as PDF

COMPLIANCE
RESOURCES FOR THE
PRINTING INDUSTRY
Sustainability Webinar Series hosted by
the Kansas Small Business
Environmental Assistance Program
Paid for, in part, by the Kansas Department of Health and Environment (KDHE)
Webinar Series Logistics
 All attendees should mute their phone lines by pressing *6. Please
keep your lines muted during the Webinar to prevent background
noise.
 Trouble hearing? If unable to adjust your computer volume, please
use your telephone. If you have phone line difficulties, you can
contact the operator at 785-532-7000.
 30-40 minute presentation followed by 5-10 minute Q&A period.
 Questions? Type in long text box at the bottom right of the screen
and press enter. Questions will be compiled and answered at end
of presentation.
 Presentation and questions/answers will be archived. Access
instructions and survey will be sent by e-mail.
2
Webinar Series Collaboration
 Kansas Small Business Environmental Assistance Program (SBEAP)
 Nancy J. Larson, Director
 E. Jean Underwood, P2 Specialist
 Leading Printing Industry Trade Associations
 Printing Industries of America (PIA)
 Gary Jones, Assistant Vice-President, EHS Affairs
 Specialty Graphic Imaging Association (SGIA)
 Marci Kinter, Vice-President, Government and Business Information
 Ashley Arneson, Government and Business Information Assistant
 Printing and Imaging Association of MidAmerica (PIA MidAmerica)
 B.J. Irvin, Director of Education and Technology
 Flexographic Technical Association (FTA)
 Doreen Monteleone, Director of Membership, EHS and Special Projects
 Sustainable Green Printing Partnership (SGP)-Certified Printer
 Minuteman Press, Lawrence, Kansas
 Dee Bisel, Owner
 KDHE air quality partners
3
Webinar Series Schedule
 May 3: Available resources to help confirm your regulatory status
 Nancy J. Larson/E. Jean Underwood (Kansas SBEAP)
 B.J. Irvin (PIA MidAmerica)
 May 10: Reducing your solvent-related operating costs
 Gary Jones (PIA)
 Marci Kinter (SGIA)
 May 17: Sustainable green printing to help increase your business
 Dee Bisel (Minuteman Press)
 Doreen Monteleone (FTA)
 Sign up at www.sbeap.org
4
Overview
 What is Kansas SBEAP?
 Air Emissions of Concern
 Confirming Compliance Status
 When is an Air Permit Needed?
 Waste Management
 Wastewater and Stormwater
 Pollution Prevention Opportunities
 Reducing Solvent Emissions
 Printing and Imaging Association of MidAmerica (PIA MidAmerica)
 B.J. Irvin, Director of Education and Technology
 Questions?
5
Kansas State
University
What
is
Kansas
SBEAP?
College of
Engineering
Engineering
Extension
Pollution
Prevention
Institute
Small Business
Environmental
Assistance
Program
6
Kansas SBEAP at a Glance
 Environmental compliance assistance (air-quality focused)
 Multimedia (air, waste and some water) and other
 Free to small- and medium-sized businesses (KDHE funded)
 Confidential
 Staff located throughout Kansas
 Contact information
 Web site:
 Hotline:
 E-mail:
www.sbeap.org
800-578-8898
[email protected]
7
Types of SBEAP Assistance
 Environmental hotline (800-578-8898)
 On-site visits
 Host regulatory or industry-specific webinars/workshops
 Publications (hard copy or electronic)
 Fact sheets
 Manuals
 Web-based tools and training
at: www.sbeap.org
 Poll question
8
Print Operations
 Pre-press
 Press
 Flexography
 Gravure
 Lithography
 Screen printing
 Post-press and finishing
9
Air Emissions of Concern
 Likely
 Volatile organic compounds (VOCs)
 Hazardous air pollutants (HAPs)
 Other possible
 Nitrogen oxides (NOx)
 Sulfur oxides (SOx)
 Particulate matter (PM2.5 and PM10)
 Carbon monoxide (CO)
 Lead (Pb)
10
VOC Emission Sources
 Sources
 Inks
 Alcohol-based fountain solutions
 Coatings
 Cleaning solvents
 Adhesives
 Aerosols
 Miscellaneous
 Examples
 Mineral spirits
 Methyl ethyl ketone (MEK)
 Acetone
 Cyclohexane
 Xylene(s)
11
Hazardous Air Pollutants (HAPs)
 Sources
 Largely same as for VOCs
 Examples
 Xylene(s)
 Ethyl benzene
 MEK
 Methyl isobutyl ketone (MIK)
 Methanol
 Ethylene glycol
 Certain glycol ethers
 Complete list at www.epa.gov/ttn/atw/188polls.html
12
Confirming Compliance Status – Air Emissions
 Identify all emission sources and emissions
 Annual facility-wide emissions inventory
 Calculate VOC, HAP, and other emissions
 Consider both actual and potential emissions
 Additional non-attainment area restrictions
 Two types air permits - construction and operating
 Poll question
Product Information
Product Name
Description
or part #
BARSOL A-2840
solvent
BARSOL A-2867
solvent
SOLVENT (MAGIESOL 47)
solvent
STARKOTE AQ-18
coating
SYNTEX FD FR ND YELLOW
SYNTEX FR PROC MAGENTA
CUMULATIVE INK (High VOC)
ink
CUMULATIVE INK (Low VOC)
ink
Annual usage
Product Density *
VOC content **
PM content
gallons
lb/gal
weight %
weight %
purchase records
from MSDS
from MSDS
calculated
HAP Content - Look up using Product MSDSs *
1330207
98828
0
100414
Xylene
Ethyl benzene
Cumene
Glycol ethers
wt%
wt%
wt%
0.0
1.17
0.59
5.00
0.0
0.60
0.38
9.00
1600.00
6.76
100.0
110.00
6.00
100.0
2.00
6.80
100.0
0.0
7150.00
8.67
1.2
98.9
High VOC - example
9.20
3.8
96.2
1.00
low VOC - example
8.89
4.1
95.9
1.01
3712.00
9.00
8.0
92.0
1238.00
9.00
4.0
wt%
0.15
96.0
100.0
100.0
Note: Instead of entering data for
individual inks, SBEAP estimated
two generalized categories of high
and low VOC inks at a 75/25% split.
100.0
100.0
100.0
100.0
100.0
100.0
13
Confirming Compliance Status – Calculation
 How do I calculate Potential To Emit or PTE?
 PTE formula
Max emission rate in lbs/hr x 8760 hrs/yr = PTE (tons per year)
2000 lbs/ton
 Use spreadsheet tools at www.sbeap.org/aqrules
14
When is an Air Operating Permit Needed?
 Operating permit required when annual potential to emit (PTE) exceeds
 100 tons or more of VOCs (or other criteria pollutants)
 25 tons or more of any combination of HAPs, or
 10 tons or more of a single HAP
 Depending on your PTE you may trigger different permits
 Class I operating permit
 Class II operating permit (willing to take operating or material limits to maintain
actual emissions below the above limits)
 Class II permit-by-rule regulation




Limit purchase or use of evaporative solvents containing VOCs, HAPs, or both
Materials purchased or used contain less than 90 tons total VOCs
Materials purchased or used contain less than 22.5 tons total combination HAPs
Materials purchased or used contain less than 9 tons total any single HAP
 Refer to www.sbeap.org/publications/solventuser.pdf
 Poll question
15
Air Construction Permits and RACT Rule
 Air Construction Permits – may be needed if adding new
equipment
 RACT rule – special rule for Kansas City area industries, like
printers that use solvents to clean metals
 Limits the vapor pressure to 1 mm Hg at 68 degrees F for all solvents used
or sold for cold-cleaning
 Applies to all printers except certain Class I facilities that may already be
under stricter rules
 SBEAP resource at
http://www.sbeap.org/publications/smell_of_success.pdf
 Poll question
16
Waste Management
 Determine which of your wastes are hazardous, and document how
determination made (e.g., process knowledge or laboratory
analysis)
 Follow four steps outlined in the guidance document found at
www.kdheks.gov/waste/techguide/hw-2011-G1.pdf
 Maintain on file
 Update annually
17
Waste Management
 Determine your hazardous waste
generator classification




CESQG
KSQG
SQG
LQG
 On-line Kansas Hazardous Waste
Handler’s training at
www.sbeap.org
http://www.kdheks.gov/waste/forms/hazwaste/gen7
00-HWGenHandbook2011.pdf
18
Waste Management – Rags
 Disposable rags
 Rags contaminated with characteristic- or listed-solvents cannot be air
dried before putting in a container
 Properly label hazardous waste storage drums “Hazardous Waste”
 D001 or F003 rags that contain no “free liquid” are not hazardous waste
 http://www.kdheks.gov/waste/techguide/HW-1995-G2.pdf
 Commercially laundered
 Spent cleaning rags laundered at a commercial facility do not count
towards monthly hazardous waste generation rate
 Manage spent cleaning rags in closed-lid container labeled “Used Rags for
Recycle”
 Non-hazardous waste disposal and recycling
 Poll question
19
Wastewater and Stormwater
 Spent fixer management
 Silver recovery for recycle or reuse
 Discharge industrial process wastewater only with permission




Local sewer plant or publically-owned treatment works (POTW)
National Pollutant Discharge Elimination System (NPDES) permit from KDHE
Do not discharge to septic tank system
May require on-site pretreatment before discharge
 File Notice of Intent (NOI) for stormwater runoff
 May need spill prevention control and countermeasure (SPCC) plan
20
Pollution Prevention Opportunities
 Explore alternative press cleaning methods, materials, and timing
 Find a blanket wash alternative with lower vapor pressure
 Consider an automatic blanket cleaner retrofit for presses
 Establish an inventory control system to track solvent use
 Use roller wash-up blades and ink blades to remove residual ink
 Improve operating practices for efficient press cleaning
 Use plunger-can solvent dispensers to control amount of solvent
 Eliminate open buckets of cleaning solvent at presses
21
Reducing Solvent Emissions
 Change the material
 Use less hazardous materials (characteristic and quantity)
 Change the practice
 Operating and maintenance procedures
 Management practices
 Waste stream segregation
 Production scheduling
 Inventory control
 Personnel training
 Change the technology
 Layout changes to improve workflow
 Increased automation
 Improved operating conditions
22
Flexographic Technical Association
www.flexography.org
 1300 flexographic printers and converters, prepress providers,
suppliers, consumer products companies and educators –
primarily in US & Canada (established 1958)
 In-Plant EHS Self-Assessment for Flexographic Printers –
Checklist & Workbook
 Flexography Principles & Practices 6 th Ed. (July 1 release) –
Textbook
 Sustainable FLEXO & FLEXO Magazine – Articles on carbon
footprinting, sustainability and technology
 LinkedIn Site – Sustainable Green Printing for Flexo Printers
 Sustainability Committee – Various Projects
 Doreen Monteleone [email protected]
 631-737-6020 ext. 30
PIA MIDAMERICA
ENVIRONMENTAL, HEALTH & SAFETY MEMBER
RESOURCES

Print Industry Experts


Local Expert Consults with extensive EHS
backgrounds specializing in the Printing Industry
Contact our Offices at 800-788-2040 or
visit our website at www.piamidam.org for
details on all Environmental and
Sustainable services
Printing Industries of America

Respond to member inquiries regarding EHS compliance and
sustainability questions
Provide consulting services for EHS and sustainability



Permits, reporting, training, etc.
Provide industry representation to government agencies during
rulemaking and policy development
Compliance & sustainability webinars
Compliance & sustainability resources at www.printing.org




Articles, green guide, fact sheets, etc.
Gary Jones at [email protected]

412-259-1794
Specialty Graphic Imaging Association

Respond to member inquiries regarding EHS compliance
and sustainability questions
Provide industry representation to government agencies
during rulemaking and policy development
Compliance & sustainability resources at www.sgia.org






Articles, 4-step sustainability action plan, fact sheets, etc.
Compliance & sustainability webinars
Peer-to-peer sustainability training
Marci Kinter at [email protected]

703-359-1313
Additional Resources
Kansas
 Kansas SBEAP at www.sbeap.org
 Target publications at www.sbeap.org/resources/industries/printers
 KDHE at www.kdheks.gov
 Kansas Dept of Labor at 785-296-4386
National
 Printers’ National Environmental Assistance Center (PNEAC) at
www.pneac.org
 Small Business Environmental at www.smallbiz-enviroweb.org/
 PIA at www.printing.org/
 FTA at www.flexography.org/
 PIA Mid-America at www.piamidam.org/
 SGIA at www.sgia.org/
 SGP at www.sgppartnership.org/
27
Contact Information
Kansas SBEAP
800-578-8898
Nancy J. Larson
[email protected]
E. Jean Underwood
[email protected]
Kansas State University
Pollution Prevention Institute
133 Ward Hall
Manhattan, KS 66506-2508
[email protected]
www.sbeap.org
28
Questions?
 We will answer questions typed
into the question box first.
 If you raised your hand, we will
call on you using your first name,
then you can press *6 to unmute
your line and ask questions.
 We will remain on the line until
all questions or discussion is
finished.
 You can also e-mail or call us at

[email protected]

800-578-8898
29