and no or low HAP content and/or products with a vapor pressure of 10mm Hg at 20 C or less. A product which contains 100% VOC, but has a vapor press of 10mm of Hg at 70 at 20 C will emit approximately 30% VOC's by weight because the product does not evaporate as quickly. 3. Vapor Density: The weight of a vapor or gas compared with an equal volume of air measured at 60-90 degrees F. Vapor density indicates whether the vapor is heavier or lighter than air. With flammable materials, when the vapor density is greater than one, vapors will tend to move or collect in a low spot. Flame sources should be carefully controlled or avoided in these areas. For example the vapor density of isopropyl alcohol is 2.07, propane is 1.52, and helium is 0.1114; which means IPA and propane are an immediate fire hazard because the gas can collect in low spots within a building and easily ignite. 4. Solubility in Water: Indicates how quickly the material combines with distilled water at 50 F. It is measured in the following terms:

Negligible less than 0.1% Slight 0.1 to 1% Moderate 1 to 10% Appreciable more than 10% Complete in all proportions

5. Specific Gravity This is the ratio of the density of a material to the density of water. In other words, it compares the weight of water to the weight of material. This information is especially important in the event of a spill which can reach a lake or stream. 6. Evaporation Rate This the rate the material evaporates compared to either butyl acetate or ethyl ether. 7. Appearance and Odor

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A brief description of the material. Ex. viscous colored liquid with ammonia odor. 8. Percent Volatile by Weight This information may not be included (required on old format); the printer may need to ask the supplier in writing, to include this information on all MSDS or provide a product data sheet. This is the total VOC content of the product. This number should correspond with the sum of the VOC products listed in Section II. This number should be used to calculate the total VOC emissions of the product. This is calculated by multiplying the total pounds of material by the %VOC content listed (or gal product x density x %VOC). Some state air regulations limit the VOC content of products commonly used by printers. For SARA reporting purposes each reportable chemical listed, the printer must calculate the amount consumed or stored on site by the % content listed in the health hazard section. The total amount (in all mixtures and pure form) stored or consumed on site must then be compared to the reporting limit. If the reporting limit for any &quot;listed&quot; chemical is less than what was consumed or stored on site during any month or calendar year reporting requirements may apply. Section IV: Fire and Explosion Data 1. Flash Point The minimum temperature in degrees Fahrenheit, at which a liquid gives off enough vapor for the material to auto ignite. The most common test method is the closed cup method. 2. Flammable or Explosive Limits The range of gas or vapor concentrations (percent by volume in air) which will burn or explode if an ignition source is present. This is expressed as the lower explosion limit or LEL and the upper explosion limit or UEL. 3. Extinguishing Media Lists the fire fighting media suitable for use on the burning material. Some chemicals may negatively react to water which is the most common extinguishing media. Therefore alternative methods, such as carbon dioxide may be more suitable for extinguishing the flames. 4. Special Fire Fighting Procedures This includes information about the toxicity of combustion products, any special personal protective equipment, etc. 5. Unusual Fire and Explosion Hazards This describes any special potential hazards which may need attention. For example, if water is improperly applied to a flammable liquid with a flash point greater than 212 F, a violent boiling reaction could occur. Section V. Reactivity Data

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1. Stability Indicates whether a chemical is stable or unstable under reasonably foreseeable conditions of storage, use or misuse. If unstable, the potential reactions will be listed. 2. Incompatibility Lists chemicals and compounds that will negatively react with the product and should not be combined or stored. This is important to review prior to use and/or disposal. Shop towels and waste storage containers are one of the more common areas where incompatible materials are inadvertently combined and a negative reaction occurs. 3. Hazardous Decomposition or By-Products Describes the products produced as a result of heating, burning or oxidizing. For example, thermal decomposition of vinyl chloride plastics produces carbon monoxide (CO), carbon dioxide (CO2) and hydrochloric acid (HCl) 4. Hazardous Polymerization Describes the products that may be produced as a result of combining/exposing incompatible products. For example combining chlorine (bleach) with ammonia will produce hydrochloric acid. Section VI. Health Hazard Data 1. Routes of Entry Ways the material could enter the body. 2. Health Hazards (acute and chronic) Potential over exposure affects that will dissipate when moved away from product (acute) and potential health affects resulting from repeated, long term overexposure which leads to symptoms that remain fom greater than a few minutes/hours (chronic). 3. Carcinogenicity Indicates whether or not the product is known or suspect cause of cancer. 4. Signs/symptoms of Exposure 5. Medical conditions generally aggravated by exposure Lists potential medical conditions which will worsen as a result of exposure to this product. 6. Emergency and First Aid Procedures. Recommendations on how to treat victims of over exposure.

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Section VII: Spill and Leak Procedures 1. Steps to be taken in case material is released or spilled Describes special precautions if the material is spilled, such as evacuate area. 2. Waste Disposal Method This area rarely describes how the product should be disposed of because each state and local government's waste disposal regulations may be different. Check with the supplier and review your state and local ordinances for proper disposal methods. Additionally, review waste water discharge permits prior to flushing any product down any drain. 3. Precautions to be taken in handling and storing. Provides information such as recommendations for temperature control, light exposure, etc. which should be followed to avoid product degradation. 4. Other Precautions Section VIII: Control Measures 1. Respiratory Protection Specifies necessary protection to avoid inhalation overexposure. 2. Ventilation Indicates type of ventilation needed to avoid overexposure. 3. Protective Gloves/eye protection/other equipment Specifies the type of eye, hand and/or body protection that should be used while handling product. 4. Other Protective Clothing or Equipment Includes additional recommended protective garments not covered in #3. 5. Work/Hygienic Practices Provides information regarding personal handling such as washing hands prior to consuming food or beverage, etc. For additional information about pollution prevention opportunities in the printing industry call the PNEAC toll free number at 1-888-USPNEAC or contact : Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig(412/741-6860 Printing Industries of America - Ben Cooper (703/519-8115) Illinois Hazardous Waste Research and Information Center - Gary Miller (217/333-8940) or Debra Jacobson (630/472-5019) University of Wisconsin - Wayne Pferdehirt (608/265-2361) or Keith West (920/465-2940) or Bob Gifford (608/262-1083) Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/or local regulatory agencies.

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Printers’ National Environmental Assistance Center

Printing Environmental Compliance Fact Sheet

PNEAC www.pneac.org

1-888-USPNEAC

WHAT IS A HAZARDOUS WASTE? As a result of conducting its business, a printer may generate wastes that are considered hazardous or otherwise regulated by EPA, state, and local agencies including the Department of Transportation. If not handled and disposed of properly, these wastes can cause serious problems, injury or death of humans, animals, and/or plant life; or damage or pollute land, air, or water. In addition, improperly handled and disposed wastes expose the printer to liability ranging from possible enforcement actions including but not limited to fines, cleanup costs associated with Superfund liability, and, in extreme cases, criminal enforcement. This fact sheet is designed to provide information on how to determine if a waste is classified as hazardous under the federal regulations. The federal regulations were developed as a result of the passage of the Resource Conservation and Recovery Act signed into law in 1976. It is important to recognize that some states have differing definitions of hazardous or other regulated wastes. These additional and other wastes include more wastes than those covered by EPA’s regulations. However, all states must, as a minimum, include all of the wastes defined as hazardous under the federal regulations. Waste Determination The first and most important step is to determine if a spent material is in fact a waste. While this may seem to be obvious, the regulation’s definition of a waste is quite detailed and somewhat confusing. Essentially, a waste is any solid, liquid, or contained gaseous material that is no longer used and is either recycled, thrown away, or stored until sufficient quantities are accumulated for treatment or disposal. If a “waste” is used as a raw material in a subsequent process within the printer’s facility or other manufacturers, process, it is not considered a waste and therefore it does not have to be manifested. However other regulations, such as Department of Transportation hazardous material shipping requirements still, apply. After the material is determined to be a waste, it must be evaluated relative to its ingredients and physical characteristics. A waste is classified as a hazardous waste in one of two ways:

I. It exhibits any of the characteristics specified by EPA regulations or II. It is specifically listed as a hazardous waste in EPA regulations

Characteristic Wastes A waste is considered hazardous if it exhibits one or more characteristics identified in the federal regulations. The characteristics are:

�� Ignitability �� Corrosivity �� Reactivity �� Toxicity

Attached Chart A describes the four characteristics along with examples of waste characteristics possibly generated by printers. In reviewing hazardous wastes generated by printers, the most common wastes

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generated exhibit one or more of the four characteristics. Of the characteristic wastes, D001 or ignitables are the most prevalent waste due to spent cleaning solvents with flashpoints below 140�F. Listed Wastes A waste is considered hazardous if it appears on any one or more of the four hazardous waste lists (F, P, K, or U) contained in the federal regulations. Wastes falling on one of the four lists have been classified as hazardous because they contain any of a number of toxic constituents that have been shown to be harmful to health and/or the environment. EPA regulations specifically list over 400 hazardous wastes, including specific wastes derived from manufacturing processes and discarded commercial chemical products. The next most common wastes generated by printers, after characteristic wastes, are F-listed ones. The F-listed wastes apply to those wastes that are considered used or spent. Understanding the F-listed category can be somewhat challenging and confusing. Attached Chart C contains the list of F categories. In order for a waste to be classified as F001, F002, F004, or F005, it must contain a total of 10% or more (by volume) of one or more of the chemicals listed in that category. For example, a waste solvent blend containing 10% methylene chloride and 90% water would be classified as an F002 waste. For the F003 category, a waste must either be 100% of any of the chemicals in the F003 category or contain one of the chemicals in the category and 10% or more of any chemicals in F001, F002, F004, or F005 categories. Any waste chemical in the category originally used as a “technical grade” is also considered 100%. For example, a waste solvent blend containing 5% xylene, 15% methylene chloride, and 80% water would be classified as an F003 and F002 hazardous waste. Likewise, a waste solvent blend containing 15% xylene, 15% methylene chloride, and 70% water would also be classified as F002 and F003. However, a waste solvent blend containing 25% xylene, 5% methylene chloride, and 70% water would not be classified as an F-listed waste. Depending upon the flashpoint of the waste, it could be still classified as a hazardous waste. If the flashpoint is below 140�F, then it would be a D001 or ignitable hazardous waste. It should also be noted that the waste could be characteristically toxic, depending on the cleaner and/or residues removed by the cleaner. The U and P listed wastes are for those discarded, unused commercial chemical products that are either 100% pure, technical grade, or any formulation where the chemical is the active ingredient. K-listed wastes are those from specific industrial manufacturing processes such as lead or chrome pigment manufacturing. Few if any printers generate P or K listed wastes. Attached Chart D contains several U-listed chemicals that could be generated by a printer. In some instances, a waste may receive two designations or classifications. Generally the primary ingredients in the waste will be the primary classification, with the other classification being noted on the manifest. When there may be confusion with these types of wastes, it is best to consult the state agency, state technical assistance provider, or PNEAC. Multiple classifications of wastes are not common within the printing industry. Hazardous Waste Determination It is the printer’s responsibility to determine whether the wastes generated at the facility are hazardous and the subsequent classification that is to be assigned to the waste. EPA allows for two approaches to determine if a waste is hazardous:

I. The generator can “apply knowledge” or II. The generator can test the waste using a variety of test methods.

Applying knowledge of the physical characteristics of a chemical or material and how it is used in a given process is the most cost-effective method of hazardous waste determination. Under this approach, the

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printer applies knowledge of the material's physical characteristics and its use to determine whether the waste is hazardous. For example, the generator would identify which purchased materials were combined in the generation of the waste. Those materials, plus any contaminants that the materials might have picked up during use, would have to be evaluated to determine if the resulting waste has, or might have, a listed hazardous constituent (see above) or exhibits a hazardous waste characteristic (i.e., ignitability, corrosivity, reactivity, or toxicity). Material safety data sheets (MSDSs) are a commonly used source of information for this analysis. If a material is chemically unchanged (e.g., uncontaminated ink), the MSDS would be representative of the material as a waste. Is the flash point of the cleaning solution 140�F or less? If so, the waste cleaning solution and ink mixture is ignitable and gets a designation of D001. Does the waste have a pH less than or equal to 2.0, or greater than or equal to 12.5? If so, it is corrosive and gets a designation of D002. The MSDS and other product information can also be used to compare the ingredients to either list of “listed” hazardous wastes. If the applying knowledge review is inconclusive, testing should be performed to be certain of the waste’s classification. The “applying knowledge“ approach is best used to document clear-cut cases where it is obvious that the materials used and the manner in which they are used would not result in a hazardous waste. Improper classification of a hazardous waste as non-hazardous does not relieve a generator of the liabilities that could result from improper disposal of the hazardous waste. In some cases where it appears likely but uncertain that a waste is non-hazardous, testing can be performed to verify the analysis. This testing could then be used as part of the data that is used in the “applying knowledge“ review of subsequent wastes generated from the same input materials and processes. In using the applying knowledge approach it is important to note that very few waste streams are solely composed of just the uncontaminated material itself. Typical waste streams are usually mixtures of several waste products. For example, waste press cleaning solvent will actually be a mixture of the solvent and the ink. Therefore, when the applying knowledge approach is used, remember � the hazard classification needs to take into account the entire waste mixture and not just one of the ingredients. When using MSDSs as part of the “applying knowledge” approach, recognize that MSDSs are not required to address all of the environmental concerns related to a product. MSDSs are not environmental data sheets, which means that although they do contain very important and useful information about a product, they are not required to detail all of the environmental concerns associated with a given product. MSDSs are mandated by OSHA, and their purpose is to provide information about the health and safety aspects associated with a particular chemical or product. MSDSs are prepared by manufacturers, suppliers, and importers to meet OSHA requirements regarding the health and safety aspects of a product. Helpful environmental information is often included on MSDSs, but this information should not be assumed to be exhaustive. When in question, ask the supplier or manufacturer for more information. In some cases, testing may be appropriate to supplement or verify information from the manufacturer. To illustrate the limitation of MSDSs when making waste classification determinations, it should be recognized that MSDSs are only required to report hazardous ingredients that are present in concentrations of at least 1%, or 0.1% for carcinogens. A 1% concentration translates to 10,000 parts per million (ppm). Likewise, a chemical present in a 0.1% concentration would be equivalent to 1,000 parts per million. The threshold quantities for several toxic criteria chemicals is substantially below 10,000 parts per million (see TCLP threshold levels in Chart A); for example, the hazardous waste threshold level for carbon tetrachloride is 0.5 parts per million. To address this inadequacy of MSDSs as a sufficient basis to make hazardous waste determinations, request that suppliers provide you with a written statement identifying any constituents in their materials that may cause the resulting waste to be classified as hazardous waste. Testing the waste, although incurring more cost than applying knowledge, can provide specific results to determine if a waste is hazardous. The types of tests commonly used are flashpoint, pH, and toxicity characteristic leaching procedure (TCLP). TCLP contains specific testing procedures that must be followed, and the ones used depend upon the physical state of the particular waste being analyzed. TCLP will be used to determine heavy metal content and the concentration of certain other organic

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chemicals. Chart B contains the complete list of chemicals regulated under TCLP and a list of possible TCLP wastes generated by printers. The first step in testing involves obtaining two samples of the waste. One waste sample is sent to a testing laboratory to conduct an analysis of the waste. The other sample is retained in case the first sample becomes lost, contaminated, or if the results of the first sample are questionable. Samples should be representative of the waste chemical, meaning the waste material should be collected at the point of generation (e.g., cleaning solvents used after cleaning, used fountain solutions including additives, etc.). Once the samples are collected, they should be sealed in a clean, durable, and compatible container, dated, and either shipped immediately to the laboratory or refrigerated until shipment can be made. To ensure that the samples remained untampered, a chain of custody should accompany them from the moment it was collected until it is received at the laboratory. The chain of custody is used to show when the sample was passed along to other parties, identifying everyone who had access to the sample. Documentation It is very important that you can prove that all waste streams have been properly classified. Whether you apply knowledge or test the waste, some form of documentation is necessary. Attached is a waste profile sheet that should be used for classifying each waste stream. The sheet should be kept on file along with copies of MSDSs and any results of tests conducted on the wastes. In many instances, vendors who transport/dispose your waste typically conduct these tests. Depending upon the particular waste, tests for pH, flashpoint, and TCLP should be conducted. These test results should be attached to the profile sheet. As long as the wastes remain the same, retesting or reprofiling is not required. Liability Management Because hazardous waste is generated as a result of an industrial manufacturing process, it is subject to strict government disposal regulations. Under the current environmental laws and regulations, all industrial waste streams generated by a printer are that printer’s responsibility forever, even if the printer follows all applicable regulations. Hazardous waste that is improperly disposed or was once legally disposed that eventually causes environmental contamination can result in Superfund liability for the printer. Therefore, it is imperative that all wastes, including nonhazardous ones, be properly handled and disposed of in as permanent fashion as feasible. The best approach to ink waste disposal is to not generate it in the first place. Several techniques can be used to reduce, recycle, or reuse materials. Several fact sheets addressing this subject for various products used by printers can be found on PNEAC’s web page at www.pneac.org. Printers who have adopted some or all of these approaches have reduced the amount of waste generated. Since disposal of waste is inevitable, preferred methods include neutralization, stabilization, solidification, incineration, or other appropriate treatment methods. Landfilling of hazardous waste should not be considered. In fact, it is illegal to landfill hazardous waste without first treating it. Landfills should be avoided for chemical nonhazardous wastes as they only represent long-term storage. They do not offer a permanent means of disposal, and printers have been caught in Superfund cleanup actions because they had landfilled ink waste. Summary and Conclusion It is the printer’s responsibility to properly characterize and manage their waste streams, including hazardous waste. This is why it is critical that the printer understands the definition of a hazardous waste so that all wastes generated can be properly classified. Classifying nonhazardous wastes as hazardous increases a printer’s liability and disposal costs, and can cause the printer to be classified as a larger generator than it actually is, which results in increased compliance requirements. Most importantly, all wastes must be properly identified, managed, and disposed, or the printer can face cleanup liability concerns. Hazardous waste carries additional concerns in that improper classification, management, and disposal can lead to enforcement actions. It is also essential to recognize that some states regulate

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certain wastes as hazardous per state waste regulations. For example, although EPA does not consider used oil being recycled to be a hazardous waste, many states regulate used oil as hazardous waste. Accordingly, the printer needs to understand both the federal definition of waste (as presented in this fact sheet) and what additional wastes the state defines as hazardous. Adoption of appropriate reduction, reuse, and recycling techniques and employing permanent treatment methods will help reduce liability to the greatest possible extent. In all but very limited circumstances, a printer’s liability for waste can never be completely eliminated. For additional information about pollution prevention opportunities in the printing industry call the PNEAC toll free number at 1-888-USPNEAC or contact : �� Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig(412/741-6860 �� Printing Industries of America - Ben Cooper (703/519-8115) �� Illinois Hazardous Waste Research and Information Center - Gary Miller (217/333-8940) or Debra Jacobson

(630/472-5019) �� University of Wisconsin - Wayne Pferdehirt (608/265-2361) or Keith West (920/465-2940) or Bob Gifford

(608/262-1083) �� RCRA/Superfund Hotline (800/424-9346), Washington, DC (703/557-1938) �� Your state hazardous waste management agency �� Your EPA regional office Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/or local regulatory agencies.

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Chart A Characteristics of Hazardous Waste

Characteristic Criteria Of Characteristic Waste Possible Printing-Related

Sources Waste Code

Characteristic of Ignitability

�� A liquid (expect solutions containing less than 25% alcohol) that has a flash point below 140� (60�C); or

�� A non-liquid capable of spontaneous and sustained combustion under normal conditions; or,

�� An ignitable compressed gas (as defined by DOT); or

�� An oxidizer (as defined by DOT)

Chemical products such as blanket and roller washes, cleanup solvents, isopropyl alcohol, and inks. Shop towels being thrown out for disposal

D001

Characteristics of

Corrosivity

�� An aqueous material with a pH less than 2.0 or greater than or equal to 12.5%; or

�� A liquid that corrodes steel at a rate greater than ¼ inch per year at a temperature of 130�F (55�C)

Plate and film processing chemicals, particularly etching chemicals. Acids, waste battery acid, and alkaline cleaners, depending on their pH.

D003

Characteristic of Reactivity

�� Normally unstable and reacts violently without detonating; or

�� Reacts violently or forms an explosive mixture with water; or

�� Generates toxic gases, vapor, or fumes when mixed with water; or

�� Contains cyanide or sulfide and generates toxic gas vapors or fumes at a pH between 2 and 12.5.

Waste bleaches and oxidizers

D003

Characteristic of Toxicity

�� Contains specific toxic contaminants above threshold levels;

�� Waste needs to be tested2 using specific test method(s);

�� List of some common printing contaminants and threshold levels are provided on the following pages.

Waste fixer, plate processing chemicals, ink, and cleanup solvents, and specific pesticides. Please see next chart for specific toxic contaminants.

D004-D043

Notes: 1. For solvents, check the MSDS. Normally the product’s flash point will be provided as “Physical Data.” 2. Testing is normally done by an outside laboratory or through a disposal company.

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Chart B List of Chemicals Regulated by TCLP

Organics Regulatory

Levels Waste Code

Metals

Regulatory Levels

Waste Code

Benzene 0.50 ppm D018 Arsenic 5.0 ppm D004 Carbon tetrachloride 0.50 ppm D019 Barium 100.0 ppm D005 Chlordane 0.03 ppm D020 Cadmium 1.0 ppm D006 Chlorobenzene 100.0 ppm D021 Chromium 5.0 ppm D007 Chloroform 6.0 ppm D022 Lead 5.0 ppm D008 Cresol 200.0 ppm D026 Mercury 0.2 ppm D009 m-Cresol 200.0 ppm D024 Selenium 1.0 ppm D010 o-Cresol 200.0 ppm D023 Silver 5.0 ppm D011 p-Cresol 200.0 ppm D025 1,4-Dichlorobenzene 7.5 ppm D027 1,2-Dichloroethane 0.50 ppm D028 1,1-Dichloroethylene 0.70 ppm D029 2,4-Dinitrotoluene 0.13 ppm D030 Heptachlor (and its epoxide) 0.008 ppm D031 Hexachlorobutadiene 0.5 ppm D033 Hexachlorobenzene 0.13 ppm D032 Hexachloroethane 3.0 ppm D034 Methyl ethyl ketone 200.0 ppm D035 Nitrobenzene 2.0 ppm D036 Pentachlorophenol 100.0 ppm D037 Pyridine 5.0 ppm D038 Tetrachloroethylene 0.7 ppm D039 Trichloroethylene 0.5 ppm D040 2,4,5-Trichlorophenol 400.0 ppm D041 2,4,6-Trichlorophenol 2.0 ppm D042 Vinyl chloride 0.20 ppm D043 Endrin 0.02 ppm D012 Lindane 0.4 ppm D013 Methoxychlor 10.0 ppm D014 Toxaphene 0.5 ppm D015 2,4-Dichlorophenoxyacetic acid 10.0 ppm D016 2,4,5-Trichlorophenoxypropionic acid

1.0 ppm D017

Possible EPA Toxic Characteristic Contaminants Found in Printing Waste Contaminant

Waste Code

Regulatory Threshold

Contaminant

Waste Code

Regulatory Threshold

Barium D005 100.0 ppm Silver D011 5.0 ppm Benzene D018 0.5 ppm Trichloroethylene D039 0.5 ppm Chromium D007 5.0 ppm Vinyl chloride D043 0.2 ppm Carbon tetrachloride D019 0.5 ppm Methyl ethyl ketone D035 200.0 ppm

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Chart C Examples of F-Listed Wastes F001 The following spent halogenated solvents used in degreasing: tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of 10% or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures. F002 The following spent halogenated solvents: tetrachloroethylene, trichloroethylene,

methylene chloride, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2-triflouroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before use, a total of 10% or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F001, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F003 The following ignitable non-toxic solvents: xylene, acetone, ethyl acetate, ethyl benzene,

ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents; and all spent solvent mixtures/blends containing before use, one or more of the above non-halogenated solvents, and a total of 10% or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F004 Toxic non-halogenated solvents: Aerosols, cresylic acid and nitrobenzene, all spent

solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents; and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and a total of 10% or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F005 The following spent non-halogenated solvents: toluene, methyl ethyl ketone, carbon

disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before use, a total of 10% or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

PNEAC Fact Sheet: What is a Hazardous Waste?, p 9 of 10

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Chart D Possible U-Listed Wastes Found In Printing Waste

Name/Description Waste Code

Name/Description Waste Code

Acetone Benzene Carbon tetrachloride Chromium Cumene Cyclohexane Dibutyl phthalate Ethyl acetate Ethanol, 2-ethoxy Ethylene glycol monoethyl ether Formaldehyde Methanol

U002 U019 U211 U007 U055 U056 U069 U112 U359 U359 U122 U154

Methyl chloroform Methylene chloride Methyl ethyl ketone (MEK) Methyl isobutyl ketone Tetrachloroethylene (perchloroethylene) Toluene Toluene diisocyanate Trichloroethylene Vinyl chloride Xylene

U226 U080 U159 U161 U210 U220 U223 U228 U043 U239

PNEAC Fact Sheet: What is a Hazardous Waste?, p 10 of 10

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Waste Profile Sheet General Information Department ______________________ Waste Coordinator ___________________ Waste Name ________________________________________________________ Process Generating the Waste __________________________________________ ___________________________________________________________________ Waste Generation Rate (Gallons or pounds per month) ______________________ Current Disposal Procedure ____________________________________________ ___________________________________________________________________ One-Time Disposal? Yes ___ No ___ Waste Classification Nonhazardous _____ Residual Waste _____ Hazardous _____ If so, list the EPA Waste Codes: _______ ______ ______ _____ Waste Composition Tests of Representative Sample Yes ___ No ___ (attach test results) Process Knowledge Yes ___ No ___ (attach supporting documentation, e.g. MSDSs) Waste Composition Percent 1. ___________________________ ___________ 2. ___________________________ ___________ 3. ___________________________ ___________ 4. ___________________________ ___________ 5. ___________________________ ___________ 6. ___________________________ ___________ General Parameters: Flash Point ______°F pH ______ Physical State at 70°F Solid ____ Liquid ____ Semi-Solid ____ Gas ____ Waste Packaging Type & Size (e.g., 55-gal, drum) ____________________________ Waste Coordinator Signature _____________________ Date _________________

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Printers’ National Environmental Assistance Center

Printing Environmental Complinace Fact Sheet

PNEAC www.pneac.org

1-888-USPNEAC

Basic RCRA Recordkeeping Requirements For Printers The Resource Conservation and Recovery Act (RCRA) of 1984 gave the U.S. Environmental Protection Agency (EPA) the authority to regulate municipal and hazardous waste. The purpose of this fact sheet is to provide a basic understanding of the various recordkeeping requirements mandated by EPA. Depending on state and local requirements, additional recordkeeping requirements and longer record retention requirements may apply. RECORDKEEPING: The information below in a starting point for determining if your RCRA required records are in order. Since paperwork is one of the easiest noncompliance issues to spot during an EPA audit, keep your paperwork in order. Here are some records to keep. ! EPA Identification Number / Notice of Hazardous Waste Activity (40 CFR 262.11) Prior to offering hazardous waste to transporters or treatment, storage, or disposal facilities a generator must obtain a EPA (waste generator) identification number. The facility must complete EPA form 870012 and submit it to the Agency. Copies of the application and notification/assignment of the facilities assigned identification number must be kept on file. No specified record retention period. Note, this number does not expire or change, unless the facility relocates. ! Hazardous Waste Storage and Accumulation (40 CFR 262.34) Facilities that generate greater than 221 lbs per month (SQG & LQG) of hazardous waste are required to train affected employees on proper waste handling and emergency procedures, maintain documentation on waste handling procedures, which includes designated emergency response personnel; documentation on duration and date of waste storage, and a written storage time compliance procedure. No specified record retention period. ! Manifests and Land Disposal Notification (40 CFR 262.40) Facilities that generate greater than 221 lbs per month (SQG & LQG) of hazardous waste are to maintain copies of each signed manifest. One copy should be retained when the waste is transported from the facility and the second copy must be signed and supplied by the disposal facility within 45 days after the waste leaves the generator's facility. The facility's manifests or the signed manifests from the treatment storage and disposal facility receiving the hazardous waste are to be retained for 3 years. Records of test results, waste analyses, or other determinations that the waste is hazardous must be kept for 3 years. ! Biennial Report (40 CFR 262.41) A Biennial Report (each even numbered year) must be submitted to the USEPA by Small Quantity and Large Quantity Generators no later than March 1"' (on odd numbered years most states require a report be submitted to the state agency). A copy of the Biennial Report and Exception Report must be kept for 3 years. ! Exception Reporting (40 CFR 262.42) If the hazardous waste generator does not receive a signed copy of the manifest from the disposal facility within 45 days after the waste was accepted by the initial transporter, an Exception Report must be supplied to the state regulatory agency and a copy of this report must be retained with the manifest. The exception report must be retained for at least 3 years.

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! Hazardous Waste Minimization/Pollution Prevention Requirements (40 CFR 262

App) Hazardous waste generators using a manifest under the "Generator's Certification" attests to "If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to one which minimizes the present and future threat to human health and the environment; OR, if I am a small quantity generator, I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford." In other words a waste minimization and pollution prevention plan is required to be implemented. It is recommended that a written program be developed and retained on-site. ! Hazardous Waste Storage Area Inspection (40 CFR 265.1101) The hazardous waste storage area must be inspected at least every 7 days to monitor leak detection equipment and detect signs of releases of hazardous waste in or around the containment area. Records of weekly inspections must be maintained for at least 3 years. ! Recyclable Materials (40 CFR 266.70) Persons Who Generate or Store Recyclable Materials That Are Reclaimed to Recover Economically Significant Amount of Silver and Other Precious Metals (40 CFR 266.70): Generators must maintain manifests when material is being transported for reclamation. Persons who store these materials (nonspeculatively) must keep records showing the volume of these materials stored at the beginning of the calendar year; the amount generated or received during the calendar year; and the amount of materials remaining at the end of the calendar year. No specified retention period for the documents. ! Used Oil Generators (40 CFR 279.74) Generators of used oil are to keep a record of each used oil shipment that is accepted for processing/re-refining and shipped to a used oil burner, processor/re-refiner, or disposal facility. These records may take the form of a log, invoice, manifest, bill of lading, or other shipping documents. Records are to be retained for 3 years. ! Underground Storage Tanks (UST's) (40 CFR 280 & 281) Owners and operators of new and existing USTs are to maintain records that demonstrate compliance with performance standards (monitoring, testing, protection, repairs, and closure). These records are to be maintained for the life of the tank and piping system. Hazardous Waste Generator Status:

Conditionally Exempt SQG

Small Quantity Generator

Large Quantity Generator

less than 220 lbs/month

221-2205 lbs/month

2205 lbs/month or greater

If no specific records retention time is established, records should be retained for at least five years.

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For additional information about pollution prevention opportunities in the printing industry call the PNEAC toll free number at 1-888-USPNEAC or contact : Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig(412/741-6860 Printing Industries of America - Ben Cooper (703/519-8115) Illinois Hazardous Waste Research and Information Center - Gary Miller (217/333-8940) or Debra Jacobson (630/472-5019) University of Wisconsin - Wayne Pferdehirt (608/265-2361) or Keith West (920/465-2940) or Bob Gifford (608/262-1083) Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/or local regulatory agencies.

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Printers’ National Environmental Assistance Center

Printing Environmental Compliance Fact Sheet

PNEACwww.pneac.org

1-888-USPNEAC

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Understanding Air Pollution Permits Printers, both large and small, need to be aware of the revisions to air pollution permitting requirements that are being imposed across the country. In the quest for continuing air pollution emission reductions, an increasing number of printers and other businesses are now subject to Environmental Protection Agency (EPA) and state/local air pollution control permits because of their volatile organic compound (VOC) and to a lesser degree, hazardous air pollutant (HAP) emissions. The purpose of this fact sheet is to review the current status of air permitting that printers of all sizes could possibly be required to meet. VOC emissions are tightly controlled because they lead to the formation of ozone in the lower atmosphere. Ozone is a reactive form of oxygen and is a component of smog. EPA has established acceptable levels of ozone that can be present in the lower atmosphere. Areas exceeding the specific ozone level are classified as not in attainment with the standard. Non-attainment areas are further classified as to the severity of the ozone problem and can be marginal, moderate, serious, severe, or extreme. Congress, through the 1990 Clean Air Act Amendments, has established detailed requirements for states with nonattainment areas to implement in order to clean up the air allowing them to meet the ozone standard. The Act also details those measures that states with attainment areas need to implement in order to maintain the their clean air status. These requirements include a new federal operating permit program under Title V of the act, specific VOC emission reduction measures, and timelines for completion. The release of toxic chemicals into the air has received considerable attention by both environmental and community groups who want to know specifically how much of a specific toxic chemical they are being exposed to and the types of adverse health effects this exposure can cause. The 1990 Clean Air Act Amendments has identified 188 Hazardous Air Pollutants (HAPs) that are of a particular concern. Congress has directed EPA to establish an operating permit program for businesses that emit HAPs above certain thresholds and to require these businesses to reduce those emissions through very stringent control requirements called Maximum Available Control Technology (MACT). A MACT standard has been established for the printing industry and focuses on emissions from flexographic and rotogravure operations. Air pollution control requirements are divided into two separate, but related requirements. The first involves permit requirements and the second is the imposition of specific control requirements. It is important to understand that there are thresholds associated with each of these separate requirements and the need to obtain a permit does not necessarily mean that a printer will have control requirements imposed on its facility. Permits serve several roles. They provide an inventory of air pollution sources. States and local agencies use these inventories in their planning process for either the further reduction of air pollution or maintenance of current air quality. The permit also serves as the legal document that incorporates any applicable control requirements designed to reduce the emissions of certain pollutants. The last important function of permits is that they provide a facility with the legal basis for operation. Permits should be viewed as a “contract” or agreement between the printer and the permitting authority. This contract is legally binding and will contain terms and conditions that must be met by the printer. Failure to meet these terms and conditions can subject the printer to an enforcement action.

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Types of Permits Permits can be issued in several different formats ranging from the simple one-page variety to the very complex. Some state and local agencies require a permit-to-construct before any new facility can be built or, more importantly, before a new piece of equipment like a printing press can be installed. Technically, a printer is not allowed to accept delivery of a new piece of equipment or even begin any work to modify a piece of equipment without having a valid construction permit. In fact, any “pre-construction activity” such as moving existing equipment to make room for new equipment, pouring of concrete, or making arrangement for utility connections is prohibited until a construction permit is obtained. The state/local agencies with a permit-to-construct program will also generally require a permit-to-operate as well. In some cases, the construction permit can also serve as the operating permit. It is also important to know that other state/local agencies without a permit-to-construct program can have a permit-to-operate program. It is imperative that the printer learns and understands the specific permitting requirements applicable to their operation. Permits-to-operate look very similar to permits-to-construct and will contain all applicable and enforceable operating conditions and control requirements. They may also contain recordkeeping and reporting requirements. Operating permits will have a specified period of effectiveness. Some permits require an annual renewal, but more permits are now being written with a five-year term. Besides the construction/operating permit systems described above, some state/local permitting authorities have a “registration permit” system for those businesses or individual pieces of equipment that do not emit a large amount of air pollution. Typically, these types of “permits” are less complex and do not require the facility to provide a significant amount of detail in the application forms. For example, the state of Ohio has a registration permit program for sheetfed offset lithographic presses that emit less than 3 tons per year of VOCs. As long as the press’s emissions stay below this level, an operating permit is not required. However, an application for registration needs to be submitted in order to demonstrate compliance. Because of the 1990 Clean Air Act Amendments, another type of operating permit was created called a Title V operating permit. These permits have a five-year term limit and are federally enforceable. They specify all control requirements, emission limits, recordkeeping, compliance reporting, compliance certification, and monitoring requirements. Title V permits only apply to certain types of facilities and are administered by the state/local agencies, but reviewed and approved by USEPA. A federally enforceable permit is one that can be enforced by EPA. As a result of the Title V operating permit program, a new type of operating permit called a Federally Enforceable State Operating Permit (FESOP). FESOP permits only apply to certain types of printing operations, but as the name implies, they are state/local agency issued permits that can be enforced by EPA. Generally, the types of permits that most printers have to obtain are issued by the state/local are not federally enforceable. Title V and FESOP permits are unlike any permitting program that has been in place in the past. They require a detailed analysis of a facility’s emission sources and must address the future utilization of the equipment and materials. Completing the permit application cannot be simply delegated to the “engineering” department because it requires input from the operating, sales and marketing, and administration. Current and future strategic business decisions have to be made within the context of the Title V permitting process. Modifications and changes to the permit will be difficult and time consuming to accomplish and the printer could loose a business opportunity as a result. The need to obtain an air pollution control permit depends on the applicable thresholds that have been set by the state/local air pollution control agency. The thresholds can be based on several different parameters. Some state/local agencies use the actual emission rate or amount while others use potential emissions. Some permitting authorities do not use an emission-based threshold, but use an actual material consumption rate basis to determine if permits are required.

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Permitting Thresholds Permitting thresholds can vary quite dramatically and are driven by federal, state, and local requirements. The permitting thresholds can be for either an individual piece of equipment (e.g., press) or the entire facility (e.g., presses, coaters, bindery, and prepress). They can be expressed in pounds per hour, pounds per day, pounds per month, tons per year, or based on some type of material consumption limit. For example, in New York City, all printers regardless of their emission rate are required to have a permit. In the remainder of New York State, any printer with total VOC actual emissions less than 12.5 tons per year must obtain a registration permit. Those with actual emissions greater than 12.5 and less than 25 tons per year must obtain a state facility permit and those with potential emissions greater than either 25 or 50 tons per year must obtain a Title V permit. The Illinois EPA requires a permit for any printer that uses more than 750 gallons per year of VOCs, while Pennsylvania has both an actual and potential emission permit thresholds. The threshold for the new federal Title V operating permit uses a facility’s annual potential emissions (e.g., potential to emit) to determine applicability and applies to both VOC and hazardous air pollutant (HAP) emissions. The HAP threshold for permitting is 10 tons per year for a single HAP chemical and 25 tons per year for all HAP single chemical(s) or HAP categories combined. These thresholds are universal in that they apply across the entire country and are not tied to any attainment or nonattainment classification. The Title V thresholds for VOC emissions are dependent upon the geographical location and severity of the non-attainment problem. The only extreme area is Los Angeles, CA and the threshold is 10 tons per year. Severe areas like Chicago, IL, Philadelphia, Pa, and New York City area have thresholds of 25 tons per year. Serious areas like Atlanta, GA and the entire ozone transport region have thresholds of 50 tons per year. The ozone transport region includes the entire area bound by Pennsylvania, Maryland, District of Columbia, Delaware, New York, New Jersey, Connecticut, Massachusetts, New Hampshire, Vermont, Rhode Island, and Maine. Moderate and Marginal areas such as St. Louis, MO have thresholds of 100 tons per year. The new nonattainment classification system can extend to several counties that physically touch the nonattainment area. FESOP permits can be called by different names, but as the name implies, they are federally enforceable operating permits. Printing operations whose potential emissions exceed the Title V permit threshold with actual emissions below the threshold can qualify for a FESOP permit. Among the other applicable control requirements, FESOP permits will contain additional limits on hours of operation, input material consumption rates, or emissions that will ensure that the facility will not emit pollution at rates greater than the major source threshold. FESOP permits are generally not as rigorous as Title V permits and do not have the same fee structure associated with them.

Potential to emit Potential to emit (PTE) is defined as the greatest amount of emissions that could be released from a piece of equipment or facility based on its maximum design capacity or maximum production. Potential to emit determinations must assume the equipment will run 24 hours/day 365 days/year or 8,760 hours/year. The only way to avoid these assumptions is to have federally enforceable limits imposed on an operation that either limit the hours of operation, material input rate, or require the use of an add-on control device such as an oxidizer. There exists considerable controversy in how PTE is to be calculated, and how it applies to printers. Because printers produce a variety of products with various coverages, the amount of ink, fountain solution, coating, and other materials applied change the job and are difficult to characterize in PTE calculations. There are at least three different ways to calculate potential emissions from a printing press. The first method is a worst case. It assumes 100% application of all input materials such as inks, coatings, fountain solutions, and cleaning solvents on all cylinders at maximum press speed for 8,760 hours/year. In a study performed on a printer using water-based flexography and letterpress to manufacturer corrugated boxes, their 5 tons per year actual emissions climbed to 4,000 tons by assuming the worst case scenario. While this method is not realistic, some state

PNEAC Fact Sheet: Understanding Air Pollution Permits, p. 4 of 6

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agencies insist that printers use this method. The second method, which is preferred by industry, takes the actual average annual hourly emission rate and multiplies it by 8,760 hours/year. In the same study performed on the corrugated manufacturer, the potential emissions using this approach would be 20 tons/year. The third method further confuses the permitting threshold determination. Some states including Illinois and Wisconsin, use a maximum theoretical emission (MTE) rate for rule applicability. The concept of MTE is the same as PTE in that it requires that a printer assume equipment is running at its maximum design capacity or maximum production rate for 24 hours/day 365 days/year or 8,760 hours/year. It does not allow for any reduction in emissions due to limits on the hours of operation, material input rate, or use of an add-on control device such as an oxidizer. Because of the way PTE is applied, it has affected many small printers with extremely low actual emissions. Simply because their potential emissions made them "major sources," they are subject to more stringent regulation. EPA has recognized that small businesses that are not physically capable of emitting the "potential" described in the regulations should not be subjected to the requirements being imposed on the much larger major sources. These small businesses possess neither the technical nor financial resources to respond to these requirements.

EPA PTE Guidance On April 14, 1998, the Environmental Protection Agency released its Potential To Emit (PTE) Guidance for Specific Source Categories. The guidance was issued for state and local air pollution control agencies to use in setting rules to exempt small sources of air pollution from being subject to full regulation. It can be downloaded from http://www.epa.gov/ttnsbap1/access.html. As described above, the current air pollution control regulations could cause individual printing operations to be considered "major sources" of air pollution and required to obtain a Title V operating permit based on their potential, not actual, air pollution emissions. The new Potential To Emit (PTE) Guidance for Specific Source Categories will allow state and local air pollution agencies to exempt individual small businesses from being considered "major sources". The EPA PTE guidance document will allow state and local air pollution control agencies to establishing rules exempting small sources of VOC and HAP emissions from being considered "major" sources. Printers qualifying under the guidance would not be subject to a Title V or Federally Enforceable State Operating Permit and all of the control requirements that are applied to these types of operations. The guidance utilizes a "cap" approach. If a source can demonstrate through records that actual emissions are less than 50 percent of the major source threshold for their given area, the source will be treated as a minor source. To further simplify determinations for small printers, a quick reference threshold chart was created with consumption levels for those materials that account for the largest source of VOC or HAP emissions in a printing operation. Indicators were established for each printing process type (see chart below). For example, a sheetfed offset lithographic printer typically has two principal sources of VOC emissions or environmental indicators-cleaning solvents and fountain solution additives, namely isopropyl alcohol. If the printing establishment is located in Pittsburgh, a marginal ozone non-attainment area, it could use 14,275 gallons of cleaning solvent and fountain solution additives combined before it would be considered a major source. Even if printers exceed the levels listed in the table, they can still take advantage of this guidance if their total actual emissions do not exceed more than 50 percent of the major source threshold definition. A technical support document to the guidance has been prepared by EPA and contains the formulas to be used in calculating emissions. Furthermore, the environmental indicators identified have to account for 90 percent or more of the emissions released from the facility. If other activities-ink jetting, for instance-contribute more than 10 percent of the emissions, then the table provided in the EPA guidance cannot be used and printers must calculate their actual emissions to determine if they qualify under the guidance.

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Some printing operations will not qualify under the new guidance, including printers with actual emissions greater than 50 percent of the major source threshold and those using add-on control devices such as after-burners or oxidizers. Because of the complexities associated with control devices, printers utilizing control devices were excluded from the new guidance, even though their actual emissions could be below 50 percent of the major source threshold. To help these printers, EPA has been petitioned to accept an approach that better approximates a printer's ability to run at maximum conditions. For these printers, a more realistic approach to determining PTE would be to take the actual average hourly emission rate and multiply it by 8,760 hours per year. This approach provides a better approximation of printers' ability to run at maximum production capacities by extrapolating the current actual emissions into potential emissions that better reflect a realistic increase in production. This approach assumes printers would continue to produce the same mix of jobs, but they would be produced every hour in the year. Even though printers cannot physically run a press 8,760 hours per year, this takes into account any variations due to ink coverages and increases in productivity. Printers can readily determine actual average emissions based on material balances and hours of operation from production data. The EPA's current approach requires printers to make assumptions about material use and equipment utilization that are open to challenge by the agency.

VOC and HAP Emission Calculations Besides finding the appropriate threshold to determine whether a permit is required, the printer must also determine their VOC/HAP emission levels. This is accomplished by first deriving material use information. The materials to consider include, but are not limited to inks, extenders, diluents, fountain solutions, fountain solution additives, coatings, cleaning solutions, and other miscellaneous chemicals. Material use is typically defined as the amount purchased minus the change in inventory, minus the amount discarded. The amount released is determined by multiplying the amount used by the VOC content and if appropriate, an emission factor. An emission factor is the number used to reflect the actual release of materials. For example, a 5% emission factor for VOCs is applied to all sheetfed offset lithographic inks. Studies conducted by the printing industry have shown that 95% of VOCs in lithographic inks are retained by the substrate. For more information see the other PNEAC fact sheet(s) on determining VOC and HAP emissions from the appropriate printing process.

Summary Every printer, whether operating a large or small facility, must know and understand the air pollution permit regulations applicable to their facility. Knowing and complying with these regulations are crucial for printers because it allows them to legally operate their businesses under the current regulatory requirements. Even if a printer is not legally required to have a permit in order to operate their business, it is equally important to know and have proven and documented that they are not subject to the regulation. This aspect of the printer’s business needs to be actively managed just like other important aspects of the business. In the long run, an active approach benefits the printer rather than the alternative of ignoring regulations, where it will ultimately becomes an enforcement action and a business liability.

PNEAC Fact Sheet: Understanding Air Pollution Permits, p. 6 of 6

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For additional information about pollution prevention opportunities in the printing industry call the PNEAC toll free number at 1-888-USPNEAC or contact : • Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig(412/741-6860 • Printing Industries of America - Ben Cooper (703/519-8115) • Illinois Hazardous Waste Research and Information Center - Gary Miller (217/333-8940) or Debra Jacobson

(630/472-5019) • University of Wisconsin - Wayne Pferdehirt (608/265-2361) or Keith West (920/465-2940) or Bob Gifford

(608/262-1083 Reasonable effort has been made to review and verify information in this document. Neither PNEAC and its partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or its interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/or local regulatory agencies.

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POLLUTION PREVENTION PROGRAMNORTH CAROLINA DEPARTMENT OF ENVIRONMENT,

HEALTH, AND NATURAL RESOURCES

SILVER RECOVERY SYSTEMS AND WASTE REDUCTION IN PHOTOPROCESSING

There are several reasons to be interested in the recovery of silver from photoprocessing waste. Silveris a valuable natural resource of finite supply, it has monetary value as a recovered commodity, andit's release into the environment is strictly regulated. In photoprocessing, silver compounds are thebasic light-sensitive material used in most of today's photographic films and papers. Duringprocessing, particularly in the fixing bath or bleach-fix, silver is removed from the film or paper andis carried out in the solution, usually in the form of a silver thiosulfate complex.

Major sources of recoverable silver are: photoprocessing solutions, spent rinse water, scrap film, andscrap printing paper. As much as 80 percent of the total silver processed for black and whitepositives and almost 100 percent of the silver processed in color work will end up in the fixersolution. Silver is also present in the rinse water following the fixer or bleach-fix due to carry-over.

Economic considerations include initial equipment cost, the amount and value of silver recovered, andthe return on investment. Space and energy requirements, day-to-day attention required,maintenance, and reliability are also important. It is necessary to know the amount of silver availablefor recovery, the total volume of fixer and bleach-fix solutions used in processing, and the expectedperformance of the recovery method under consideration.

Several technologies exist for recovering silver onsite. The most common methods of onsite recoveryfrom the fixer and bleach-fix processing solutions involve metallic replacement, electrolytic recoveryand chemical precipitation. Ion exchange and reverse osmosis are other methods that can be usedalone or in combination with conventional silver recovery systems. However, these are generallyconsidered suitable only for dilute solutions of silver. A silver recovery system can be devoted to asingle process line or can be used to remove silver from the combined fixer from several process linesin a plant.

The most widely used silver recovery method for large operations is electrolysis, where the silver isrecovered from solution by electroplating it on a cathode, Fig. 1. A controlled, direct electricalcurrent is passed between two electrodes suspended in the silver-bearing solution. Silver is depositedon the cathode in the form of nearly pure silver plate. The cathodes are removed periodically, and thesilver is stripped off for sale or reuse. While this method requires a substantially larger capitalexpenditure and needs an electrical connection it does have the advantage over other methods in thatit yields virtually pure silver. This results in lower refining and shipping costs and it does notcontaminate the fixer, thereby permitting its reuse for some processes. When properly operated, 95percent of the potential available silver can be recovered. Combining electrolytic silver recovery within-situ ion exchange can result in more than 99.5 percent silver recovery efficiency.

A recirculating electrolytic recovery system has advantages over systems that only remove silver.Silver is removed from fixer solution by the recovery cell which is connected "in line" as part of a

N. Carolina DEHNR Fact Sheet: Silver Recovery Systems and Waste Reduction in Photoprocessing, p. 2 / 5

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Figure 1. Diagram of an electrolytic silverrecovery cell.

Figure 2. Diagram of a metallic replacementsilver recovery cartridge

recirculation system. Fixer solution reclaimed by electrolytic silver recovery can have limited reusein the photoprocess. By recirculating the desilvered fixer to the in-use process tank, less fresh fixersolution is needed to replenish the bath. Fixer replenishment can be reduced 20 percent or morewithout degradation of product quality. Chemical replenishment can be managed through the frequentand consistent use of test strips. A properly designed recirculating system can lower the silver in thefixer from a concentration of 1 ounce/gal. to 1 ounce/100 gals. The amount of silver carried over tothe rinse water is similarly reduced.

Metallic replacement requires little capital expenditure for equipment and requires only a few simpleplumbing connections. The equipment consists of a plastic container, a plastic-lined steel or stainlesssteel drum filled with metal, usually steel wool, and some plastic hose and plumbing connections.See Fig. 2. Silver is recovered when the silver-bearing solution flows through the cartridge andmakes contact with the steel wool. The iron goes into solution as an ion, and the metallic silver isreleased as a solid to collect in a sludge at the bottom of the cartridge or is deposited on the steelwool. The yield a user can expect is determined by the silver concentrations in solution, the volumeof solution that is run through the cartridge, and the care with which the operation is managed. Whensilver is no longer effectively removed, the silver-bearing sludge is sent to a refiner who will refine

it and pay the customer for the recovered silver.

The disadvantages of these two methods are that neither can recover more than 95 percent of thesilver from concentrated solutions, effectively treat dilute wastewater, nor remove other metals fromthe effluent.

Another option is chemical precipitation with sodium sulfide, sodium borohydride or sodiumdithionite. This can remove virtually 100 percent of the silver and most other metals fromphotographic effluent. With the addition of alkaline sodium sulfide and the resulting precipitation of

N. Carolina DEHNR Fact Sheet: Silver Recovery Systems and Waste Reduction in Photoprocessing, p. 3 / 5

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Figure 3 Ion Exchange system.

silver sulfide, levels of soluble silver below 0.1 mg/L are possible. However, the more difficult partof the process is the separation of the precipitate from the liquid. Total silver levels of 0.5 to 1.0mg/L are usually obtained due to filtration limitations. This process requires only a small capitalexpenditure and uses chemicals which are relatively inexpensive. It is not as widely used as theelectrolytic or metallic replacement methods because of the inconvenience of handling large amountsof chemicals, the separation process required, and the problem of concentrating finely precipitatedsilver sulfide particles into a sludge that can be dried and refined. Also, careful pH control is requiredto avoid generation of highly toxic hydrogen sulfide gas.

Ion exchange is generally used for effective recovery of silver from rinse water or other dilutesolutions of silver. The ion exchange method involves the exchange of ions in the solution with ions

of a similar charge on the resin. The soluble silverthiosulfate complex is exchanged with the anion onthe resin. This exhaustion step and is accomplishedby running the solution through a column containingthe resin, Fig. 3. For large operations, the next stepis the regeneration step in which the silver is removedfrom the resin column with a silver complexing agentsuch as anmnonium thiosulfate. This step includesseveral backwashes to remove particulate matter andexcess regenerant before the next exhaustion step isinitiated. Silver is then recovered from the thiosulfateregenerant with an electrolytic recovery cell. Forsmaller operations an alternative to performing the

regeneration step onsite would be to remove the resin from the column and send it to a refiner forsilver reclamation. Important factors in considering an ion exchange system for silver recovery are;selection of the resin, flow rate of the silver-bearing solution, column configuration, and selection ofthe regenerant. It has been demonstrated that the use of ion exchange can reduce the silverconcentration in photographic effluent to levels in the range of 0.5 to 2 mg/L and can recover over98 percent of the available silver. If this method is used as a tailing method after primary recoveryby electrolysis, levels in the range of 0.1 to 1 mg/L can be obtained.

Reverse osmosis (RO) is also used for dilute solutions. RO uses high pressure to force thesilver-bearing solution through a semipermeable membrane to separate larger molecules, such as saltsand organics, from smaller molecules like water. The extent of separation is determined by membranesurface chemistry and pore size, fluid pressure, and wastewater characteristics. For removal ofsilver, after-fix rinse water is flow-equalized, filtered, and pumped through an RO unit. Once thesilver is separated from the water in this manner it can be recovered by conventional means such asmetallic replacement, electrolytic recovery or chemical precipitation. Operating problems includefouling of the membrane and biological growth.

Evaporation is another option for managing waste photographic solutions. The wastewaters arecollected and heated to evaporate all liquids. The resulting sludge is collected in filter bags. Thesebags can be sent to a silver reclaimer for recovery. The major advantage of the evaporation techniqueis it achieves "zero" water discharge. This method would be useful to operations that do not have

N. Carolina DEHNR Fact Sheet: Silver Recovery Systems and Waste Reduction in Photoprocessing, p. 4 / 5

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access to sewer connections or wastewater discharge. A disadvantage is that the organics andammonia in the waste solution may also be evaporated, creating an air pollution problem. A charcoalair filter may be necessary to capture the organics. Filter purchase, disposal, and electrical power addto operating costs.

An alternative to onsite recovery is to collect the bleach/fix in containers and have a silver recoverycontractor haul it away to reclaim the silver. For this service the photolab may be paid only about 20percent of the silver value. This low percentage may be partially offset by its high silver recoveryyield. Off site recovery can be done on a larger, more efficient scale than onsite recovery. The smallquantity generator or the generator who desires a minimum commitment may find advantages in offsite services.

Silver can be recovered from scrap film and paper by soaking the material in spent fixer solution.Once dissolved in the fixer, the silver can be recovered through any of the silver recovery processesused by the lab. There are also businesses which will buy scrap photographic film and paper from thephotoprocessor.

There are additional actions that should be considered by photolabs to minimize waste.• Inventory of chemicals should be controlled so that they are used before their expiration date.• Solutions should be made up only in quantities to meet realistic processing volumes .• Floating lids should be used on developer solution tanks to prevent evaporation and loss of

potency.• Silver recovery unit operating conditions should be carefully monitored and maintained within

vendor specifications.• Spent rinse water can be treated to restore purity and recycled for rinsing.• The use of squeegees can reduce considerably the amount of liquid carried out of the solution by

the film.• Common sense safeguards such as keeping the mixing area clean, avoiding mixing of dry

chemicals where airborne particles can cause contamination of other solutions, and use ofseparate mixing tanks for developers will minimize contamination or errors in mixing.

• Counter-current rinsing can be used to reduce water consumption. The basic concept ofcounter-current rinsing is to use the water from previous rinsings to contact the film at its mostcontaminated stage. Fresh water enters the process only at the final rinse stage.

• Bleach, bleach-fix, fix, and developer can be recycled and reused.

For information on vendors and purchasers of recovered silver contact:Office of Waste Prevention Pollution Reduction ProgramN. C. Department of Environment, Health & Natural ResourcesPost Office Box 27687 Raleigh, NC 27611-7687919-571-4100

N. Carolina DEHNR Fact Sheet: Silver Recovery Systems and Waste Reduction in Photoprocessing, p. 5 / 5

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REFERENCES

1. Eastman Kodak Company “Disposal and Treatment of Photographic Processing Solutions In Support of Clean Water,” 1982.

2. Arthur D. Little, Inc., “Waste Audit - Photoprocessing Industry” prepared for AlternativeTechnology Section, Toxic Substances Control Division, California Department of HealthServices, April 1989.

3. Thomas P. Cribbs and Thomas J. Dagon, Eastman Kokak Company, "A Review of WasteReduction Programs in the Photoprocessing Industry."

4. Monica E. Campbell and William M. Glenn, The Pollution Probe Foundation,"Profit from Pollution Prevention," 1982.

Date: May, 1992

For more detailed information about pollution prevention opportunities in the printing industryvisit the PNEAC web site at www.pneac.org, call the PNEAC toll free number at1-888-USPNEAC, or contact :

• Graphic Arts Technical Foundation - Gary Jones or Rick Hartwig (412/741-6860)• Printing Industries of America - Ben Cooper (703/519-8115)• Illinois Waste Management and Research Center - Gary Miller (217/333-8940) or Debra

Jacobson (630/472-5019)• University of Wisconsin - Wayne Pferdehirt (608/265-2361), Keith West (920/465-2940)

or Bob Gifford (608/262-1083)

Reasonable effort has been made to review and verify information in this document. Neither PNEAC and itspartners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of theinformation, or its interpretation. The reader is responsible for making the appropriate decisions with respect totheir operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperativeto verify current applicable regulatory requirements with state and/or local regulatory agencies.

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Environmental Compliance Checklist for Printers Prepared by Gary Jones, Graphic Arts Technical Foundation (GATF) Revised 4/18/1996 This information is reprinted with permission from "Regulatory Concerns for the Printer: A Checklist," produced by the Graphic Arts Technical Foundation (GATF), copyright 1996. A. Air

q Annually prepare detailed facility wide omissions inventory which includes emissions of Volatile Organic Compounds (VOCs), Hazardous Air Pollutants (HAPs) Nitrogen Oxides (NOx), Sulfur Oxides (SOx) , Carbon Monoxide (CO) and Particulate Matter (e.g., paper dust or uncontrolled ink oil emissions). Emissions should be determined for both actual and potential emissions. Sources of emissions include film and plate processors, some proofing systems, printing presses, bindery lines, cyclones, bailers, boilers, dryers, furnaces, and other fuel combustion equipment. Emission determinations can be based on either test data or mass balance incorporating appropriate engineering estimates and emission factors.

q Determine thresholds for registration construction/installation and operating permits for testing

operations which could be equipment specific (e.g., press, control device, or boiler) or facility-wide. Many state/local permitting programs are now focusing on facility permits and not per equipment permits. The thresholds for registration and permits depend upon the current attainment/nonattainment classification of the area, specific regulations being enforced by the appropriate government agency, and the amount or rate of air pollutants being emitted. Contact state/local agency to obtain a copy of permit and air pollution control requirements;

q Obtain appropriate permit(s) for existing operation. Keep copies of all permit application

packages and omission determinations. q Determine permit thresholds for installation of new equipment to existing operations. New

equipment could include presses, coaters, omission control devices, boilers, cyclones, evaporators, distillation units, and some proofing and bindery equipment. The thresholds for new equipment and processes depend upon the current attainment/nonattainment classification of the area, specific regulations are enforced by the appropriate government agency, and the amount/rate of air pollutants being emitted. Contact state/local agency to obtain a copy of permit and air pollution control requirements.

q Obtain appropriate permit(s) for existing operation. Keep copies of all permit application

packages and emission determinations. q Determine thresholds for modifications to existing equipment that would require a permit

amendment. Modifications to existing equipment includes changes in materials used (e.g., inks, dampening solutions, coatings, cleaning solvents, and other chemistries), increase in operating speeds, or material application rates. Keep copies of all correspondence and subsequent permit amendments. Modifications do not need to lead to an increase in omissions especially if an existing permit dictates the use of specific equipment, throughput rates, materials or chemicals. All emission increases need to be closely examined.

q Determine thresholds for exemption. Some equipment/facilities may be exempt from registration

and permit requirements. Exemption level is dependent upon attainment/nonattainment classification of area, date of installation, and rate/amount of emissions. All exemption determinations need to be documented.

q Establish a system to track all permits and ensure that permit renewals are filed in a timely

manner.

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q Document all actions taken to reduce or eliminate emissions. Changing process materials (e.g., use of isopropanol substitutes) or shutting down equipment could generate reductions. Typically, all creditable emission reductions must have occurred after 1990. Some states have specific forms to file for emission reduction credits. These credits can be used internally to net emission increases or sold to another company requiring offsets for emission increases.

q Establish appropriate recordkeeping and monitoring system. The system should be designed to

allow for the demonstration of compliance with permit conditions and detection of potential violations. Permit conditions or regulations may require records of materials use, hours of operation, pollution control logs, temperatures of combustion or fountain solution, routine tests, etc. Depending upon the specific permit condition, it may be appropriate to periodically sample and test incoming materials, emissions, and control devices.

q File semi-annual emission reports and annual certification. Some permits, especially Title V,

require facilities to submit reports and certification of compliance. q File annual emission statements. Emission statements can be required of sources/facilities even if

they are exempt from permitting. Thresholds for omission statements vary according to specific state/local agency and attainment/nonattainment classification. Some states require emission statements from facilities with emissions greater than 3 tons per year. Many states require them from facilities with emissions greater than 10 tons per year.

q If necessary, develop and implement (when required) an emission reduction plan. Emission

reduction plans typically address omissions of VOCs and NOx during excessive day(s) of ozone formation. Depending upon severity of ozone formation, actions taken could be minor (e.g., delaying certain non -critical operations, car pooling, keeping chemical containers closed) or major which would involve production curtailment.

q Keep records of any telephone conversation, correspondence, testing, and calculations; and send

all correspondence to any agency by return registered mail.

B. Water Discharges q Inventory all sources of wastewater discharges. q Determine fate of all sink drains, floor drains, processor and equipment drains and sewage lines.

Direct discharges of wastewater are prohibited, unless permitted (see NPDES requirements below).

q Maintain copies of sewer connect permit or notification and other correspondence. q Annually determine the total wastewater flow in gallons. The amount resulting from industrial

water use should be either measured or estimated. Sources of information for estimating total flow include records indicating the volume of water purchased, other water purchased with process chemistry like water-based coatings, water-based inks, film and fountain solution concentrates, and any water pumped from wells. If necessary, gallons per month and day may also have to be determined.

q Contact local publicly owned treatment works (POTW or sewer authority for permission to

discharge process wastewater effluent and for permitting requirements and obtain a copy of the sewer code.

q Most POTWs require silver recovery and may have specific limitations for certain chemicals,

heavy metals, and physical characteristics (e.g., Copper, Ammonia, pH, COD, and BOD) contained in wastewater effluent. Contact POTW to determine specific limits.

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q Establish a system to track all permits and ensure that permit renewals are filed in a timely manner.

q Some states/local POTWs require employees who operate and maintain any pretreatment

equipment to be trained and certified as wastewater treatment operator. Contact local POTW/state agency to determine requirements.

q Conduct testing of wastewater discharges. Permits and/or sewer code may require periodic

discharge testing and monitoring reports of effluents. Contact local POTW to determine requirements.

q When conducting wastewater sampling, especially during compliance determination testing, take

a sample of incoming water to use as baseline. The preferred sampling protocol is a multiple-hour (ideally, 24-hour) composite sample versus a grab sample.

q Establish policies and procedures to prevent inadvertent release of prohibited materials. EPA ban

on discharging of oil/grease, materials that could create a fire or explosion, and chemicals that could produce toxic vapors and fumes. Many POTWs allow a small amount of oil/grease discharge, usually in the 50- to 100-ppm range. Some ignitable, especially those that contain less than 25% alcohol, could also be exempt from the discharge ban.

q Permanently block all open floor drains in the facility or if floor drain is necessary, provide drain

covers. In case of a spill, open floor drains provide a means to allow spilled chemicals to be discharged directly to the POTW and depending upon the material spilled, in a concentrated form. Alternately, a raised pipe or other device could be provided to prevent spilled chemicals from being released through the open floor drain. The alternate approach cannot present a tripping hazard.

q Provide secondary containment for all processors or equipment using chemistry to help contain

spills and prevent than from spreading. The secondary containment should be capable of holding at feast 110% of the volume of the contents of a single chemical container or processor. If mom than one container or processor is included in the containment area then the secondary containment must be capable of holding 150% of the volume of the largest primary container or 10% of the aggregate volume of all primary containers, whichever is greater.

q Assemble and locate appropriate spill response and neutralization materials in prepress area.

Materials include a wide variety of absorbents, two or three mops, mop bucket with wringer, several squeegees, several push brooms, traffic tape, spill sign, small shovel, clean container with lid for receiving spilled materials and contaminated cleanup material, weak acids (for developer), alkali material (for fix), containers, and personal protective equipment, (e.g., rubber gloves, goggles, aprons, shoe covers, and general purpose respirators).

q Discharges of more than 33lbs/month of hazardous waste, especially listed ones, or any acute

wastes mixed with domestic sewage requires written notification to local EPA office, state waste agency, and POTW.

q Significant dischargers (those discharging more than 25,000 gallons/day) and occasionally

smaller dischargers may be required to submit biannual effluent testing data and develop plans to respond to accidental spills and discharges. Contact local POTW to determine requirements.

q File annual industrial wastewater discharge survey. Some local POTWs require annual reporting

of industrial effluents. Some surveys can be extensive.

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q Install and maintain backflow prevention system. Some water authorities require backflow

prevention devices on each piece of process equipment connected to incoming water supply. Some water authorities require annual testing and registration of all backflow preventers.

National Pollutant Discharge Elimination System (NPDES) permit

q Obtain permit for discharges of industrial and sanitary wastewater effluent, non-contact cooling

water, and boiler blowdown water to navigable waterways (e.g., streams, creeks, lakes, rivers, etc.).

q Obtain NPDES stormwater discharge permit for any rain or snowmelt runoff exposed to

industrial activity (e.g., contaminated with chemicals) and discharged to navigable waterways. NPDES permits can be either group, individual, or general. Printers constructing shelters over sources of contamination (e.g., dumpsters) or bringing materials inside can exempt themselves from this regulation.

q If stormwater discharge permit is required, determine pollutant monitoring, sampling and testing

requirements. Keep copies of all testing results. q If a stormwater discharge permit is required, develop and implement pollution prevention plan

designed to minimize or eliminate sources of pollution. q Contaminated stormwater discharges to municipal systems require notification to the

municipality. Printers constructing shelters over sources of contamination (e.g., dumpsters) or bringing materials inside can exempt themselves from this regulation.

q Establish tracking system to ensure permit renewals are filed in a timely manner.

Septic system:

q Ensure that all septic systems are installed in accordance with state/local requirements. Permits for installation may be necessary.

q Conduct annual inspection of septic system to ensure it is operating properly. Same state/local

agencies require annual inspections by qualified engineers. q Prohibit discharges of industrial wastewater effluent into septic system. In some instances, states

will allow discharges of certain industrial wastes into septic systems, but dischargers will typically be required to obtain a NPDES permit.

q If a septic system had been previously used and/or removed, keep copies of all sampling and test

results indicating contamination with industrial effluents. If remediation actions were taken, copies of all pertinent records and test results must be maintained.

Drinking water:

q Make sure that lead-free solder for pipes and drinking water fountains are used.

q Use lead-free drinking fountains that have not been cited/recalled for lead-lined cooling tanks.

q Water being supplied from wells for drinking may have to be periodically tested for presence of contaminants. This testing is usually mandatory for plants with more than 25 employees.

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C. Hazardous Waste q Determine if hazardous waste is generated. A waste is any material that has been abandoned or

discarded that iii unsuitable for use without treatment or recycling. The U.S. Environmental Protection Agency (USEPA) has established a protocol of using process knowledge, chemical identification, or testing (flashpoint, pH, Toxicity Characteristic Leaching Procedure, etc.) to determine classification of wastes. USEPA also provides for many exceptions, while some state agencies do not observe the same exemptions. For example, in some states, silver-laden fixer must be counted as a hazardous waste, while USEPA exempts it. In addition, some states regulate other materials like used oil as hazardous wastes. Please check with your state agency to see if they regulate materials USEPA does not.

1. Ignitable Wastes

q A liquid that has a flashpoint below 60C or 140F. Aqueous solutions containing less than 24% alcohol by volume are not included in this definition.

q A non-liquid capable of spontaneous and sustained combustion under normal conditions. q An ignitable compressed gas as defined by DOT. q An oxidizer as defined by DOT.

2. Corrosive Wastes

q An aqueous material with a pH less than 2.0 or greater than 12.5. q A liquid that corrodes steel at a rate greater than one-forth inch per year at a temperature of

55C or 130F.

3. Reactive Wastes q Normally unstable and reacts violently without detonating. q Reacts violently with water. q Forms an explosive mixture with water. q Generates toxic gases, vapor, or fumes when mixed with water. q Contains cyanide or sulfide and generates toxic gas vapors or fumes at a pH between 2 and

12.5.

4. Toxic Wastes

q Requires testing by Toxicity Characteristic Leaching Procedure (TCLP) for 25 organic chemicals, 8 metals, and 6 pesticides and sets threshold levels above which the waste would be classified as hazardous.

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5. Listed Wastes

q Waste contains or is completely composed of chemicals from four separate lists of hazardous wastes. Some "F" listed wastes must contain chemicals on the list that exceed at least 10% of the original mixture.

Generator Status Determine generator status (e.g., exempt, small, or large), which is dependent upon the amount of hazardous waste generated per month. Some states do not recognize distinctions between exempt and small and between small and large quantity generators, thus requiring either exempt quantity generators to observe small-quantity generator requirements and small-quantity generators to observe large-quantity requirements.

q Exempt quantity generators are those generating less than 220 pounds/month of hazardous

waste and less than 2.2 pounds/month of acute waste. q Small quantity generators are those facilities who generate between 220 and 2,200

pounds/month of hazardous waste and less than 2.2 pounds/month of acute waste. q Large generates over 2,200 pounds/month of hazardous waste and/or more than 2.2

pounds/month of acute waste. Wastes to count toward generator status (Note: This list is not all inclusive.):

q All listed and characteristic wastes that are accumulated on-site for any time period. q All listed and characteristic wastes that are packaged and transported off-site. q Placed in a regulated onsite treatment or disposal unit. q Still bottoms or slugs removed from storage tanks. q Contaminated soil or spilled chemistry. q Any material mixed with a listed hazardous waste. q Unused inventory that has not been used within one year.

Wastes not to count toward generator status (Note: This list is not all-inclusive.):

q Sewer discharges sent directly to a POTW, as long as POTW grants permission. q Sewer discharges from a neutralization (pH) unit. q Wastes continuously reclaimed on-site in a closed pipe system. q Any material already counted once during a calendar month, treated or reclaimed, and

used again.

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q Used oil sent off-site for disposal or recycling and not mixed with listed hazardous waste and contains less than 1,000 ppm total halogens. Chlorofluorocarbon-bearing compressor oils are exempt, if not mixed with other oils and recycled or reclaimed. Oils burned either onsite or offsite for energy recovery that contain more than 2 ppm cadmium, 10 ppm chromium, 100 ppm lead, or 5 ppm arsenic must be burned in specially equipped furnaces, boilers, or incinerators with scrubbers.

q Any material left in containers emptied through conventional means. If a container is

less than 110 gallons, then one inch or 3% by weight of the total capacity is allowed in the container for it to be considered empty. For example, 55-Gallon drums are allowed one inch of material remaining in it for them to be considered empty. A five-pound ink can would be allowed to have about one-eighth of an inch of ink in it to be considered empty. Containers greater than 100 gallons are allowed either one inch or 0.3% by weight of the total capacity. Containers with acute wastes must be tripled rinsed.

q For reusable shop towels contaminated with hazardous waste (e.g., some solvents and

inks), states may require written contract with laundry facility; laundry uses own trucks to pick up and deliver shop towels; shop towels not saturated with solvent and pass paint filter test. (Under these conditions, shop towels being washed and returned should be exempt from regulation). Some states regulate all reusable and disposable solvent-laden shop towels (regardless of amount) as hazardous and require manifests, while other states have established management practices to exempt them from being classified as hazardous. It is important to minimize the amount of excess solvent placed on the shop towels to help launderers meet their wastewater discharge limits. Obtain copy of state interpretation of solvent-laden reusable cleaning shop towels.

q Some states classify waste and used oil recovered silver and silver-bearing wastes,

fluorescent and high-intensity lights (mercury content), PCBs, ethylene glycol (anti-freeze) and uncontaminated lithographic ink as hazardous.

q Fluorescent lights properly disposed. Some states regulate them as hazardous because of

the mercury content. q Batteries and recalled pesticides classified as universal wastes and can be taken to local

collection center without manifest. Exempt Quantity Generator Requirements:

q Determine amount of hazardous waste generated per month. q Label and store wastes according to requirements (see below). q Ensure wastes are properly disposed at licensed treatment, storage, and disposal facility. q Can use own vehicle to transport waste to disposal facility. q Can participate in local neighborhood hazardous waste collection program. q Total hazardous waste accumulation not to exceed 2,200 pounds. q Spills or accidental releases of listed materials above reportable quantities require notification

to national response center (800/424-8802), state, and local governmental agencies. Obtain proper telephone numbers for appropriate agency.

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Small Quantity Generator Requirements: q Determine amount of hazardous waste generated per month. q Collect, label and store wastes according to requirements (see below). q Obtain facility identification number for off-site shipment of hazardous waste to a treatment

or recycling facility. Number is specific to location and is not transferable. q Change in type or volume of hazardous waste stream requires notification of state agency

by refiling the notification of hazardous waste activity form. q Manifests for all shipments of hazardous wastes with all proper EPA code(s), land ban

notification. Some states allow for contractual reclamation or recycling that does not require a manifest (e.g., solvent reclamation or reusable rags). q Generator must keep copies of manifests for at least three years and land ban forms for

five years. Some states require twenty-year retention for manifests. Permanent manifest storage for Superfund purposes is strongly suggested.

q Exception report for missing manifest must be filed within 60 days of shipment.

q Complete annual or biennial report. Some states require small quantity generators to file reports on waste generation and minimization activities.

q Total hazardous waste accumulation not to exceed 13,200 pounds in any 180 day period. A

270 day storage period is allowed if waste shipment to disposal facility is over 200 miles. Some states do not recognize the federal time limits and impose tighter limits.

q Confirm treatment method and treatment facility location, existence of liability insurance,

financial status, regulatory status (permits), and historical regulatory compliance record for every treatment facility receiving waste and also the transporter (if a separate company).

q Appoint an emergency coordinator either on-site or available 24 hours per day. q Contact local emergency response authorities and coordinate any response actions for facility.

Information should be provided on waste storage, sprinkler system, utility cut-offs, and water main, etc. (See contingency plan for large quantity generators below.)

q Post name and number of emergency coordinator and fire department at strategic locations

like phones and front door. q Post location of fire extinguishers, spill control equipment, and fire alarms at strategic

locations. q Provide general awareness training on proper waste handling and emergency response to all

employees involved in hazardous waste management activities. q Develop informal waste minimization plan. q Spills or accidental releases of listed materials above reportable quantities require notification

to national response center (800/424-8802), state, and focal governmental agencies. Obtain and keep on hand proper telephone numbers for appropriate agency.

q Some states require generators to develop and implement pollution prevention and waste minimization plans.

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Large Quantity Generator Requirements:

q Determine amount of hazardous waste generated per month. q Collect, label and store wastes according to requirements (see below). q Obtain facility identification number for off-site shipment of hazardous waste to a treatment

or recycling facility. Number is specific to location and is not transferable. q Change in type or volume of hazardous waste stream requires notification of state agency

by refiling the notification of hazardous waste activity form.

q Manifests for all shipments of hazardous wastes with all proper EPA code(s), land ban notification. Some states allow for contractual reclamation or recycling that does not require a manifest (e.g., solvent reclamation or reusable shop towels). q Generator must keep copies of manifests for at least three years and land ban forms for

five years. Some states require twenty-year retention for manifests. Permanent manifest storage for Superfund purposes is strongly suggested.

q Investigation of missing manifest must begin within 35 days of shipment and exception

report for missing manifest must be filed within 45 days of shipment.

q Complete and submit biennial report. Some states require more frequent reporting. q Total hazardous waste accumulation not to exceed 13,200 pounds in any 90-day period. q Confirm treatment method and treatment facility location, existence of liability insurance,

financial status, regulatory status (permits), and historical regulatory compliance record for every treatment facility receiving waste and also the transporter (if a separate company).

q Appoint an emergency coordinator either on-site or available 24 hours per day. q Post name and number of emergency coordinator and fire department at strategic locations

like phones and front door. q Post location of fire extinguishers, spill control equipment and fire alarms at strategic

locations. q Develop and implement a formal emergency procedure and contingency plan. Plan needs to

be shared with local emergency response authorities.

Minimum Elements of Contingency plan for responding to an emergency:

Facility description including review of activities, map and review of existing response plan.

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q Activity review should include description of materials processed waste generated, and copies of appropriate MSDSs.

q Facility map should be 7.5" USG with facility name and ID number indicating property

boundaries, storage tanks, location of surface drainage courses and potentially exposed surface and groundwater.

q Facility plot plan should indicate boundaries, manufacturing areas, raw material and

product storage areas, waste handling and storage areas, drains, pipes; and outfalls, secure and open access areas, and entrance and exit routes.

q Brief incident history including spill description and cleanup measures. q Facility personnel action responses including organizational structure of chain of

command. q List names, addresses, and phone numbers of emergency coordinators; designate primary

emergency coordinator and list others in order of responsibility. q Spill and leak-prevention measures including planning for emergencies, employee

training, inspection and monitoring program, and preventive measures like housekeeping material compatibility considerations, and security.

q Countermeasure plan details describing measures to be taken facility personnel and

outside contractors, list of emergency equipment available for response, internal and external communication and alarm system and evacuation plan for facility personnel.

q Contingency plan amended with dates. q Copies of plan submitted to police, fire department hospital, and local emergency

response teams. q At least one emergency coordinator is on facility premises at all times or on call. q Some states require emergency response capabilities fix containment/clean that require

training under OSHA spill control regulation.

q Develop and implement formal employee training program. Training records must be kept as long as a person is employed, and for three years after leaving the company. Employee's job descriptions must include hazardous waste handling responsibilities.

Minimum Elements of Employee Training Program:

q Training program consisting of classroom or on-the-job training (JOT) covering

hazardous waste identification, storage, labeling and shipping requirements, handling procedures, and emergency response actions.

q Training directed by person trained in hazardous waste management procedures.

q Training completed within six months of employment or assignment.

q Annual training review.

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Training records:

q Job title and name of employee. q Job description. q Amount and type of initial and continuing training to be given each person filling

position. q Documentation of training as job experience given to and completed by personnel. q Records kept until closure or three years after termination of employment.

q Develop and implement formal waste minimization plan.

Minimum Elements of a Waste Minimization Program: q Development of a written policy setting explicit waste reduction goals. q Designation of waste minimization coordinator. q Development and implementation of employee appropriate training and recognition of

accomplishments. q Characterization of waste generation and management by developing and maintaining a

waste accounting system to track waste generation dates, types, and amounts. Attempt to determine true costs associated with waste generation and cleanup including regulatory oversight, recordkeeping reporting, loss of potential production costs of materials in waste stream, transportation and disposal costs, employee exposure and health care, and potential future liability.

q Conduct periodic waste minimization assessments by identifying opportunities at all

points in the production process where materials can be prevented from becoming a waste. Opportunities should be analyzed based on true cost of waste management.

q Explore technology transfer opportunities. Sources of information include internal and

external sources like other companies, trade associations, consultants, and federal or state funded programs.

q Implement most promising options are identified by assessment process evaluations. q Conduct periodic review of program for effectiveness and feedback for potential

improvement. q Spills or accidental releases of listed materials above reportable quantities require notification to

national response center (800/424-8802), state, and local governmental agencies. Obtain and keep on hand proper telephone numbers for appropriate agency.

GATF: Environmental Compliance Checklist for Printers p. 12 of 16

III - 54

Storage and labeling Requirements:

1) Satellite storage areas:

q Total volume limited to 55 gallons. q Wastes must be stored in compatible containers. q Must be under visual control of operator and at or near equipment. q Multiple containers usually allowed, number depends on type of waste and size of

business. q Containers must be labeled 'hazardous Waste" and marked with accumulation date when

first amount of waste is placed into the container. q Containers must be closed unless filling or draining, spring closed funnel tops permitted. q Filled drums need to be moved to storage/disposal staging area within 72 hours of being

filled, if moved to storage area, they need to be relabeled for accumulation time limit. q There is no federal storage time limit, but some states have a time limit of one year or

less, while others do not allow satellite accumulation.

2) Storage and Staging Areas:

q All drums or other containers need to be labeled "Hazardous Wastes" with accumulation date and contents [can use classification code (e.g., D001)1.

q All wastes must be kept in closed containers unless they are being drained or filled. q Wastes need to be stored an impervious surface like sealed concrete or similar material. q Storage areas must have adequate aisle space (at least 3 ft.) for inspections and reading

labels. q Drums need to be properly maintained and not leaking or rusted. q Conduct weekly drum storage area inspections and daily inspections for tank storage.

Maintain log of inspection results indicating any corrective action. q Storage area needs to be equipped with or have immediate access to a communication

system (e.g., phone, alarm, or two-way radio), fire extinguisher, water (e.g., sprinkler system), spill cleanup materials, and first-aid materials (e.g., eyewash).

q Permits for recycling/recovery hazardous waste (e.g., silver recovery, distillation units).

Many states require generators of all sizes to obtain permits for these activities. Check with state/local agency for requirements.

q Unused chemicals not stored for more than one year. They are considered waste and

must be properly disposed.

GATF: Environmental Compliance Checklist for Printers p. 13 of 16

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D. Non-hazardous Waste

q Some states have adopted mandatory recycling programs for business and require annual/biannual reporting on program effectiveness.

q Same states have adopted Residual Waste regulations governing the proper disposal of non-

hazardous industrial wastes (e.g., uncontaminated lithographic inks, films, and chemical containers). These wastes must go to an approved treatment/landfill facility, the generator has to complete a biennial report, perform chemical analysis, and develop a source reduction plan.

q Confirm treatment method and treatment facility location, existence of liability insurance,

financial status, regulatory status permits), and historical regulatory compliance record for every treatment facility receiving waste and also the transporter (if a separate company).

E. Emergency Planning and Community Right-to-Know

q Obtain copy of USEPA's consolidated list of chemicals (800/535-0202). q Procedure for notifying federal, state, and local authorities in case hazardous substances are

accidentally released above reportable quantity amounts. Depending on type of material, quantity, location and duration, and receiving media, notification should be immediate but no longer than 24 hrs may require written follow-up report detailing spill and remediation activities.

q Submission of copies of Material Safety Data Sheds (MSDSs) or list of substances to local

authorities, state authorities, and fire department for substances stored above threshold levels--usually 500 lbs. for extremely hazardous substances and 10,000 lbs. for any substance(s) requiring an MSDS. Some states and local governments have lower threshold levels and also require submission of MSDSs to hospitals.'

q Submission of Tier I/Tier II forms by March 1 for chemicals stored in excess of threshold levels

during previous calendar year. (See previous item for threshold quantities.) Some states and local governments have lower threshold levels.

q Submission of Form R, Toxic Chemical Release Inventory Reporting Form by July 1 for each

chemical on a specific list of chemicals used in excess of the threshold levels (25,000 lbs. for manufactured or processed chemicals [components of inks] or 10,000 lbs. for otherwise used chemicals [solvents]) during the previous calendar year. New Form R requires pollution prevention activity reporting.

q Consider using approved alternate reporting option for Section 313 (e.g., Form R). Under this

option a Form R need not be submitted only an annual certification is needed. Applies to reporting year 1995 and chemical being reported must be used in quantities less than 1 million pounds and have a combined reportable threshold of 500 pounds (i.e., released, treated, of disposed).

GATF: Environmental Compliance Checklist for Printers p. 14 of 16

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F. Storage Tanks

q Submit registration form for all chemical underground storage tanks (USTs) greater than 110 gallons storing listed hazardous chemicals or petroleum products except for heating oil tanks. Some states do regulate heating oil tanks with the size for regulation varying. Some states regulate all chemical tanks.

q New petroleum USTs must be equipped with leak detection devices, corrosion protection, and

spill overfill prevention measures. New chemical USTs must also have secondary containment. q Existing petroleum and chemical USTs must be retrofitted with leak detection by 1993 depending

upon the age of the tank. Corrosion and spill/overfill prevention measures are required by 1998. Existing chemical USTs must be retrofitted with secondary containment systems by 1998.

q Aboveground tanks located outside the plant must have a spill containment system including

dikes. Some states regulate above ground storage tanks with regard to registration, spill control programs, and other corrosion requirements.

q Aboveground tanks located inside the plant (tote tanks) may also require a spill containment

system, registration, and spill control programs. Contact state for requirements. q Tank removal, especially of USTs, requires written notification, state supervision possible testing

for contamination, and remediation. q Demonstrate financial assurance of at least $1 million for cleanup costs and third-party claims

resulting from leaks and spills' from USTs. q Maintain records of testing; maintenance, spills, and cleanup activities.

G. Spill Prevention Control and Countermeasures Plan

q Storage total of more than 1,320 gallons in aboveground tanks or single tanks exceeding 660 gallons or UST with more than 42,000 gallons of petroleum or petroleum-derived products (e.g., inks, lubrication oil gasoline, diesel fuel and possibly some solvents) that when accidentally released can contaminate navigable waters of the United States and adjoining shorelines requires development of contingency and cleanup plan. Plan must be updated and certified by professional engineer every three years.

q Spills of materials require notification of federal, state and local authorities.

GATF: Environmental Compliance Checklist for Printers p. 15 of 16

III - 57

H. Polychlorinated Biphenyls

q Some states regulate polychlorinated biphenyls (PCBs) and PCB contaminated material as hazardous wastes (e.g., ballasts from fluorescent lights, dielectric fluid from transformers, soil, and power -stabilizing rectifiers).

q PCBs or PCB-contaminated material must be shipped with a special manifest, or if considered hazardous, then with a state manifest form.

q 480-volt or greater transformers containing more than 500 parts per million PCB located near a commercial building and located in a network must be removed or reclassified by draining and refilling by October 1, 1990. Transformers less than 480 volts can be used, but they must be protected and disposed properly.

q Transformers containing less than 500 ppm and greater than 50 ppm PCB can be used, but they

must be disposed properly. q Transformers containing less than 50 ppm are exempt from federal regulation. q Presence of PCB can be determined by records, manufacturer's data, or testing. q PCB containing transformers need to be inspected quarterly and prominently identified for

firefighters. q Fires involving PCB transformers need to reported to the national response center (800/424-

8802), state, and local emergency response personnel. The phone numbers should also be included in the contingency plan.

q Maintain records of inspections, manifests, service, marking and maintenance of PCB areas of the

proper forms. q A one-year time limit is imposed requiring the disposal of PCB contaminated materials removed

from service. I. Asbestos

q Renovation or demolition of more than 260 linear feet, 160 square feet or 35 cubic feet of asbestos containing material requires EPA/state approval.

q Removal of more than 80 linear feet or 15 cubic feet requires the presence of a trained person on

site to monitor activities and employee exposure. Make sure that the contractor has the proper credentials and has not been cited for violations.

q suggest institution of asbestos operation and maintenance program including regular inspections. q Some banks and lending institutions require that all asbestos be removed from commercial

buildings prior to granting loans for property acquisition or expansion. q See new OSHA regulations on employee training and exposure control requirements.

GATF: Environmental Compliance Checklist for Printers p. 16 of 16

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J. Department of Transportation Employee Training

q Training required for employees and supervisors involved in driving, loading, unloading, or handling hazardous materials. Training is specific to job function and should include:

q General awareness of regulations. q Shipping paper preparation. q Recognition and identification of hazardous materials. q Proper handling and safety procedures q Procedures for accident prevention and emergency response including specific protection

measures like personal protective equipment. q DOT allows OSHA hazard communication standard, hazardous waste response (Hazwoper), and

USEPA Resource Conservation and Recovery Act (see hazardous waste generator requirements), K. Ozone Depleting Substances

q All products manufactured with or containing a Class I substance (chloroflurocarbons, halons, carbon tetrachloride, or l,l,l-trichloroethane) after May 15, 1993 must be labeled. All products manufactured with or containing a Class II substance (hydrochloroflurocarbons) after January 1, 2015 must be labeled. All containers used to transport or store a Class I or II substance must also be labeled. Labeling requirements are specified by regulation.

q No venting of refrigerants from commercial refrigeration equipment air conditioners, and vehicle

air conditioners. Refrigerants must be recovered and recycled by certified technician. q Certifications obtained fix technicians who will work on refrigeration equipment. q Equipment used to recover and recycle refrigerants must be certified. q Used refrigeration equipment cannot be discarded without first removing refrigerant. q Consider retrofitting existing equipment for new refrigerants.

III - 59

FEDERAL ENVIRONMENTAL REGULATIONS POTENTIALLY AFFECTING THE COMMERCIAL PRINTING INDUSTRY

The following tables and information are drawn from the EPA publication, “Federal Environmental Regulations Potentially Affecting the Printing Industry” (EPA 744B-94-001), prepared by the Design for the Environment Program for the Office of Pollution Prevention and Toxics, US Environmental Protection Agency, Washington, D.C., March 1994. The full report is available from the EPA, www.epa.gov/opptintr/dfe/printing/fedregs/printreg.pdf. Tables are numbered as in the full report. EXHIBIT 6. Chemicals Used in the Printing Industry That are Listed as Hazardous Air Pollutants in the Clean Air Act Amendments

HAZARDOUS AIR POLLUTANTS Benzene Formaldehyde Methylene chloride Cadium compounds Glycol ethers Perchloroethylene Carbon tetrachloride Hexane Polycyclic organic matter Chromium compounds Hydrochloric acid Propylene oxide Cumene Isophorone Toluene Dibutylphthalate Lead compounds 2,4-Toluene diisocyanate Diethanolamine Methanol 1,1,2-Trichloroethane Ethyl benzene Methyl ethyl ketone Vinyl chloride Ethylene glycol Methyl isobutyl ketone Xylenes EXHIBIT 9. Examples of Listed Wastes (U) Found in the Printing Industry Waste Code

Name or Description of Waste Waste Code

Name or Description of Waste

U002 Acetone U226 Methyl chloroform U019 Benzene U080 Methylene chloride U211 Carbon tetrachloride U159 Methyl ethyl ketone (MEK) U055 Cumene U161 Methyl isobutyl ketone U056 Cyclohexane U210 Tetrachloroethylene (perchloroethylene) U069 Dibutyl phthalate U220 Toluene U112 Ethyl acetate U223 Toluene diisocyanate U359 Ethanol, 2-ethoxy U228 Trichloroethylene U359 Ethylene glycol monoethyl ether U043 Vinyl chloride U122 Formaldehyde U239 Xylene U154 Methanol

FEDERAL ENVIRONMENTAL REGULATIONS POTENTIALLY AFFECTING THE COMMERCIAL PRINTING INDUSTRY p. 2 of 5

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EXHIBIT 8. Examples of Listed Wastes (F-series) Found in the Printing Industry

Waste Code Name or Description of Waste

F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F002 The following spent halogenated solvents: Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2- trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F003 The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents; and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and, a total of ten percent or more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F005 The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

FEDERAL ENVIRONMENTAL REGULATIONS POTENTIALLY AFFECTING THE COMMERCIAL PRINTING INDUSTRY p. 3 of 5

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EXHIBIT 11. EPA Toxic Characteristic Contaminants That May be Found in Printing Industry Waste Waste Code Contaminant Waste Code Contaminant D005 Barium D011 Silver D007 Chromium D040 Trichloroethylene D019 Carbon tetrachloride D043 Vinyl chloride D035 Methyl ethyl ketone APPENDIX B CLEAN WATER ACT: REPORTABLE QUANTITIES OF HAZARDOUS SUBSTANCES THAT MAY APPLY IN THE PRINTING INDUSTRY

Hazardous Substance RQ (in pounds) Benzene 10 Carbon tetrachloride 10 Chloroform 10 Cyclohexane 1,000 Ethylbenzene 1,000 Formaldehyde 100 Hydrochloric acid 5,000 Propylene oxide 100 Styrene 1,000 Toluene 1,000 Xylene (mixed) 1,000

FEDERAL ENVIRONMENTAL REGULATIONS POTENTIALLY AFFECTING THE COMMERCIAL PRINTING INDUSTRY p. 4 of 5

III - 62

APPENDIX D CERCLA REPORTABLE QUANTITIES FOR SOME CHEMICALS USED IN THE PRINTING INDUSTRY Chemical Reportable

Quantity (lbs)

Chemical Reportable Quantity (lbs)

Acetone 5,000 Methyl chloroform 1,000 Ammonia 100 Methylene chloride 1,000 Benzene 10 Methanol 5,000 Cadmium and compounds

1 Methyl ethyl ketone 5,000

Carbon tetrachloride 10 Methyl isobutyl ketone

5,000

Chloroform 10 Perchloroethylene 100 Chromium and compounds

1 Phosphoric acid 5,000

Cumene 5,000 Propylene oxide 100 Cyclohexane 1,000 Sulfuric acid 1,000 Dibutyl phthalate 10 Toluene 1,000 Ethanol, 2-ethoxy 1,000 Toluene

diisocyanate 100

Ethyl acetate 5,000 1,1,1-Trichloroethane

1,000

Ethylbenzene 1,000 1,1,2-Trichloroethane

100

Formaldehyde 100 Trichloroethylene 100 Hydrochloric acid 5,000 Vinyl chloride 1 Isophorone 5000 Xylene (mixed) 1,000 Lead and compounds 1

APPENDIX E THRESHOLD PLANNING AND REPORTING QUANTITIES FOR SOME EPCRA-DESIGNATED EXTREMELY HAZARDOUS CHEMICALS USED IN THE PRINTING INDUSTRY Chemical Name Reportable Quantity

(lbs) Threshold Planning Quantity (lbs)

Ammonia 100 500 Formaldehyde 100 500 Hydroquinone 1 500/10,000* Propylene oxide 100 10,000 Sulfuric acid 1,000 1,000 Toluene 2,4-Diisocyanate 100 500 * Revised threshold planning quantity based on new of re-evaluated toxicity data.

FEDERAL ENVIRONMENTAL REGULATIONS POTENTIALLY AFFECTING THE COMMERCIAL PRINTING INDUSTRY p. 5 of 5

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APPENDIX F CHEMICALS USED IN THE PRINTING INDUSTRY THAT ARE LISTED IN THE TOXIC RELEASE INVENTORY

TOXIC CHEMICALS Acetone Ethylene glycol Phosphoric acid Ammonia Ethylene oxide Silver Barium Formaldehyde Sulfuric acid Cadmium Freon 113 Tetrachloroethylene Chromium Hydrochloric acid Toluene Copper* Hydroquinone Trichloroethylene Cumene Lead 1,1,1-Trichloroethane Cyclohexane Methanol Xylene Methylene chloride Methyl ethyl ketone Ethylbenzene Methyl isobutyl ketone * Copper phthalocyanini pigments delisted in May 1991.

III - 64

hotopolymer printing platesh ave become a staple of thef l e x ographic industry. And

while the technology is still far fro mperfect, most of the pro blems associ-ated with plates are fairly routine anda result of erro rs in the platemakingp rocess, not flaws in the plate materi-al. In this art i c l e, I’ll examine thee n t i re platemaking process, descri b i n gwhat should happen at each step, andwhat can go wrong if proper pro c e-d u res are not followed. Inters p e rs e dthroughout the article are photos ofcommon plate defects, along withtheir possible causes.

The Platemaking Pro c e s sBack exposure is the first step in

making a photopolymer plate. It’s asimple task, but it’s one of the most

H e re ’s a step-by-step examination of the making of a photopolymer plat e ,and the my riad things that can go wrong from start to fin i s h .

By Dan Owenby

Figure 1: Reverse fill-in is one of the many possible results of excessive back-exposure time.

REVERSE FILL-INCauses:

• excessive face exposure• excessive back exposure• low-density negative• defective negative• out-of-contact polymer negative

W H E NPlates Go Bad!

P

i m p o rtant steps — if not t h e m o s ti m p o rtant step — in making a plate.This is where the relief depth is setfor support of the printing image.

D u ring back exposure, the plate isexposed to UVA light. The UVAp o rtion of the electromagnetic spec-t rum encompasses a radiation wave-length range of 320-400 nanometers .

At the moment UVA contacts thep l a t e, photoinitiators within the poly-mer energize and begin the curi n g ,or cross-linking, process. This chainreaction will continue for the dura-tion of the exposure, penetratingdeeper into the plate over the lengthof the exposure time. Once the UVAenergy is re m oved, the cro s s - l i n k i n g

chain reaction stops almost instanta-n e o u s l y, thus giving the plate a con-sistent penetration depth, or flo o r.

I m p roper back-exposure time canlead to a floor depth that is either toothin or too thick. Excessive back-e x p o s u re time will create a floor thatis too thick, which means there willnot be enough unexposed polymerremaining to properly create theimage (see Figure 1, on facing page).On the other hand, insufficient back-e x p o s u re time will create a floor thatis too thin. In this instance, there willbe too much unexposed polymer

remaining, and the image will notp roperly merge with the floor (seeFigure 2). Thus, floor thickness shouldbe checked with a micrometer toe n s u re proper relief and floor consis-t e n c y.

The next step is face exposure.H e re, the negative is positioned onthe photopolymer with the emu l s i o nside facing the surfa c e. A va c u u mc over sheet is applied to create inti-mate contact between the plate andn e g a t ive, and UVA is used to transferthe image to the uncured photopoly-mer remaining from the back-expo-

Figure 2: A sticky plate could be the resultof insufficient back-exposure time.

BLURRED IMAGECauses:

• defective negative• air trapped under negative• excessive face exposure• emulsion on wrong side

Figure 3: A blurred image may be the sign of excessive face exposure.

STICKY PLATE/GUMMY FLOORCauses:

• insufficient back exposure• insufficient washout• insufficient oven-dry time• insufficient germicidal detack• insufficient post exposure

When Plates Go Bad!

Too much or too little washout canlead to serious pro blems. For instance,if the washout time is insufficient,then some of the unexposed polymerwill remain on the plate, meaning thatthe relief depth will either be incor-rect or inconsistent. Plates not wa s h e dcompletely to the floor contain a laye rof non-exposed polymer on top ofthe exposed flo o r. This layer is morep rone to develop tack during the pre s srun (see Figure 5) .

On the other hand, if the plate isove r washed, it may swell to such anextent that it may not be dried dow n

s u re process. As the UVA energytransmits through the clear areas ofthe negative to the polymer, it initi-ates curing of the majority of the pre-viously uncured polymer. The imagea reas of the negative allow the light topass through, while the non-imagea reas absorb the light, thus preve n t i n gc ross-linking from occurring. Thisf o rms the printing image.

The amount of fa c e - e x p o s u re timeis ve ry important. Ove rexposed plateswill have shallow reve rses, bro a d

Figure 5: Tackiness is a possible indicator of insufficient washout procedures.

INCONSISTENT PLATE GAUGECauses:

• i m p roper storage of raw materials• excessive washout• insufficient oven-dry time• defective material• manufacturing error

TACKY PLATECauses:

• insufficient back exposure• insufficient washout• insufficient oven-dry time• insufficient germicidal detack• insufficient post exposure

Figure 6: If you’ve detected an inconsistencyin your plate gauge, it could be the result ofexcessive washout that caused the plate toswell beyond the point where it could besufficiently dried.

WAVY LINES & CHIPPINGCauses:

• insufficient face exposure• insufficient back exposure• excessive washout• excessive brush pressure• insufficient oven-dry time• incorrect artwork on negative

Figure 4: Wavy lines and/or chipping canoccur if a plate has been underexposed.

s h o u l d e rs and reduced shadow - d o tdepths (see Figure 3, on page 47).U n d e rexposed plates will have wav ylines, unsecured screens and a mottledplate surface (see Figure 4). To ensurethat the photopolymer is fa c e -exposed pro p e r l y, the user needs toh ave knowledge of the photopolymera c t iv i t y, the expose-unit’s lamps t rength, and the art wo r k ’s level ofd e t a i l .

Wa s h o u tNext, the uncured polymer under

the non-image areas of the plate mu s tbe re m oved. This is accomplished bythe combined process of washing theplate with solvent (or wa t e r - b a s e dacids or detergents, for wa t e r - wa s hand liquid plates) while scrubbing itwith a brush. In most cases, the poly-mer is dissolved and re m oved in solu-tion, not by the scrubbing action.Thus, the amount of pre s s u re appliedby the brushing should be the mini-mum amount necessary to re m ovethe polymer and recoat the plate withthe solvent. The plate should bewashed long enough to completelyreach the floor of the non-imagea reas, but no longer than necessary.

D u ring washout, the plate absorbss o l vent and swells up, much like asponge absorbing wa t e r. As a re s u l t ,upon re m oval of the plate from thewashout unit, fine lines may appearwavy and reve rses may seem to befilled in. If the washout time was cor-rect, these effects should disappear inthe early stages of dry - d ow n .

(see Figure 6, on page 48). Fine detailm ay also be chipped off of the plate.Again, washout time should be limit-ed to the minimum time necessary toreach the plate flo o r.

R i n s i n g / B l o t t i n gThe wash cycle will leave dissolve d

photopolymer on the plate’s surfa c e,and this must be re m oved. Thus,once the washout cycle is complete,the plate should be rinsed in cleans o l vent. When rinsing the plate, payp a rticular attention to screen areas andfine reve rses. Improper rinsing will

When Plates Go Bad!

l e ave polymer in the reve rs e s / s c re e n sand on the plate surfa c e, leading to amottled effect on the printed pro d u c t .

After rinsing, the plate should beblotted with a lint-free towel tore m ove as much solvent as possibl e.This will allow the plate to dry dow nwith the highest efficiency. With in-line pro c e s s o rs, the rinsing and bl o t-ting are done automatically.

Next, the solvent that wa sabsorbed during washout must bere m oved from the plate. Drying theplate in a heated, forced-air drye raccomplishes this. (The temperature

MOTTLED PLATE SURFACECauses:

• insufficient face exposure• excessive washout• dirty washout solvent• insufficient oven-dry time• slip-film area damaged

Figure 7: A mottled plate surface, “orange peel,” in this case, may be the sign of insufficientdrying time.

Figure 8: A cracked plate could be an indicator of excess finishing time.

CRACKED PLATECauses:

• excessive finishing time• insufficient post exposure• plate stored in the round• plate stored in the presence of light• poor cleaning prior to storage• high-ozone environment

of the dryer should be between 140and 150 degrees Fahrenheit.) Thed rying process allows the solvent toevaporate out of the plate, re t u rn i n gthe plate to its normal gauge anda l l owing the image areas to re g a i ntheir ori ginal dimensions. Keep inmind that the solid areas will re t u rnto gauge before the screen areas, dueto the larger surface area of thes c re e n s .

Most of the pro blems associatedwith dry - d own result from insuffi-cient drying. Of all the steps in theplatemaking process, this is the onemost commonly cut short. Sav i n gtime is of no benefit here, and canlead to pro blems such as wavy lines,tacky plates, “orange peel,” stickyflo o rs and a plate that smells of sol-vent (see Figure 7). The idea is to drythe plate long enough to re m ove allof the solvent. Fo rt u n a t e l y, excesstime in the dryer will not damage thep h o t o p o l y m e r, provided that the ove nt e m p e r a t u re does not exceed the pre-s c ribed 150 degrees Fahrenheit. Ove nt e m p e r a t u res greater than 150 degre e sF a h renheit can cause shrinkage of theplate backing.

Im p roper rinsing will

leave polymer in

the re v e r s e s / s c re e n s

and on the plate

s u rface, leading to a

mottled effect on the

printed pro d u c t .

F i n i s h i n g / P o s t - E x p o s u reA plate remains somewhat tacky

even after all solvent has beenre m oved in the drye r. This tack canbe eliminated by finishing, or surfa c e -t reating, the plate. This is accom-plished by exposing the plate surfa c eto UVC light, creating what is essen-tially a “super” cross-link. The UVCp o rtion of the electromagnetic spec-t rum is where the UV radiationwavelength range is 200 to 290n a n o m e t e rs. UVC does not fullypenetrate the plate, rather, it mere l y“ finishes” the surfa c e.

Note that heat will change the

Mechanical DamageA ny mechanical damage will,

almost without fail, render a plateuseless (see Figure 9). Thus, platesmust be handled correctly: cleaningshould be done with a soft-bri s t l e db rush and a quality flexo-plate wa s hf o rmula; care must be taken in trans-p o rtation and storage, or kinks mayd evelop; aniloxes must release imme-diately upon press stoppage or theywill damage a plate in seconds (seeFigure 10). In short, there are manyways to damage a plate, and few, ifa ny, ways to fix one.

I n c o m p a t i ble inks or cleaningchemicals are another source of platep ro blems, in this case, swelling, soft-ening and/or tack. If in doubt aboutwhat will or wo n ’t work with yo u rp a rticular plates, call your plate sup-plier and ask for a list of approve d /c o m p a t i ble chemicals. Anothermethod of precaution would be top e r f o rm a swell test to determine inkc o m p a t i b i l i t y, provided a tabl e t o pm i c rometer is ava i l a bl e. To performthis test, take a piece of plate, measureits thickness, put it in a glass contain-e r, add the ink or cleaning solution,and let the plate soak for 24 hours .Then re m ove the piece of plate mate-rial and re m e a s u re it. If the plate hasswelled by more than five perc e n t ,compatibility is suspect.

As you can see, there are plenty ofthings that can go wrong at somepoint in the platemaking pro c e s s .Indeed, a quality plate is the result ofsound techniques and careful attentionpaid to detail. By consulting with yo u rplate supplier and following the pro c e-d u res outlined in this art i c l e, you willbe well on your way to achieving bet-ter quality in your plates.

When Plates Go Bad!

e f f e c t iveness of finishing, so the fin-i s h i n g / p o s t - e x p o s u re unit should bep roperly vented. Care should also bet a ken to re s t rict finishing time to them i n i mum amount of time necessaryto sufficiently re m ove the plate tack.E x c e s s ive finishing will make the plateb rittle and cause it to crack (see F i g u r e8, on page 50).

While the plate is undergoing thefinishing process, it should be simu l t a-neously post-exposed using UVAlight to penetrate the entire plate, thuse n s u ring a complete cross-linking ofall the photopolymer and achiev i n ge f f e c t ive hard n e s s .

Dan Owenby is a senior field test engineer atP o l y fibron Technologies Inc., Atlanta. He has beenin the industry for 10 years and is a frequentspeaker at FTA and related flexographic technicalseminars. Owenby holds a B.S. in mechanical engi-neering from Southern Technical Institute and anM.B.A. from Kennesaw State University. For moreinformation on Polyfibron, please visit their Website, w w w . p o l y fib r o n . c o m.

MECHANICAL DAMAGECauses:

• improper handling• cleaning brush too stiff• plate jammed in press• anilox roll grinding into plate• improper storage

Figure 9: A plate with mechanical damage is best suited for the trash heap.

FLOOR CRACKEDCauses:

• excessive finishing time• high-ozone environment• improper plate storage

Figure 10: A cracked plate floor is often the result of improper storage procedures.

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PERFORMANCE

IV. Biographical Sketches of Presenters and Panelists

PHONE NUMBERS TO USE DURING THE PROGRAM Live Question and Answer Period: 1-800-442-4613 Fax Number: 1-800-348-9529

IV- 1

Biographical Sketches of Presenters and Panelists

IV-2

PERFORMANCE

David Argent has spent thirty years in ink and allied industries in his native England, Canada and the United States occupying various technical and management positions. He has broad-based experience with litho, rotogravure, as well as flexography and has developed many products and concepts to improve flexographic and rotogravure printing, especially in the areas of High Solids, Thin Film and Water-Based Inks. Mr. Argent is currently Product Manager with Progressive Ink and is active in GTA, FTA, TAPPI, and as a founding member of FQC. Phone: 314-768-5530, ext. 351 Fax: 314-768-5540 E-mail: Daveargent@progressiveink.com Karen Doerschug is a Senior Project Manager with the U.S. Environmental Protection Agency’s Design for the Environment (DfE) Program. DfE is a voluntary partnership program that promotes the incorporation of environmental considerations into business decisions. Ms. Doerschug manages DfE’s projects with the flexographic and lithographic printing industries. She also leads DfE’s program evaluation and communication teams, and participates in the program’s New Project team. Prior to joining EPA, she worked with MCI, Searle and ICF Consulting and has accumulated twelve years of experience in business analysis, marketing and environmental issues. Phone: 202-260-0695 Fax: 202-260-0981 E-mail: doerschug.karen@epamail.epa.gov Bill Dowdell has been President of the Flexographic Technical Association since 1993. Prior to that, he was with the DuPont Corporation for 28 years, including the last eight years as Worldwide Business Director of DuPont’s CYREL Packaging Graphics business. Phone: 631-737-6020, ext. 30 Fax: 631-737-6813 E-mail: bdowdell@vax.fta-ffta.org Mike Klemme has been with Highland Supply Corporation since 1986. His broad-based experience with the company includes management of plant production, maintenance and environmental programs, development of production operating procedures and training materials, and research, development and implementation of a water-based ink system for flexographic and gravure printing. Mr. Klemme is currently responsible for specifying and purchasing production equipment for all pre-press, press and post-press operations, as well as the development of new or improved inks and coatings. Phone: 618-654-2161, ext. 470 Fax: 618-654-9623 E-mail: marklemme@sprintmail.com

Biographical Sketches of Presenters and Panelists

IV-3

PERFORMANCE

Doreen M. Monteleone is Director of Environmental Affairs for the Flexographic Technical Association where she has national responsibility for environmental issues that affect flexographic printers. Since Dr. Monteleone joined FTA in 1996, her accomplishments have included representing the flexographic industry in the USEPA Design for the Environment and Common Sense Intiatives, publishing the monthly Environmental Newsletter, and serving as the association’s Supervisor of Membership. Additionally, she works with federal, state and local agencies to distribute information to FTA members, and reviews regulations to make them appropriate for flexo printers. Dr. Monteleone previously held several high-level positions within New York state government providing environmental and other technical assistance to businesses. She was a Resource Expert for the 1994-95 White House Conference on Small Business and was the Conference Chair for the 1998 National Environmental, Health and Safety Conference for the Graphic Communications Industries. Phone: 631-737-6020, ext. 18 Fax: 631-737-6813 E-mail: dmonteleone@flexography.org Jim O’Leary began his career as an operations research analyst with Grumman Aerospace Corporation in 1965. After a move to the Washington DC are in 1970, he worked for several management consulting organizations as an operations research analyst. Since 1980, he has been with the U.S. EPA in Washington hold various management and non-supervisory positions, primarily with the Office of Solid Waste. Currently, Mr. O’Leary is a special assistant to the Division director, Hazardous Waste Identification Division where he conducts various studies and analyses, including the study of solvent-contaminated shop towels and wipes, and issues related to hazardous waste recycling activities. Phone: 703-308-8827 Fax: 703-308-0514 E-mail: oleary.jim@epa.gov W. Michael McCabe is Acting Deputy Administrator for the U.S. Environmental Protection Agency. He assists the EPA Administrator in setting and communication national environmental policy, implementing and enforcing federal environmental laws, and ensuring the efficient management of the Agency and its 18,000 employees. Mr. McCabe has 25 years of experience in environmental policy and leadership within the EPA as well as the legislative branch of the federal government.

Biographical Sketches of Presenters and Panelists

IV-4

PERFORMANCE

Dan Owenby is the Technical Service Manager for Chemence, Inc. of Alpharetta, Georgia. He has been in the industry for 11 years and is a frequent speaker at FTA and related flexographic technical seminars. Mr. Owenby holds a B.S. in Mechanical Engineering from Southern Technical Institute and an M.B.A. from Kennesaw State University. Phone: 770-664-6624, ext. 34 Fax: 678-429-0907 E-mail: dowenby@chemence.com Wayne Pferdehirt is a Waste Reduction and Management Specialist with the University of Wisconsin-Extension’s Solid and Hazardous Waste Education Center, and a Co-Director of the Printers’ National Environmental Assistance Center. Mr. Pferdehirt assists printers and other businesses seeking to reduce hazardous wastes and toxic air and water emissions. He also directs the University of Wisconsin – Madison’s first on-line graduate program, the Master of Engineering in Professional Practice. Phone: 608-265-2361 Fax: 608-262-6250 E-mail: pferdehi@epd.engr.wisc.edu Sigmond Singramdoo is a Process Engineer at Anagram International, Inc. He is responsible for maintaining and improving all processes of the printing and extrusion operations. Since 1995, Mr. Singramdoo has been involved with the company’s Pollution Prevention Initiatives and Hazardous Waste Reduction programs. As a result of these programs, Anagram has received awards and recognition from local and state government, as well as from trade associations. He is also an ISO 9000 and ISO 14000 auditor. Phone: 612-949-5752 Fax: 612-949-5609 E-Mail: singrams@anagramintl.com Brad Taylor is a Research Associate for DuPont Cyrel� Packaging Graphics Products. He is responsible for research, development and applications support of DuPont Cyrel�’s digital products, including electronic prepress, digital imaging, and media testing, development, and analysis. Prior to his assignment with Cyrel�, Dr. Taylor worked on various electronic imaging technologies in DuPont’s Printing and Publishing and Imaging Systems businesses, which included thermal offset plate imaging, color electronic scanning, color science and electronic image recording technology. Phone: 302-999-3627 Fax: 302-999-4579 E-mail: brad.k.taylor@usa.dupont.com

Biographical Sketches of Presenters and Panelists

IV-5

PERFORMANCE

Tom Underwood is Plant Manager for OEC Graphics, Inc. in Oshkosh, Wisconsin. Phone: 920-235-7770 Fax: 920-235-2252 E-mail: tom@oecgraphics.com Keith West is an Industrial Recycling Specialist for the Solid and Hazardous Waste Education Center of University of Wisconsin – Extension. For the past few years he has provided waste reduction and pollution prevention assessments to manufacturers and other businesses in the state. Mr. West worked for many years in private industry and among his other accomplishments, he coordinated a small manufacturer’s ISO 9002 registration effort and Environmental Management System development. Phone: 920-465-2940 Fax: 920-465-2143 E-mail: westk@uwgb.edu

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PERFORMANCE

V - 1

V. Additional Sources of Information and Assistance

Printers National Environmental Assistance Center (PNEAC) World Wide Web Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-3 Index of Fax-Back Documents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-7 Flexographic Technical Association (FTA) . . . . . . . . . . . . . . . . . . . . . . . . . . . V-11 EPA Design for the Environment (DfE) Program Get Involved: Industry Contributions to Informed Ink Choices . . . . . . . . V-13 Focusing on Flexo Inks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-15 National Trade Associations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-17 State Pollution Prevention Technical Assistance Programs . . . . . . . . . . . . . . . V-19 Clean Air Act Small Business Ombudsmen and Technical Assistance Directors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-25 National Small Business Environmental Resources . . . . . . . . . . . . . . . . . . . . . V-29

V - 2

What Is PNEAC?EPA's Office of Enforcement and Compliance Assurance and PollutionPrevention Policy Staff have partnered with industry and environmental experts todevelop this environmental assistance center for the printing industry whichincludes compliance assistance and P2 information.

This is a communications-based center linking trade, governmental, and universityservice providers to efficiently provide the most current and complete complianceassistance and pollution prevention information to the printing industry. Theproject's staff are located within the partnering organizations. The Great LakesInformation Network is providing support for the two Internet Listservs.

PNEAC Partners (Contacting Humans at PNEAC)

Illinois Waste Management and Research Center:

University of Illinois, Champaign, IL

Gary Miller, PNEAC Director(217) 333-8940 / gmiller@wmrc.uiuc.edu

❍

Todd Schumacher, Project Management Assistant(217) 333-8940 / todds@wmrc.uiuc.edu

❍

●

Oak Brook, IL

Debra Jacobson(630) 472-5019 / djacobso@wmrc.uiuc.edu

❍

●

Solid and Hazardous Waste Education Center:

University of Wisconsin, Madison, WI

Wayne Pferdehirt, PNEAC Co-Director(608) 265-2361 / pferdehi@epd.engr.wisc.edu

❍

Bob Gifford(608) 262-1083 / gifford@epd.engr.wisc.edu

❍

●

Graphic Arts Technical Foundation / Printing Industries of America:

Sewickley, PA

Gary Jones(412) 741-6860 / garyjgatf@aol.com

❍

Rick Hartwig(412) 741-6860 / rickhgatf@aol.com

❍

●

PNEAC'sAdvisoryCouncil

Council of GreatLakesGovernors

EnvironmentalDefense Fund

FlexiblePackagingAssociation

FlexographicTechnicalAssociation

GravureAssociation ofAmerica

NationalAssociation ofPrinters &Lithographers

NationalInstitute ofStandards &Technology

NationalPollutionPreventionRoundtable

Screenprinting &Graphic ImagingAssociation,International

Clean Air ActSmall BusinessDevelopmentCenters

Association ofSmall BusinessDevelopmentCenters

InternationalAssociation ofPrinting HouseCraftsmen

What is PNEAC?: Environment and Printing: The Printers' National En...AC: The Environmental Information Website for the Printing Industry

http://www.pneac.org/whatis.html (1 of 3) [3/12/2000 2:19:40 PM]

Products and Services

Training

One of the most important goals of the PNEAC project is to offer printers andtechnical assistance providers a wide variety of training materials and educationalopportunities.

Basics of Printing●

P2 In Lithographic Printing●

P2 In Gravure Printing●

P2 In flexographic Printing●

P2 in Screen Printing●

Compliance Assistance Training●

Green and Profitable Printing Training Videos●

Technical Assistance●

Regulatory Assistance●

Documents/ProductsWhile many of our services are provided at no charge, several of our products arefairly expensive to create, and we charge nominal fees to recover these costs.

Green and Profitable Training Series $75Printing with Alcohol Substitutes- GATF SS#20 $20Controlling Waste In Web Offset Printing(video)- GATF #4204V

$39

Chemistry For The Graphic Arts- GATF #1401 $60The Lithographers Manual- GATF #1407 $60Glossary of Printing Terms- GATF #1305 $60

Fax Back Service 1-888-USPNEACThe Fax Back Service makes fact sheets, case studies, and other documentsavailable via fax by calling our toll free number, 1-888-USPNEAC and accessingthe fax back information system.

What is PNEAC?: Environment and Printing: The Printers' National En...AC: The Environmental Information Website for the Printing Industry

http://www.pneac.org/whatis.html (2 of 3) [3/12/2000 2:19:40 PM]

Who is PNEAC for?

Compliance Assistance Providers Technical Assistance Providers Small BusinessAssistance Programs Small Business Development Centers Regulatory Agencies(Federal, State, Local) P2 Programs Industry Trade Associations Printers

What is PNEAC?: Environment and Printing: The Printers' National En...AC: The Environmental Information Website for the Printing Industry

http://www.pneac.org/whatis.html (2 of 3) [3/12/2000 2:19:40 PM]

To subscribe to either of these, go here or contact Wayne Pferdehirt at608-265-2361.

Toll Free Access Line1-888-USPNEACOur Toll Free number provides direct access to technical and complianceassistance professionals.

Listservs

PrinTech is a free listserv to promote discussion among technical assistanceproviders on P2 and compliance issues affecting printers. PrintReg is a listservsimilar to PrinTech, but focusing on regulatory issues facing printers.

V - 6

V-7

Printers’ National Environmental Assistance Center

FACT SHEETS and CASE STUDIES

PNEAC www.pneac.org

1-888-USPNEAC

PNEAC Fax-on-Demand FactsLine 1-888-USPNEAC

Index of Available Documents

Index

Name Number of Pages

1000

What is PNEAC?

3

1020

Federal Environmental Regulations Potentially Affecting the Printing Industry, EPA DfE (Unavailable by fax. Available from <http://www.epa.gov/opptintr/dfe/printing/fedregs/printreg.pdf> or from the Pollution Prevention Information Clearinghouse at (202) 260-1023 )

69

1040

Understanding Air Pollution Permits

7

1050

What are VOCs and Do Printing Related Materials Contain Them?

2

1130

What is a Hazardous Waste?

8

1160

Basic RCRA Recordkeeping Requirements For Printers

3

1200

How to Read and Use an MSDS for Environmental Purposes

6

1205

One Plan Complies With OSHA & EPA Emergency Response Requirements

6

1210

Basic OSHA Recordkeeping & Training Requirements Affecting Printers

7

1250

Printing Industry Manuals on Compliance, P2 & Processes

16

1420

Demystifying Environmental Management Systems, Jeff Adrian

3

1470

Pollution Prevention: Working with Suppliers, Montana, 6/96

2

1520

Pollution Prevention: Environmental Marketing, Montana, 6/96

2

1540

Energy Efficiency Program

2

1570

Managing Solvents and Wipes, EPA DfE

4

1600

Management of Solvents and Wipes in the Printing Industry

6

1620

Managing Solvents and Wipes, EPA DfE

4

1650

Options for Printers to Reduce Image Processing Costs by Minimizing Waste and Recovering Silver

5

PNEAC Fax-on-Demand FactsLine 888-USPNEAC Index of Available Documents p. 2 of 4

V-8

Index

Name

Number of Pages

1670

Code of Management Practice; Guide for Commercial Imaging, Silver Council, 4/97 (Unavailable by fax. Available from <http://www.silvercouncil.org/codes/commercmain.pdf>, or by calling 914-698-7603)

44

1680

Silver Recovery Systems And Waste Reduction in Photoprocessing. North Carolina

5

1800

Pollution Prevention: Facts About Paper, Montana, 6/96

6

1905

Profile of the Printing and Publishing Industry, EPA (Unavailable by fax. Available at <http://es.epa.gov/comply/sector/#print> Contact Ginger Gotliffe, EPA (202) 564-7072, E-mail: gotliffe.ginger@epamail.epa.gov )

117

1906

Printing Industry and Use Cluster Profile, EPA DfE (Unavailable by fax. Available at <http://www.epa.gov/opptintr/dfe/printing/usecluster/index.html > or from the Pollution Prevention Information Clearinghouse at (202) 260-1023 )

183

2000

Environmental Compliance Checklist for Lithographic Printers

4

2250

Pollution Prevention Checklist For Lithographic Printers

15

2300

Pollution Prevention: Self-Assessment Checklist, Montana, 6/96

6

2310

Pollution Prevention at Custom Print, EPA DfE

4

2315

Pollution Prevention at Custom Print, EPA DfE (en Espanol)

4

2320

Workplace Practices Make the Difference, EPA DfE

4

2325

Workplace Practices Make the Difference, EPA DfE (en Espanol)

4

2330

Book Printer Reduces Waste at the Source, MI DEQ

6

2450

Deciding to Go Digital, MI DEQ

2

2500

Pollution Prevention: Plate Developing, Montana, 6/96

3

2690

Substitute Blanket Washes: Making Them Work, EPA DfE

4

2695

Substitute Blanket Washes: Making Them Work, EPA DfE (en Espanol)

4

2710

Vegetable Ester Blanket Washes, EPA DfE

4

2715

Vegetable Ester Blanket Washes, EPA DfE (en Espanol)

4

2720

A Worksheet to Help You Choose a Better Wash, EPA DfE

6

2725

A Worksheet to Help You Choose a Better Wash, EPA DfE (en Espanol)

6

2730

Blanket Wash Solutions for Small Printers, EPA DfE

2

PNEAC Fax-on-Demand FactsLine 888-USPNEAC Index of Available Documents p. 3 of 4

V-9

Index

Name

Number of Pages

2740

CTSA Summary Booklet: Solutions for Lithographic Printers: An Evaluation of Substitute Blanket Washes (Unavailable by fax. Available from the Pollution Prevention Information Clearinghouse at (202) 260-1023. Available at <http://www.epa.gov/opptintr/dfe/lithography/lithbkst.pdf>)

33

2742

CTSA: Lithographic Blanket Washes (Unavailable by fax. Available from the Pollution Prevention Information Clearinghouse at (202) 260-1023. Available at <http://www.epa.gov/opptintr/dfe/lithography/ctsa/litho.pdf > )

447

2750

How to Reduce, Reuse and Recycle Lithographic Ink Wastes

6

2800

Pollution Prevention: Printing Inks, Montana, 6/96

5

2810

On-Site Waste Ink Recycling, EPA

7

2860

Emission Reduction in Waterless Printing Operations

3

2900

Pollution Prevention: Fountain Solution Solutions; Montana, 6/96

4

3250

Screen Printing Project Fact Sheet: Designing Solutions for Screen Printers, EPA DfE

2

3550

Improving on a Good Thing: Romo Reduces TRI Releases

5

3600

Technology Alternatives for Screen Reclamation, EPA DfE

4

3605

Technology Alternatives for Screen Reclamation, EPA DfE (en Espanol)

4

3610

Smarter, Safer Screen Reclamation; Alternative System Epsilon, EPA DfE

4

3615

Smarter, Safer Screen Reclamation; Alternative System Epsilon, EPA DfE (en Espanol)

4

3620

Smarter, Safer Screen Reclamation; Alternative System Chi, EPA DfE

4

3625

Smarter, Safer Screen Reclamation; Alternative System Chi, EPA DfE (en Espanol)

4

3630

Work Practice Alternatives for Screen Reclamation, EPA DfE

4

3635

Work Practice Alternatives for Screen Reclamation, EPA DfE (en Espanol)

4

3640

Reducing the Use of Reclamation Chemicals in Screen Printing, EPA DfE

4

3645

Reducing the Use of Reclamation Chemicals in Screen Printing, EPA DfE (en Espanol)

4

3650

Changing Equipment and Reducing Solvent Use in Screen Reclamation, EPA DfE

4

3655

Changing Equipment and Reducing Solvent Use in Screen Reclamation, EPA DfE (en Espanol)

4

3660

Innovations in Adhesives, Screen Cleaning and Screen Reclamation, EPA DfE

4

PNEAC Fax-on-Demand FactsLine 888-USPNEAC Index of Available Documents p. 4 of 4

V-10

Index

Name

Number of Pages

3665

Innovations in Adhesives, Screen Cleaning and Screen Reclamation, EPA DfE (en Espanol)

4

3670

Designing Solutions for Screen Printers: An Evaluation of Screen Reclamation Systems, EPA DfE (Unavailable by fax. Available from the Pollution Prevention Information Clearinghouse at (202) 260-1023. Also available from <http://www.epa.gov/opptintr/dfe/screenprinting/ctsa/scbook.pdf> )

58

3680

Cleaner Technologies Substitutes Assessment Executive Summary: Screen Reclamation, EPA DfE (Unavailable by fax. Available from the Pollution Prevention Information Clearinghouse at (202) 260-1023. Also available from <http://www.epa.gov/opptintr/dfe/screenprinting/ctsa/execsum.pdf> )

16

3690

Cleaner Technologies Substitutes Assessment: Screen Reclamation, EPA DfE (Unavailable by fax. Available from the Pollution Prevention Information Clearinghouse at (202) 260-1023. Also available from <http://www.epa.gov/opptintr/dfe/screenprinting/ctsa/index.html>

680

4300

Reducing VOCs in Flexography, EPA DfE

5

4305

Reducing VOCs in Flexography, EPA DfE (en Espanol)

5

4400

Environmental Management of Photopolymer Flexographic Plates

6

4500

Focusing on Flexo Inks, EPA DfE

2

4510 Learning from Three Companies that Reduced VOC Emissions, EPA DfE 4

4515 Learning from Three Companies that Reduced VOC Emissions, EPA DfE (en Espanol)

4

4520

Replacement of Hazardous Material in Wide Web Flexographic Printing Process, EPA

6

4530

Water and Ink Waste Reduction at F.C. Meyer Company, MA-OTA

2

4650

Anagram Saves Over $68,600 through Waste Reduction, MnTAP

4

4750

Reducing Film Scrap, MnTAP

3

5250

Environmental Research Brief: Waste Minimization Assessment for a Manufacturer of New and Reworked Rotogravure Printing Cylinders, EPA

6

5400

Environmental Research Brief: Waste Minimization Assessment for a Manufacturer of Labels and Flexible Packaging, EPA

8

5500

Environmental Research Brief: Waste Minimization Assessment for a Manufacturer of Gravure-Coated Metalized Paper and Metalized Film, EPA

5

9998

Index of available documents (this document)

4

V-11

FLEXOGRAPHIC TECHNICAL ASSOCIATION

900 MARCONI AVENUE RONKONKOMA, NY 11779

Phone: 631-737-6020

Fax: 631-737-6813

JOIN FTA! Reduced Rates on Seminars and Products Subscriptions to FLEXO® and FLEXO ESPAÑOL

® Magazines Technical and Environmental Assistance Awards Competitions SOME OF OUR EVENTS v National Environmental, Health and Safety Conference for the Graphic

Communications Industries – the EHS event for printers v Annual Forum and INFO*FLEX – the largest gathering of flexo printers which includes

seminars and tabletop exhibits SOME OF OUR PRODUCTS v Environmental Newsletter – a monthly newsletter sent to FTA members highlighting

the latest environmental issues v Flexography: Principles and Practices, 5th Edition – a six volume text which

includes a chapter on environmental, health and safety regulations v Environmental Glossary of Terms – a press pal which includes definitions for nearly

600 environmental terms and acronyms v P2 Finance for Flexographers – a software program to analyze cost of pollution

prevention and environmental compliance modifications v Inside Flexo, A Cleaner Run for the Money – a video of pollution prevention options

for flexo printers v Flexographic Image Reproduction Specifications and Tolerances (FIRST) –

guidelines, tutorials and data that can be used as communication and production tools v FLEXSYS™ Press Simulator – a computer simulation program designed to be used as

a training and diagnostic troubleshooting tool COMING SOON! v The Flexo Environment – a book encompassing environmental compliance and

pollution prevention issues Visit FTA on the Internet at www.flexography.org

For membership information, contact the Membership Department at membership@flexography.org or call 631-737-6020

V - 12

I n f o r m a t i o n E x c h a n g e We b P a g e

A Cooperative Projectbetween the

U.S. EnvironmentalProtection Agency

and the

Printing TradeAssociationsNationwide If you are a flexographic ink manufac-

turer or printer, you have probablyheard of DfE’s Flexographic InksPartnership. The goal of the Partnershipis to better understand the possibleenvironmental and health impacts ofink chemicals and to encourage the

innovation and use of cleaner, saferinks. To achieve these goals, thePartnership is developing a comprehen-sive technical report — FlexographicInk Options: A Cleaner TechnologiesSubstitutes Assessment (CTSA). Thisreport, soon to be released, is a com-parative evaluation of solvent-based,water-based, and UV-cured ink systemson wide-web film substrates. It assess-es the performance, cost, energy, andenvironmental and human healthaspects of 45 ink formulations.

The CTSA was developed to provideprinters and ink formulators withinformation that can help guide theirink choices and encourage them toconsider a variety of factors whenchoosing or evaluating ink systems orspecific formulations. In particular,judging inks based on only perfor-mance or cost leaves out very impor-tant information. Different formula-tions may pose different workerhealth and environmental concerns.Also, each printing facility operateswith a unique combination of cus-tomers, equipment, product specialty,and labor resources. Thus, only byworking together can printers andtheir suppliers make fully-informedink choices.

Similarly, the DfE Partnership recog-nizes that lessons learned by flexogra-phers in developing, selecting, andusing inks represent another important

Get Involved:Industry Contributions to Informed Ink Choices

April 2000

What’s in the Flexographic Inks CTSA?

The CTSA provides a wealth of information to help guide ink choices, withthe goal of enabling printers to be as efficient and as environmentallyresponsible as possible.

Chapter 3: Risk*

• Possible health concerns relevant to press-room workers and theirmanagement.

• Aquatic toxicity information that will be useful in the event of aninadvertent release to water.

Chapter 4: Performance

• Performance of each of the CTSA formulations on 18 different perfor-mance tests. Compares solvent-based and water-based formulations,and presents UV-cured formulations as an emerging technology.

Chapter 5: Cost

• Operating-cost assessment of the three flexographic ink technolo-gies. Includes material, labor, capital, and energy costs.

• Information on other costs to consider when evaluating an ink,including disposal, storage, and clean-up costs.

Chapter 6: Resource and Energy Conservation

• Energy requirements, and subsequent environmental implications,of ink drying and curing systems, corona treaters, and oxidizers.

Chapter 7: Additional Improvement Opportunities

• Options to increase efficiency and control environmental emissions inflexographic printing. Such choices may have a number of positivefinancial as well as health and environmental implications.

* Because the ink formulations studied in the CTSA may not be the formulationyou use, you should work with your supplier to get specific information on yourcurrent ink or the one you are considering.

source of guidance. Most of the innova-tive approaches to reducing environ-mental health and safety impacts of inksystems naturally come from industrymembers, like you.

DfE Seeks Lessons Learned

from Industry Leaders, Like You

In the next few months prior to therelease of the CTSA, the Partnershipseeks input from printers and ink for-mulators, like you, in providing infor-mation to supplement the CTSA andaid their colleagues in the innovationand use of cleaner, safer inks. To facil-itate this information exchange, theDfE Web site now features a newinteractive page designed to allowindustry members to share insights onoptimizing the ink-selection and useprocess. The format for informationexchange is organized into topic areassuch as performance, cost, and healthand environmental risk. For example,

in the performance topic area, samplequestions include:

• What are critical performanceattributes for wide-web film atyour facility?

• Share tips on optimizing perfor-mance for water-based inks.

• What information from ink formu-lators do you find most helpful inselecting and using inks?

The Web page is organized for easy accessand information exchange with opportuni-ties for formal and informal interaction.Your input, combined with informationfrom the CTSA, will help the DfEPartnership communicate practical, helpfulinformation to other flexographers.

See for yourself. Visit the flexographypage on DfE Web site atwww.epa.gov/dfe/flexography/flexography.html. We look forward toyour contribution.

The broad goal of the DfE Flexography project is to provide flexographers with information that canhelp them design an operation which is more environmentally sound, safer for workers, and morecost effective.

The partners of the DfE Flexography Project, in a voluntary cooperative effort, are evaluating threedifferent ink technologies: solvent-based, water-based, and UV-cured. Information is being gatheredon the performance, cost, and health and environmental risk implications of several inks withineach technology.

In addition to the Flexography Project, DfE is piloting environmental management systems with theScreen Printing and Graphic Imaging Association. DfE has also completed CTSA projects on screenprinting reclamation systems and lithographic blanket washes.

Mention of trade names, companies, or commercial products does not constitute endorsement orrecommendation of use by either the U.S. Environmental Protection Agency or other firms, organi-zations, or individuals who have participated in the preparation of this publication.

Partners in the DfE FlexographyProject include:

California Film Extruders and Converters Association(CFECA)Flexible Packaging Association(FPA)Flexographic TechnicalAssociation (FTA)Industrial Technology Institute(ITI)National Association of Printing Ink Manufacturers(NAPIM)Film and Bag Federation (FBF)RadTech International N.A.National Institute of Standardsand Technology (NIST)University of Tennessee (UT)U.S. Environmental ProtectionAgency (EPA)Western Michigan University(WMU)and individual printers andsuppliers.

About the Design for the Environment Flexography Project

InformationExchangeWeb Page:www.epa.gov/dfe/flexography/flexography.html

Wayne Pferdehirt

V - 15

Wayne Pferdehirt

V - 16

University of Wisconsin-Extension & The Solid and Hazardous Waste Education Center, January, 2000

V - 17

SUP-7.8 National Trade Associations - Partial Listing(Current as of December 1999)

National Coalition forAdvanced Manufacturing(NACFAM)202/216-2740202/289-7618 fax

National Association ofManufacturers202/637-3000202/637-3182 faxhttp://www.nam.org

Chemical Coaters AssociationHelpline800/9 COAT IT513/624-0601 faxhttp://www.finishing.com/ccai/index.html

CTC Hotline -- U.S. EPAControl Technology Center919/541-0800919/541-0242 faxhttp://www.epa.gov/earth100/records/a00130.html

Electronics ManufacturingProductivity Facility317/226-5601317/226-5615 faxhttp://www.indiana.edu/~rugs/ctrdir/empf.html

American Forest & PaperAssociation202/463-2700202/463-2471 faxhttp://205.197.9.134/

Association of GraphicsCommunications (AGC)212/279-2100212/279-5381 faxhttp://agcomm.org/

Business Forms ManagementAssociation503/227-3393503/274-7667 faxhttp://bfma.org

Graphic Arts TechnicalFoundation (GATF)412/741-6860800/910-GATF412/741-2311 faxhttp://www.gatf.com

Graphics Arts MarketingInformation Service/PIA703/519-8100http://printing.org/

International Association ofPrinting House Craftsmen800/466-4274612/560-1350 faxhttp://www.iaphc.org/

International Digital ImagingAssociation (IDIA)908/359-3924908/359-7619 faxhttp://www.idia.org

International PrepressAssociation612/896-1908612/896-0181 faxhttp://www.ipa.org

National Association forPrinting Leadership201/634-9600201/634-0324 faxhttp://www.napl.org

PrintImage International312/321-6886312/527-6789 faxhttp://www.printimage.org

Newspaper Association ofAmerica (NAA)703/902-1600703/620-4557http://www.naa.org

North American Graphic ArtsSuppliers Association(NAGASA)202/328-8441202/328-8513 faxhttp://nagasa.org/

NPES, The Association ForSuppliers of Printing andPublishing Technologies703/264-7200703/620-0994 faxhttp://www.npes.org

Screen Printing & GraphicImaging AssociationInternational703/385-1335703/273-0456 faxhttp://www.sgia.org

National Recycling Coalition703/683-9025703/683-9026 faxhttp://www.nrc-recycle.org/

V - 18

State Pollution Prevention Technical Assistance Programs

V - 19

Region 1 US EPA Region 1 Mark Mahoney JFK Federal Bldg (SPP) Boston, MA 02203 Ph: 617/ 918-1155 Fx: 617/565-4939 mahoney.mark@epa.gov Connecticut DEP Kim Trella 79 Elm St Hartford, CT 06106 Ph: 860/424-3234 Fx: 860/566-4924 Maine DEP Chris Rushton State House Station 17 Augusta, ME 04333 Ph: 207/287-7100 Fx: 207/287-2814 chris.rushton@state.me.us Massachusetts DEP- OTA Scott Fortier 100 Cambridge St. Rm 2109 Boston, MA 02202 Ph: 617/626-1090 Fx: 617/6261095 scott.fortier@state.ma.us

MA OTA - STEP Program Paul Richard 100 Cambridge St. Rm 2000 Boston, MA 02202 Ph: 617/626-1042 paul.richard@state.ma.us Toxics Use Reduction Institute Janet Clark One University Avenue Lowell, MA 01854 Ph: 508/934-3346 Fx: 508/934-3050 clarkjan@turi.org New Hampshire DES Stephanie D=Agostino 6 Hazen Drive Concord, NH 03301 Ph: 603/271-6398 Fx: 603/271-2867 s_dagostino@des.state.nh.us

Rhode Island DEM Richard Enander 235 Promenade St. Providence, RI 02908 Ph: 401/222-6822 Fx: 401/222-3810 Narragansett Bay Commission James McCaughey 235 Promenade St. Providence, RI 02908 Ph: 401/222-6680 Fx: 401/222-2584 ppr@narrabay.com Vermont ANR Gary Gulka 103 South Main St Waterbury, VT 05671 Ph: 802/241-3626 garyg@dec.anr.state.vt.us NEWMOA Terri Goldberg 129 Portland St, Suite 602 Boston, MA 02114 Ph: 617/367-8558 Fax: 617-367-0449 neppr@tiac.net Region 2 US EPA Region 2 Danielle Fuligni 290 Broadway (SPMMB) New York, NY 10007 Ph: 212/ 637-3584 Fx: 212/637-3771 fuligni.danielle@epa.gov New Jersey DEP Melinda Dower 401 E State St, PO Box 423 Trenton, NJ 08625 Ph: 609/292-1122 Fx: 609/777-1330 mdower@dep.state.nj.us NJ TAP Laura Battista 138 Warren St Newark, NJ 07102 Ph: 973/596-5864 Fx: 973/596-6367 battista@megahertz.njit.edu

New York DEC-P2 Unit Mary Werner 50 Wolf Rd Albany, NY 12233 Ph: 518/457-2553 Fx: 518/457-2570 mhwerner@gw.dec.state.ny.us Puerto Rico Environment Carlos Gonzales Ph: 809/765-7517 x381 Fx: 809/765-6853 Region 3 US EPA Region 3 Jeff Burke 1650 Arch St Philadelphia PA 19103 Ph: 215/814-2761 Fx: 215/814-2782 burke.jeff@epa.gov Delaware DNR Andrea Kreiner PO Box 1401 89 Kings Highway Dover, DE 19903 Ph: 302/739-3822 Fx: 302/739-6242 akreiner@dnrec.state.de.us MD Dept of Environment Laura Armstrong 2500 Broening Hwy Baltimore, MD 21224 Ph: 410/631-4119 Fx: 410/631-4477 larmstrong@mde.state.md.us PA Dept of Environment Meredith Hill PO Box 2063 Harrisburg, PA 17105 Ph: 717/783-8727 Fx: 717/787-8470 hill.meredith@dep.state.pa.us PA Technical Assistance Jack Gido 110 Barbara Bldg II University Park, PA 16802 Ph: 814/865-0427 Fx: 814/865-5909

State Pollution Prevention Technical Assistance Programs p. 2 of 5

V - 20

Virginia DEQ Sharon K. Baxter PO Box 10009 Richmond, VA 23240 Ph: 804/698-4344 Fx: 804/698-4277 skbaxter@deq.state.va.us West Virginia DEP-OWR Leroy Gilbert HC 61 Box 384 Danese, WV 25831 Ph: 304/484-6269 Fx: 304/558-2780 llgilbert@hotmail.com Region 4 US EPA Region 4 Dan Ahern 61 Forsyth St SW Atlanta, GA 30303 Ph: 404/ 562-9028 Fx: 404/562-9066 ahern.dan@epa.gov Alabama DEM - P2 Unit Gary Ellis PO Box 301463 Montgomery, AL 36130 Ph: 334/213-4303 Florida DEP - P2 Program Julie Abcarian 2600 Blair Stone Road Tallahassee. FL 32399 Ph: 850/488-0300 Fx: 850/921-8061 julie.abcarian@dep.state.fl.us Georgia DNR- P2AD Jancie Hatcher 7 MLK Jr. Dr. Suite 450 Atlanta. GA 30334 Ph: 404/651-5120 Fx: 404/651-5130 p2ad@ix.netcom.com Kentucky DEP Vicki Pettus 14 Reilly Road Frankfort, KY 40601 Ph: 502/564-6716

Kentucky P2 Center Cam Metcalf 420 Lutz Hall Louisville, KY 40292 Ph: 502/852-0965 Fx: 502/852-0964 jcmetc01@gwise.louisville.eud Mississippi DEQ Thomas E. Whitten PO Box 20305 Jackson, MS 39289 Ph: 601/961-5241 Fx: 601/961-5349 North Carolina DEHNR Gary Hunt PO Box 29569 Raleigh, NC 27626 Ph: 919/715-6500 Fx: 919/715-6794 gary_hunt@owr.ehnr.state.nc.us South Carolina DHEC Robert Burgess 2600 Bull St Columbia, SC 29208 Ph: 803/898-3971 burgesre@columb30.dhec.state.sc.us Tennessee DEC Angie Pitcock 401 Church St Nashville, TN 37243 Ph: 615/532-0760 Region 5 US EPA Region 5 Phil Kaplan 77 West Jackson Blvd Chicago, IL 60604 Ph: 312/353-4669 Fx: 312/353-4788 kaplan.phil@epa.gov Illinois EPA Keri Luly 1021 N Grand Ave. East Springfield, IL 62794 Ph: 217/524-1846 Fx: 217/557-2125 epa8604@epa.state.il.us

Illinois Waste Mgmt Tim Lindsey One East Hazelwood Dr. Champaign, IL 61820 Ph: 217/333-8955 Fx: 217/333-8944 tlindsey@wmrc.hazard.uiuc.edu Indiana DEM John Chavez 100 N Senate Ave PO6015 Indianapolis, IN 46206 Ph: 317/233-6658 Fx: 317/233-5627 jchavez@dem.state.in.us IN Clean Manufacturing Tech & Safe Materials Institute Alice Smith 2655 Yeager Rd. Suite 103 West Lafayette, IN 47906 Ph: 765/463-4749 Fx: 765/463-3795 alice@ce-ecn.purdue.edu Michigan DEQ Marcia Horan PO Box 30273 Lansing, MI 48909 Ph: 517/373-9122 Fx: 517/335-4729 horanm@state.mi.us Minnesota (MN TAP) Cindy McComas 1313 5th St SW Suite 207 Minneapolis, MN 55414 Ph: 612/627-4556 Fx: 612/627-4769 mccom003@tc.umn.edu MN Pollution Control Agency Al Innes 520 Lafayette Road North St. Paul, MN 55155 Ph: 651/296-7330 Fx: 651/282-6247 alister.innes@pca.state.mn.us MN Office of Environmental Assistance Phillip Muessig 520 Lafayette Road North St. Paul, MN 55155 Ph: 651/215-0204 Fx: 651/215-0246 phillip.muessig@moea.state.mn.us

State Pollution Prevention Technical Assistance Programs p. 3 of 5

V - 21

MN Technology Inc. Kevin O'Donnell 111 3rd Ave. South Minneapolis, MN 55401 Ph: 612/672-3446 Fx: 612/497-8475 kodonnell@mail.mntech.org Ohio EPA Michael Kelley P.O. Box 1049 Columbus, OH 43216-1049 Ph: 614/644-3469 Fx: 614/728-2807 michael.kelley@epa.state.oh.us University of Wisconsin Rick Grote 610 Langdon St, Rm 530 Madison, WI 53703 Ph: 608/265-3055 Fx: 608/262-6250 grote@wmep.org National Farmstead Program Liz Nevers B142 Steenbock Library Madison WI 53706 Ph: 608/265-2774 Fx: 608/265-2775 enevers@facstaff.wisc.edu Wisconsin DNR Lynn Persson PO Box 7921 Madison, WI 53707 Ph: 608/267-3763 Fx: 608/267-0496 Region 6 US EPA Region 6 Eli Martinez 1455 Ross Ave Suite 1200 Dallas, TX 75202 Ph: 214/665-2119 Fx: 214/665-7446 martinez.eli@epa.gov Arkansas IDC Alford Drinkwater One Capitol Mall Little Rock, AR 72201 Ph: 501/682-7325 Fx: 501/682-2703 adrinkwater@aedc/state.ar.us

Louisiana DEQ Gary Johnson PO Box 82263 Baton Rouge, LA 70884 Ph: 504/765-0739 Fx: 504/765-0742 gary_j@deq.state.la.us Louisiana TAP University of New Orleans New Orleans, LA Ph: 504/286-6305 Fax: 504/286-5586 New Mexico ED Patricia Gallagher 1190 St Framcis Dr Sante Fe, NM 87502 Ph: 505/827-0677 Fx: 505/827-2846 pat_gallagher@nmenv.state.nm.us Oklahoma DEQ Dianne Wilkins 707 N Robinson PO Box 1677 Oklahoma City, OK 73101 Ph: 405/702-6116 Fx: 405/702-6100 dianne.wilkins@deqmail.state.ok.us Texas NRCC Kathey Ferland PO Box 13087 - MC112 Austin, TX 78711 Ph: 512/239-3177 Fx: 512/239-3165 kferland@tnrcc.state.tx.us Gulf Coast Hazardous Substance Research Margaret Aycock PO Box 10671 Beaumont, TX 77710 Ph: 409/880-8897 Fx: 409/880-1837 aycock@ALMARK.lamar.edu TX Manuf. Assistance Center Conrad Soltero Univ. of TX-El Paso 500 W University , Burges El Paso, TX 75202 Ph: 915/747-5930 Fx: 915/747-5437 conrad@utep.edu

Lower Colorado River Authority Mark Johnson PO Box 220 Austin, TX 78703 Ph: 512/473-3200 Fx: 512/473-3579 mark.johnson@lcra.org Region 7 US EPA Region 7 Marc Matthews 726 Minnesota Ave (ARTD/TSPP) Kansas City, KS 66101 Ph: 913/551-7517 Fx: 913/551-7065 matthews.marc@epa.gov Iowa DNR Jeff Fiagle 502 E. 9th St Des Moines, IA 50319 Ph: 515/281-5353 Fx: 515/281-8895 jfiagle@max.state.ia.us Iowa Waste Reduction Center Christine Twait 1005 Technology Parkway Cedar Fall, IA 50613 Ph: 319/273-8905 Fax: 319/268-3733 twait@uni.edu IOWA DED Linda King Small Business Liasion Ph: 515/242-4761 Fx: 515-242-6338

State Pollution Prevention Technical Assistance Programs p. 4 of 5

V - 22

Kansas DHE Janet Neff Bldg. 283 , Forbes Field Topeka, KS 66620 Ph: 785/296-0669 Fx: 785/296-3266 jneff@kdhe.state.ks.us KSU - P2 Institute Sherry Davis 133 Ward Hall Manhatten, KS 66506 Ph: 785/532-6501 Fx: 785/532-6952 sbd@.ksa.edu Missouri DNR - TAP David Goggins PO Box 176 Jefferson City, MO 65102 Ph: 573/526-6627 Fx: 573/526-5808 nrgoggd@mail.state.mo.us NE Business Development Center Rick Yoder 1135 M St, Suite 200 Lincoln, NE 68508 Ph: 402/472-1183 Fx: 402/472-3363 ryoder@unomaha.edu Nebraska DEQ, P2 Office Ben Hammerschmidt PO Box 98922 Lincoln, NE 68509 Ph: 402/471-6988 Fax: 402/471-2909 deq219@mail.deq.state.ne.us MAMTC Anne Brown 801 Campus Dr Garden City, KS 67846 Ph: 316/276-9505 Fx: 316/276-9523 abrown@midusa.net

Region 8 US EPA Region 8 John Larson 999 18th St, Suite 500 Denver, CO 80202 Ph: 303/312-6030 Fx: 303/312-6741 larson.john@epa.gov Colorado DHE Parry Burnap 4300 Cherry Creek Dr Denver, CO 80222 Ph: 303/692-3009 Fx: 303/782-4969 parry.burnap@state.co.us Montana P2 Program Michael P. Vogel 109 Taylor Hall Bozeman, MT 59717 Ph: 406/994-3451 Fx: 406/994-5417 acxmv@montana.edu North Dakota Dept of Health Jeffrey L. Burgess PO Box 5520 Bismarck, ND 58506-5520 Ph: 701/328-5150 Fx: 701/328-5200 jburgess@state.nd.us South Dakota DENR Dennis Clarke 523 E Capitol Ave Pierre, SD 57501-3151 Ph: 605/773-4254 Fx: 605/773-4068 Utah DEQ Sonja Wallace 168 N 1950 West Salt Lake City, UT 84114 Ph: 801/536-4477 Fx: 801/536-0061 swallace.deq.state.ut.us Wyoming DEQ Patricia Jordan 122 West 25th Cheyenne, WY 82002 Ph: 307/777-6105 Fx: 307/777-5973 pjorda@missc.state.wy.us

Region 9 US EPA Region 9 Eileen Sheehan 75 Hawthorn St (WST-1-1) San Francisco, CA 94105 Ph: 415/744-2190 Fx: 415/744-1680 wilson.bill@epa.gov Arizonia DEQ Jacquelione Maye 3033 North Central Ave Phoenix, AZ 85012 Ph: 602/207-4607 Fax: 602/207-2302 maye.jacqueline@ev.state.az.us California EPA Terri Cronin 8800 Cal Center Dr Sacramento, CA 95826 California Energy Commission David Jones 1519 9th St Sacramento, CA 95814 Ph: 916/654-4554 CA Toxic Substance Control Kathy Barwick PO Box 806 Sacramento, CA 95812 Ph: 916/323-9560 Fx: 916/327-4494 UCLA P2 Center Billy Romain Ph: 310/825-2654 Fx: 310/206-3906 Hawaii Department of Health Marlyn Aguilar 919 Ala Moana Blvd, Rm 212 Honolulu, HI 96814 Ph: 808/586-7496 Fx: 808/586-7509 maguilar@eha.health.state.hi.us

State Pollution Prevention Technical Assistance Programs p. 5 of 5

V - 23

Nevada Small Business Development Center Kevin Dick 6100 Neil Rd. Suite 400 Reno, NV 89511 Ph: 775/689-6677 Fx: 775/689-6689 dick@unr.edu Region 10 US EPA Region 10 Carolyn Gangmark 1200 Sixth Ave (01-085) Seattle, WA 98101 Ph: 206/553-4072 Fx: 206/553-8338 gangmark.carolyn@epa.gov Alaska DEC Marianne See 555 Cordova St Anchorage, AK 99501 Ph: 907/269-7586 Fx: 907/269-7600 msee@envircon.state.ak.us

Idaho DEQ Katie Sewell 450 West State St Boise, ID 83720 Ph: 208/373-0465 Fx: 208/373-0169 ksewell@deq.state.id.us Oregon DEQ Marianne Fitzgerald 811 SW Sixth St Portland, OR 97204 Ph: 503/229-5946 Fax: 503/229-5850 fitzgerald.marianne@deq.state.or.us Washington DEC Lynn Helbrecht PO Box 47600 Olympia, WA 98504 Ph: 360/407-6760 Fx: 360/407-6715 lhel461@ecy.wa.gov

Pacific Northwest P2 Resource Center Madeline Sten 1326 Fifth Ave., Suite 650 Seattle, WA 98101 Ph: 206/223-1151 Fx: 206/223-1165 msten@pprc.org Washington State University Carol Reisenberg 501 Johnson Tower Pullman, WA 99164 Ph: 509/335-1576 Fx: 509/335-0949 andersol@wsuvml.csc.wsu.edu

This list is updated and maintained on the EPA P2 Home Page www.epa.gov/oppintr/p2/p2statecontacts.htm

11/99

V - 24

Clean Air Act Small Business Ombudsmen and Technical Assistance Directors

V - 25

STATE

OMBUDSMAN

PHONE

TECH. ASST. DIR.

PHONE

AL

Blake Roper

(334) 394-4335 (N) (800) 533-2336

Mike Sherman

(334) 271-7873 (N) (800) 533-2336

AK

Tom Chapple

(907) 269-7686 (S) (800) 510-2332

AZ

Gregory Workman

(602) 207-4337 (S) (800) 234-5677, x 4337

AZ

MARICOPA COUNTY

Richard Polito

(602) 506-5102

AR

Joe Bob Garner

(501)682-0866

CA

Kathleen Tschogl

(916) 323-6791 (S) (800) 272-4572

Peter Venturini

(916) 445-0650 (S) (800) 272-4572

CA

South Coast AQMD

La Ronda Bowen

(909) 396-3235 (S)(800)388-2121

Larry Kolczak

(909) 396-3215 (S)(800)388-2121

CO

Cathy Heald

(303) 692-2034 (S) (800) 886-7689

Nick Melliadis

(303) 692-3175 (N) (800) 333-7798

CT

Tracy Babbidge

(860) 424-3382 (S) (800) 760-7036

DE

To be Announced

(302) 739-6400

DC

Sandra Handon

(202) 535-1722

Olivia Achuko

(202) 535-2997

FL

Elsa Bishop

(850) 414-8399 (S) 800-722-7457

Bruce Thomas

(850) 921-7744 (S) (800) 722-7457

GA

Marvin Lowry

(404) 362-2656

Anita Dorsey-Word

(404) 362-4842

HI

Anthony Ching

(808) 586-4527

Robert Tam

(808) 586-4200

ID

Sally Tarowski

(208) 373-0472

IL

Don Squires

(217) 785-1625 (S) (888) 372-1996

Mark Enstrom

(217) 524-0169 (S) (800) 252-3998

IA

Linda King

(N) (515) 242-4761 (S) (800) 358-5510

John Konefes

(319) 273-8905 (S) (800) 422-3109

IN

Erika Seydel-Cheney

(317) 232-8598 (S) (800) 451-6027

Cheri Storms

(317) 233-1041 (S) (800) 451-6027

KS

Janet Neff

(785) 296-0669 (N) (800) 357-6087

Jean Waters

(785) 532-4698 (N) (800) 578-8898

KY

Rose Marie Wilmoth

(502) 564-2150 X128 (N) (800) 926-8111

Gregory Copley

(606) 257-1131 (N) (800) 562-2327

LA

Jim Friloux

(225) 765-0735 (S) (800) 259-2890

Dick Lehr

(225) 765-2453 (S) (800) 259-2890

MA

Terry Goldberg

(617) 367-8558 X 302

Clean Air Act Small Business Ombudsmen and Technical Assistance Directors p. 2 of 3

V - 26

STATE OMBUDSMAN

PHONE

TECH. ASST. DIR.

PHONE

MD

Don Jackson

(410) 631-3165 (S) (800) 633-6101, X 3772

Andrew Gosden

410-631-4158 (S) ( 800) 633- 6101,x4158

ME

Ron Dyer

(207) 287-4152 (S) (800) 789-9802

Brian Kavanah

(207) 287-6188 (S) (800) 789-9802

MI

Dana Cole

(517) 241-3518

Dave Fiedler

(517) 373-0607 (N) (800) 662-9278

MN

Charlie Kennedy

(651) 297-8615 (S) (800) 985-4247

Troy Johnson

(651) 296-7767 (S) (800)657-3938

MO

Angie Heffner

(573) 751-3222 (S) (800)361-4827

Byron Shaw

(573) 526-6627 (N) (800) 361-4827

MS

Jesse Thompson

(601) 961-5167 (N) (800) 725-6112

Randy Wolfe

(601)961-5166 (N) (800)725-6112

MT

Karen Ekstrom

(406) 444-2960 (N) (800) 433-8773

Warren Norton

(406) 444-2960 (N) (800) 433-8773

NE

Dan Eddinger

(402) 471-3413

NV

Marcia Manley

(775) 687-4670, x3162 (S) (800) 992-0900

Janet Goodman

(775) 687-4670, x3164

NH

Rudolph Cartier

(603) 271-1379

Rudolph Cartier

(603) 271-1379

NJ

Lauren Moore

(609) 292-3863 (N) (800) 643-6090

Chuck McCarty

(609) 292-5565

NM

Robert Horwitz

(505) 827-9685 (N) (800) 810-7227

Cecilia Williams

(505) 827-0042 (N) (800) 810-7227

NY

Tria Case

(212) 803-2280 (N) (800) 782-8369

Marian J. Mudar, Ph.d

(518) 457-9135 (S) (800) 780-7227

NC

Edythe McKinney

(919) 733-0823 (N) (800) 829-4841

Karen Davis

(919) 733-1267 (N) 800-829-4841

ND

Jeff Burgess

(701) 328-5153 (S) (800) 755-1625

Tom Bachman

(701) 328-5188 (S) (800) 755-1625

OH

Mark Shanahan

(614) 728-3540 (S) (800) 225-5051

Rick Carleski

(614) 728-1742

OK

Steve Thompson

(405) 702-7100

Alwin Ning

(405) 702-6100

OR

Paul Burnet

(503) 229-5776 (800) 452-4011 (S)

Jill Inahara

(503) 229-6147 (S) (800) 452-4011

Clean Air Act Small Business Ombudsmen and Technical Assistance Directors p. 3 of 3

V - 27

STATE OMBUDSMAN

PHONE

TECH. ASST. DIR.

PHONE

PA

Greg Czarnecki

(717) 772-8951

Cecily Beall

(215) 656-8709 (N) (800) 722-4743

PR

Tomas DeLeon

(787) 724-1451

Maria Rivera

(787) 767-8025 X296

RI

Pam Annarummo

(401) 222-6822 X7204 (S) (800) 253-2674

SC

Phyllis Copeland

(803) 898-3997 (N) (800) 819-9001

Natalie M. Loquist

(803) 898-3957 (N) (800) 819-9001

SD

Joe Nadenicek

(605) 773-3836 (S) (800) 438-3367

Bryan Gustafson

(605) 773-7171 (S) (800) 438-3367

TN

Ernest Blankenship

(615) 532-6262 (N) 800-734-3619

Linda Sadler

(615) 532-8012 (N) (800) 734-3619

TX

Israel Anderson

(512) 239-5319 (N) (800) 447-2827

Tamra Shae-Oatman

(512) 239-1066 (N) (800) 447-2827

UT

Stephanie Bernkopf

(801) 536-4479 (N) (800)458-0145

Ron Reece

(801) 536-4091 (N) (800) 270-4440

VT

Judy Mirro

(802) 241-3745 (S) (800) 974-9559

VA

John Daniel

(804) 698-4311 (S) (800) 592-5482

Richard Rasmussen

(804) 698-4394 (S) (800) 592-5482

VI

Marylyn A. Stapleton

(340) 777-4577,x228

Marylyn A. Stapleton

(340) 777-4577,x228

WA

Leighton Pratt

(360) 407-7018

Bernard Brady

(360) 407-6803

WV

Fred Durham

(304) 558-1217 (S) (800) 982-2474

WI

Hampton Rothwell

(608) 267-0313 (N) (800) 435-7287

Pam Christenson

(608) 267-9214 (N) (800) 435-7287

WY

Dan Clark

(307) 777-7388

Charles Raffelson

(307) 777-7347

Note: (S) = State (N) = National

V - 28

University of Wisconsin-Extension & The Solid and Hazardous Waste Education Center, January, 2000

V - 29

SUP-1.0 National Small Business Environmental ResourcesQuick Reference List

Federal Hotlines

Chemical Information: ChemTrec ChemicalReferral Center (Chemical ManufacturersAssociation)9 am - 5 pm EST, M-F800/262-8200800/424-9346http://www.cmahq.com

Chemical Safety: Emergency Planning andCommunity Right-to-Know Act (EPCRA)9 am - 6 pm EST, M-F800/535-0202800/424-9346http://www.epa.gov/epaoswer/hotline

Groundwater/Stormwater: U.S. EPA Office ofWater Resource Center202/260-778624-hour voice mailhttp://www.epa.gov/watrhome

Ozone Depleting Chemicals: Stratospheric Ozone(Clean Air Act -CAA)10 am - 4 pm EST, M-F800/296-1996 http://www.epa.gov/ozone

Pesticides: National PesticideTelecommunications Network6:30 am - 4:30 pm PST, M-F800/858-7378

Transportation: Hazardous Materials (U.S.DOT)9 am - 5 pm EST, M-F202/366-4488800/467-4922http://hazmat.dot.gov/

Underground Storage Tanks (USTs)9 am - 6 pm EST, M-F800/424-9346http://www.epa.gov/epaoswer/hotline

Water: Safe Drinking Water9 am - 5:30 pm EST, M-F800/426-4791http://www.epa.gov/safewater

Pollution Prevention: U.S. EPA InformationClearinghouse (PPIC)8 am - 4 pm EST, M-F202/260-102324-hour voice mailhttp://www.epa.gov/earth100

Small Business Clearinghouse: U.S. EPAOmbudsman8 am - 4 pm EST, M-F800/368-588824-hour voice mailhttp://www.epa.gov/sbo

Solid & Hazardous Waste: (RCRA)9 am - 6 pm EST, M-F800/424-9346http://www.epa.gov/epaoswer/hotline

Spill Response: National Response Center (U.S.Coast Guard)24 Hours800/424-8802http://www.epa.gov/superfund/programs/er/nrs/nrsnrc.htm

Superfund (CERCLA)9 am - 6 pm EST, M-F800/424-9346http://www.epa.gov/epaoswer/hotline

Toxic Substances: Toxic Substances Control Act(TSCA) and Asbestos8:30 am - 5 pm EST, M-F202/554-1404http://www.epa.gov/opptintr/opptloc.htm