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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 sbeap@ksu.edu 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 dmonteleone@flexography.org 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 gjones@printing.org 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 Marcik@sgia.org 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 nlarson@ksu.edu E. Jean Underwood ejunderwood@ksu.edu Kansas State University Pollution Prevention Institute 133 Ward Hall Manhattan, KS 66506-2508 sbeap@ksu.edu 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 sbeap@ksu.edu 800-578-8898 29