POLLUTION PREVENTION AND BEST MANAGEMENT PRACTICES FOR LITHOGRAPHIC PRINTERS OPERATING IN BROWARD COUNTY

View entire document in PDF - 284 pages - 14,406 KB

Waste Reduction Manual for Lithographic and Screen Printers [entire manual - originally only pages 25-40 were attached]

ACKNOWLEDGMENTS:
The Department of Natural Resource Protection wishes to thank the University of Tennessee and U.S. Environmental Protection Agency Region IX for their technical information on "Waste Reduction And Recycling Opportunities" and "Pollution Prevention Techniques" for lithographic printers which were included in this document for educational purposes.

ABBREVIATIONS USED IN THIS DOCUMENT

• AC Air Construction license
• AO Air Operation license
• BCCO Broward County Code of Ordinances
• BMP Best Management Practices
• CAA Clean Air Act
• CERCLA Comprehensive Environmental Response, Compensation and Liability Act
• CESQG Conditionally Exempt Small Quantity Generator
• CFR Code of Federal Regulations
• CWA Clean Water Act
• DNRP Department of Natural Resource Protection
• EPA Environmental Protection Agency
• EPCRA Emergency Planning and Community Right-to-Know Act
• FAC Florida Administrative Code
• FDEP Florida Department of Environmental Protection
• HAP Hazardous Air Pollutant
• LQG Large Quantity Generator
• MACT Maximum Achievable Control Technology
• NAAQS National Ambient Air Quality Standards
• NESHAPs National Emission Standards for Pollutants
• NPDES National Pollutant Discharge Elimination System
• P2 Pollution Prevention
• P2-BMP Pollution Prevention and Best Management Practices
• POTW Publicly Owned Treatment Works
• PPA Pollution Prevention Act
• PPRP Division of Pollution Prevention & Remediation Programs
• PTE Potential to Emit
• RCRA Resource Conservation and Recovery Act
• SARA Title III Superfund Amendments and Reauthorization Act
• SBAP Small Business Assistance Program
• SQG Small Quantity Generator
• TCLP Toxicity Characteristic Leaching Procedure
• TSCA Toxic Substances Control Act
• TSDF Treatment, Storage, or Disposal Facility
• VOC Volatile Organic Compound

Back to the top

EXECUTIVE SUMMARY

This Pollution Prevention and Best Management Practices (P2-BMP) document has been developed by the Division of Pollution Prevention and Remediation Programs (PPRP) to assist owners and operators of lithographic printing facilities in Broward County in their effort to maintain an environmentally sound business. Operating such a business means complying with environmental regulations, reducing wastes at the source, and minimizing the potential for releasing hazardous materials to the environment. Facilities managed in such a way benefit the owners and operators by reducing the substantial costs associated with regulatory permitting and compliance, and waste management and disposal. In addition, these facilities provide a safer workplace and an improved company public image. More importantly, the general community of Broward County benefits from environmentally sound operations because releases of hazardous materials to the environment are minimized.

The overall goal of this document is to facilitate compliance with applicable Federal, State, and local environmental regulations, minimize wastes, and foster a pollution prevention attitude within lithographic printing facilities operating in Broward County.

The multi-media approach of this P2-BMP is intended to assist lithographic printers in achieving compliance with many complex environmental laws and regulations, and to address pollution prevention opportunities.

Two sections have been provided in this document to achieve the aforementioned goal:

• The first section provides a brief description of each Federal, State and local environmental regulation affecting lithographic printers, followed by a self-audit checklist. These checklists are designed to assist owners/operators in evaluating the level of compliance at their facility and to correct discovered discrepancies.
• The second section of this document addresses pollution prevention opportunities for lithographic printers to further minimize the generation of waste and potential release of hazardous material to the environment. An overview of national pollution prevention programs is provided. The Department of Natural Resource Protection (DNRP) recommends a Pollution Prevention Program be implemented by each facility. Recommended criteria to develop a comprehensive Pollution Prevention Plan are included in this document. This plan describes the actions to be taken at a facility to minimize generation of wastes at the source and releases of hazardous materials to the environment. It also provides a schedule for implementation, and a means for measuring progress towards reaching pollution prevention goals.

Overall, the P2-BMP document is intended to assist lithographic printers in achieving environmental compliance while maintaining a profitable business. This document will be distributed county-wide. The DNRP's Pollution Prevention Division staff will supplement this document by providing training workshops and technical support to facilities requesting assistance. Confidential, non-regulatory on-site visits will also be made available to assist facilities in developing Pollution Prevention Plans.

Back to the top

FORWARD

The need for protecting the public health and the environment has resulted in numerous of laws and regulations. In the past, mostly larger companies were affected by these laws, even though approximately 50% of the pollution in the nation is created by the combined effect of all small businesses. Currently, however, there are many Federal, State, and local environmental laws and regulations that may affect small businesses, such as lithographic printing businesses. These laws and regulations are complex and require continuing review to ensure up-to-date compliance with the latest requirements.

Regardless of the complexity of environmental regulations, the facility owners and operators are responsible for understanding and complying with the rules that affect their business. Failure to understand and comply with the requirements will not excuse the owner/operator from violation of the regulations nor from the potential fines and penalties that may result.

The Department of Natural Resource Protection (DNRP) is responsible for the protection, restoration, and enhancement of Broward County's natural resources and environmental quality of life. This mission is accomplished through programs which are governed by the provisions of the Broward County Code of Ordinances Chapter 27.

In 1991, DNRP initiated the development of Pollution Prevention and Best Management Practices (P2-BMP) for businesses operating in Broward County that use hazardous materials or generate hazardous wastes. The P2-BMP document is intended to serve as an instrumental compliance tool enabling the protection, preservation, and maintenance of Broward County's environmental resources. The purpose of the P2-BMP is to foster a working relationship between the regulated community and DNRP as a regulator in achieving regulatory compliance and in preventing pollution in Broward County. Complying with environmental regulations and incorporating pollution prevention techniques are complementary activities.

Pollution prevention is a more efficient use of materials and resources in order to generate less waste and emissions. It is preferred over traditional pollution control approaches, like treatment and disposal, which often just shift pollution around (e.g., from land to water) without eliminating it. Many pollution prevention practices are low-cost and low-risk alternatives to hazardous waste disposal. Every printer employs some of the pollution prevention techniques that are included in this document. Printers may refer to these techniques simply as "good business practices" or "standard operating procedures." Some may know them as waste reduction or waste minimization techniques.

Back to the top

INDUSTRY PROFILE

OVERVIEW

The printing industry, also known as the graphic arts industry, is characterized by many small businesses, with nearly 80% of the companies employing 20 people or less. The purpose of the printer is to duplicate a given image repeatedly on specified materials (substrates), such as paper, plastic, metal, wood or fabric. The major raw materials used by the printing industry include inks, substrates, photographic films, photo processing chemicals, gravure cylinders, printing plates, plate processing chemicals, fountain solutions, cleaning solvents, and rags.

The five most common printing processes are lithography, gravure, flexography, letterpress, and screen printing.

Lithography, or offset printing, is the predominant printing process. There are two categories of lithography:

• Sheet-fed lithography is the printing of images on individual sheets of paper. It is commonly used for printing books, posters, greeting cards, labels, packaging, advertising flyers and brochures, periodicals, and for reproducing artwork.
• Web-offset lithography is the printing of images onto a continuous roll (web) of paper. It is commonly used for newspapers, periodicals, advertising, books, catalogs, and business forms.

Back to the top

LITHOGRAPHIC PRINTING PROCESS DESCRIPTION

Printing begins with the preparation of artwork or copy, which is photographed to produce an image. The photographic image is transferred to a plate and image areas are made receptive to ink. In the printing operation, ink is applied to the plate, then transferred to a rubber blanket and then to the substrate, reproducing the image. Multi-color printing is done by passing the substrate through several single-color printing operations. The substrate is then cut, folded, and bound to produce the final product. Main operations include image processing, plate making, printing, and finishing. Other sub-operations include proofing, make ready, ink drying and press cleaning. The general flowsheet is shown on page 4 (Source: EPA Guides to Pollution Prevention - The Commercial Printing Industry). A short description of these operations follows:

• IMAGE PROCESSING employs graphic arts photography in the reproduction of the artwork or copy. Some lithographic processes use photographic negatives to transfer an image to the plate, others require positives, which are produced by printing negatives onto paper or film. Image processing operations use materials similar to those in other fields of photography. These materials include paper, plastic film, or glass base covered with photographic emulsion, usually silver halide salts in gelatin, developer and fixer chemicals.

• PROOFING occurs after the image processing and is part of internal job control. This step also may serve as a communication tool between printer and client. The proof shows whether all elements fit, whether color is right, and how the job will look when it is printed.
• PLATE MAKING employs the usage of a flat metal or paper plate as an intermediate image carrier which transfers an inked image to a rubber blanket. The blanket then transfers the image to the substrate. Lithographic plates have ink-receptive image areas and water- receptive non-image areas on the same plate. Plates are usually photo mechanically made surfaces (for metal plates) or electrostatically made surfaces (for paper plates), covered with a light sensitive coating. An image is transferred to a plate by placing the image transparency over the plate. A vacuum is applied for better contact. The plate is then exposed to ultraviolet light, which passes through the transparency, leaving the image on the plate. The plates are then developed to make image areas ink-receptive and to dissolve the coating over the non-image areas.
• MAKEREADY is necessary for all the adjustments to achieve a reproduction equivalent or comparable to the proof, and acceptable to the costumer. The makeready is more complex for web-offset presses than for sheet-fed offset because with web-offset printing, eight press units are involved (two for each process color) which must be adjusted properly.
• PRINTING employs mechanical presses, one for each color. Multi-color printing is done by overlying the four basic colors: black, magenta, cyan, and yellow. The three major areas of each printing unit are: the dampening system, the inking system and the image transfer. Prepared plates are mounted to a rotating metal cylinder. As the cylinder rotates, a dampening solution (fountain solution) followed by an ink is transferred to the plate's image area. The image area repels the dampening solution and accepts the printing ink, while the non-image area accepts the dampening solution and repels the ink. As the cylinder continues to rotate, the inked image is transferred to a blanket and than onto the substrate. Fountain solution generally contains gum arabic, phosphoric acid, defoamers, fungicide, isopropyl alcohol and water. Traditional lithographic inks are formulated with petroleum-based oils and metal-based pigments.
• INK DRYING operations may be necessary after printing, depending on the type of ink used. Inks for lithographic printing are usually oil-based. These inks may contain solvents including xylenes, ketones, alcohols, or aliphatics.
• PRESS CLEANING operations are necessary following a printing job or a color change. The frequency of cleaning depends on factors such as dried ink and paper lint accumulation. Ink rollers and plates are usually cleaned in-place by pouring solvent over them. Residual ink is dissolved in the solvent and scraped from a roller with a blade. The waste solvent/ink mixture is captured in a tray. Rubber blankets are usually cleaned with rags wetted with solvent. Usually, the same solvent is used for blanket and roller cleaning. Solvents used for cleaning include methanol, toluene, naphtha, and methylene chloride.
• FINISHING process includes trimming, folding, collating, binding (stitching, gluing or mechanical binding), laminating, and embossing.

Back to the top

COMMON CHEMICAL USED, WASTE GENERATED AND DISPOSAL PRACTICES*

* These methods may or may not be in compliance with regulations applicable to your facility. You are responsible for evaluating your waste streams to determine their regulatory status.

Back to the top

POTENTIAL SOURCES OF WASTES

The wastes generated by a printer depend on the technologies and material used, and waste reduction methods employed. Potential sources of wastes in the lithographic printing operations by category are listed below:

HAZARDOUS WASTE

• Photographic wastes: photo developer, fixer, intensifiers, reducers, cleaner, scrap film.
• Spent solvents:acetone, carbon tetrachloride, ethanol, ethyl benzene, isopropanol, methanol, methylene chloride, mineral spirits, toluene, xylene.
• Spent fountain solutions with hazardous components (alcohols, ethylene glycol, etc.)
• Waste inks with solvents and heavy metals:inks sludges containing chromium, lead or cadmium.
• Strong alkaline wastes: ammonium hydroxide, sodium hydroxide.
• Strong acid wastes:chromic, hydrochloric, nitric, phosphoric, and sulfuric acids.
• Cleaning rags contaminated with solvents and inks containing heavy metals.
• Containers with hazardous residues of solvents, inks or adhesives if not legally empty.

USED OILS

Used oil (lubricating oil, compressor oil, vehicle oil, etc) is not a hazardous waste if special measures are taken to ensure that the used oil does not become contaminated by other material and is suitable for further use and recycling. However, a special management of used oil is required, which is provided on page 12 of this document.

VOLATILE ORGANIC COMPOUNDS (VOCs)

• Inks: alcohols, aliphatics, ketones, xylenes.
• Fountain solutions: isopropyl alcohol.
• Adhesives: ammonia, isopropanol, toluene.
• Cleaning solvents: acetone, chlorinated solvents, kerosene, methanol, naphtha, toluene.

CONTAMINATED WASTEWATER

• Rinse from Photo processing.
• Any liquid hazardous waste dumped down the drain.

NON-HAZARDOUS SOLID WASTES

• Waste substrates: paper, plastic, foil etc. from trimmings, rejects, and excess quantities.
• Non-hazardous waste inks: water based inks without heavy metals.
• Legally empty containers (no more than one inch of residue for 55 gal drum or 3% of the total capacity).
• Empty cartons, wrappers and roll cores.

Back to the top

P2-BMP GOAL, OBJECTIVES, and STRATEGIES

The overall GOAL of this P2-BMP document is to facilitate compliance with applicable Federal, State, and local environmental regulations, minimize wastes, and foster a pollution prevention attitude within lithographic printing facilities operating in Broward County.

To accomplish this goal, DNRP has established the following OBJECTIVES:

A. FACILITATE COMPLIANCE with all Federal, State, and local environmental regulations governing the use, storage, generation, and disposal of hazardous materials and hazardous wastes, and air emissions within the lithographic printing industry.

B. PREVENT THE RELEASE OF CHEMICALS to the environment as a result of fugitive emissions to the atmosphere, leaks, accidents, or improper disposal or discharge.

C. PROVIDE SPECIFIC INDUSTRY POLLUTION PREVENTION TECHNIQUES and information on nation-wide initiatives in order to reduce the use and release of hazardous materials, generation of hazardous and non-hazardous waste, without negatively impacting business profitability, and possibly improving the bottom line.

To achieve these objectives, the following STRATEGIES have been established:

1. DEVELOP A P2-BMP DOCUMENT for lithographic printers operating in Broward County to facilitate compliance with applicable environmental regulations, minimize wastes, and foster a pollution prevention attitude within industry.

2. ENSURE DISTRIBUTION OF A P2-BMP TO EACH FACILITY IN BROWARD COUNTY. This document can be used by each lithographic printer as a self-audit manual, to ensure compliance with environmental regulations and implementation of pollution prevention techniques.

3. ORGANIZE WORKSHOPS AND PROVIDE TRAINING to lithographic printing facility owners/operators. At these workshops the entire document will be reviewed and all questions will be answered.

4. PROVIDE TECHNICAL ASSISTANCE through confidential, non-regulatory on-site visits, upon request. The facility owner/operator should contact the DNRP Pollution Prevention Section staff at 519-1421 for technical assistance.

Back to the top

ENVIRONMENTAL LAWS AND REGULATIONS THAT MAY APPLY TO LITHOGRAPHIC PRINTERS

The Congress of the United States passes legislation concerning environmental compliance in order to solve specific environmental problems and concerns, such as water and air pollution. The U.S. Environmental Protection Agency (EPA) promulgates Federal regulations and develops standards to implement and enforce these laws.

The EPA has a national responsibility to protect public health and natural resources, while the State and local agencies have a smaller area of responsibility confined to their state or local area. Oftentimes the responsibility to administer a Federal program may be delegated down to State or local agencies. For example, the EPA has delegated the administration of the hazardous waste program to the Florida Department of Environmental Protection (FDEP). The State or local agency then develops it's own regulations, that are often similar, but not necessarily identical, to the EPA regulations. State and local regulations must be at least as strict as federal regulations, but often- times are more stringent based on the special concerns of that particular state or local area. For example, the State of Florida implemented aggressive storage tank rules, ahead of the federal government, to protect the surface and groundwater resources of Florida.

There are many Federal, State, and local environmental laws and regulations that may affect lithographic printing businesses, such as: the Clean Air Act (CAA), the Clean Water Act (CWA), the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Emergency Planning and Community Right-to-Know Act (EPCRA), also known as Superfund Amendments and Reauthorization Act (SARA Title III), the Toxic Substances Control Act (TSCA), the Pollution Prevention Act (PPA), the Florida Administrative Code (FAC) and FDEP regulations, and Broward County Code of Ordinances (BCCO) Chapter 27, known as "Broward County Natural Resource Protection Code."

All these laws may not be applicable to every lithographic printing facility. Lithographic printing facility owners and operators are responsible for understanding and complying with all applicable requirements of Federal, State and local environmental regulations. Failure to understand and comply with these requirements will not excuse the owner/operator from violation of the regulations nor from the potential fines and penalties that may result.

In the P2-BMP document, we have attempted to summarize the Federal, State and local environmental requirements affecting the lithographic printers. A brief overview of the environmental regulations in each area is provided. A self-audit checklist follows each summary, if applicable. Each checklist is designed to assist the facility's owner/operator in determining which specific sections are applicable to the facility and in evaluating the level of compliance with environmental requirements. If non-compliant items are identified during the self-audit, instructions advising how to correct these discrepancies are provided directly below the question. This allows the owner/operator an opportunity to correct the problems and to prevent potential fines or penalties by a regulatory agency which may discover these violations.

Back to the top

A. FEDERAL AND STATE REGULATIONS THAT MAY APPLY TO LITHOGRAPHIC PRINTERS

A.1 CLEAN AIR ACT (CAA)

The Clean Air Act Amendments of 1990 contain new requirements for sources of air pollution which impact both large and small businesses. CAA distinguishes between criteria pollutants which are subject to National Ambient Air Quality Standards (NAAQS) and hazardous air pollutants (HAPs), which are subject to the more stringent National Emission Standards for Pollutants (NESHAPs). Primary NAAQS have been established for six air pollutants: ozone, carbon monoxide, particulate matter, sulfur dioxide, nitrogen dioxide, and lead. The CAA Title I establishes provisions for Attainment and Maintenance of the National Ambient Air Quality Standards. The CAA Title III establishes Maximum Achievable Control Technology (MACT) Standards for a list of 189 hazardous air pollutants. Appendix 1 of this document provides "EPA Chemical Lists for the Printing Industry", including the list of HAPs.

Air pollution control involves permit requirements and the imposition of control requirements. The CAA Title V establishes a new permit system which will cover all applicable emission control requirements. The Title V permit is a five-year federally enforceable operating permit. In Broward County this permit will be administered by the DNRP Air Quality Division via state delegation and will be reviewed by EPA. It will specify all control requirements, emission limits, record keeping, compliance reporting, compliance certification, and monitoring requirements. The Title V permit will only apply to certain types of facilities which are defined as major sources due to their annual potential to emit. "Potential to emit" is defined as the greatest amount of emissions that could be released from a piece of equipment based on its maximum design capacity or maximum production (assuming the equipment will run 24 hours/day 365 days/year or 8,760 hours/year). The Title V permit applies to both hazardous air pollutants (HAPs) and volatile organic compounds (VOC) emissions:

• The threshold for permitting HAP emissions is 10 tons/year for a single chemical/category and 25 tons/year for all HAP chemicals/categories. (Emissions must be at this amount or more before a permit is required.) These thresholds apply nationwide. The most common HAP chemical used by lithographers is glycol ethers, which can be found in alcohol substitutes and cleaning solutions.
• The Title V threshold for VOC emissions varies by geographical location and the ozone non- attainment status of the area in which the facility is located. Ozone non-attainment areas are classified as: marginal, moderate, serious, severe, or extreme. For example the VOC emission threshold is 10 tons/year for the only extreme area (Los Angeles), 25 tons/year for severe areas (like New York), 50 tons/year for serious areas (like Atlanta), and 100 tons/year for moderate and marginal areas (like the industrialized counties in Florida).

States are required to adopt and implement the CAA requirements through permitting. Florida Statutes Chapter 403, and Florida Administrative Code Rules 62-4 and 62-209 through 297 specify the state permitting requirements. Any facility (or source) that has the potential to emit (PTE) in excess of the threshold limits is subject to Title V. State permits may require certain activities, such as modifying existing equipment or changing process materials (inks, fountain solutions, cleaning solvents, and other chemicals). Florida DEP developed guidelines that provide procedures for limiting a facility's PTE in a federally enforceable manner to preclude Title V permitting requirements. Facilities with the PTE above Title V thresholds can thus become synthetic non-Title V facilities. Many facilities are seeking to obtain synthetic non-Title V status to avoid costly controls and burdensome emission estimation, record keeping and reporting requirements. This is accomplished by obtaining a federally enforceable construction permit or a federally enforceable state permit (FESOP). The permit conditions and emission limitations must be verifiable and enforceable in a practical manner (i.e., if the PTE is limited by hours of operation, the permit must require the owner to document hours of operation). In addition, the Notice of Permit must be advertised in a newspaper of general circulation. Florida DEP has delegated to DNRP Air Quality Division the authority to issue Title V and synthetic non-Title V permits. For more details, please see the Local Environmental Regulation section on page 26. An air permit to operate a lithographic printing facility may be required.

The Printing industry is being targeted by the EPA because printers emit volatile organic compounds (VOCs), which lead to the formation of ground level ozone. Primary sources of these emissions are fountain solutions, inks, and cleanup solvents. Some VOCs are also listed as HAPs. Common chemicals, classified as VOCs and/or HAPs, regulated by CAA and used in the printing industry are listed below:

• Heptane, Methyl isobutyl ketone (HAP)
• Butanol, Hexane (HAP), Mineral spirits
• Carbon tetrachloride (HAP), Isooctanol, Naphthas
• Ethanol, Isopropanol, Normal propyl acetate
• Ethyl acetate, Isopropyl acetate, Propanol
• Ethylene glycol (HAP)Methanol, (HAP)Stoddard solvent
• Glycol ethers (HAP), Methyl chloroform (HAP), Toluene (HAP)
• Glycol esters, Methyl ethyl ketone (HAP), Xylene (HAP)

The Clean Air Act Amendments of 1990 mandated that each state establish a Small Business Assistance Program (SBAP). Each program is to have an Ombudsman (Advocate) to advise the small business communities on CAA matters and to develop a technical assistance program to help small business comply with CAA requirements. Services are provided at no cost. Florida DEP - SBAP can be reached by calling 1-800-722-7457.

A.2 CLEAN WATER ACT (CWA)

The Clean Water Act requirements that may apply to lithographic printers are related to wastewater and oil discharges. Generally, lithographic operations generate wastewater (containing acids, alkali, solvents), rinse water contaminated with photochemicals (especially silver) and plate making chemicals (containing chromium and cyanides), and lubricating waste oil.

Usually, all wastewater effluent is discharged to the Publicly Owned Treatment Works (POTW). An agreement must be reached between the facility and the POTW before the discharge is accepted. Standards of wastewater effluent parameters are required to be met, which sometimes imply a pre-treatment before discharge. Direct discharge of non-domestic wastewater to a body of water, storm sewer, or septic tank is prohibited without a National Pollutant Discharge Elimination System (NPDES ) permit.

The Broward County Code of Ordinances includes related local environmental regulations, such as Chapter 27 "Broward County Natural Resource Code" and Chapter 34 "Wastewater Management." The local regulation requirements are similar to CWA requirements, but more stringent and specific to local conditions. Broward County's specific requirements are provided in Section B.2, Art.V., WATER RESOURCE MANAGEMENT, starting on page 27 of this document.

A. 2.1 USED OIL MANAGEMENT

Oil discharges and used oil management are regulated at federal and state level. According to these requirements, used oil is not a hazardous waste if special measures are taken to ensure that the used oil does not become contaminated by another material and is suitable for further use and recycling. If a hazardous waste is accidentally mixed with used oil, then the contaminated used oil must be disposed of as a hazardous waste. Disposal or discharge of used oil in the sanitary sewer, septic tank, on the ground or in a water body is prohibited. In Broward County the related requirements are more stringent, because oils and used oils are considered hazardous materials and regulated under BCCO Chapter 27, Art.XII. These requirements are provided in Section B.4, Art. XII, HAZARDOUS MATERIAL, starting on page 33 of this document.

A. 2.1.1 USED OIL MANAGEMENT CHECKLIST

YES / NO

Is used oil collected and stored in non-leaking containers or tanks that are in good condition and labeled with the words "Used Oil"?

If NO, implement this method of storage immediately.

YES / NO

Is the used oil storage area separated from other hazardous material and hazardous waste storage areas to prevent accidental contamination of the used oil?

If NO, designate a separate storage area for used oil containers.

YES / NO

Is secondary containment provided at the used oil storage area to contain spills and prevent accidental discharge to drains or the environment?

If NO, provide secondary containment. Please see DNRP requirements for secondary containment (page 37).

YES / NO

Is absorbent material and other pertinent spill control materials provided at the used oil storage area to cleanup spills immediately?

If NO, provide the necessary spill control materials to contain and cleanup potential spills.

YES / NO

Is your used oil transported by a certified (DNRP licensed) used oil transporter?

If NO, switch to a DNRP licensed used oil hauler. The up-to-date list is provided in Appendix 2.

YES / NO

Is used oil recycled by an FDEP permitted Used Oil Recycling Facility?

If NO, send your used oil to a permitted Used Oil Recycling Facility and retain records for five (5) years.

A.3 RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

The Resource Conservation and Recovery Act (RCRA) was enacted by Congress to protect public health and the environment from improper management and disposal of hazardous waste. RCRA establishes waste storage, handling and disposal criteria and emergency procedures in the event of a release. A manifest system is established to implement strict controls on the disposal of hazardous waste and the ability to trace a hazardous waste back to the original generator. The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 establishes responsibility for clean-up of contamination to the environment.

A lithographic printing facility may generate wastes that can be harmful to human health and/or the environment. Such wastes are considered hazardous and are regulated by Federal and State laws [40 Code of Federal Regulation (CFR) parts 260-265 and appendices and Florida Administrative Code (FAC) rule 62-730].

A waste is classified as a hazardous waste if:

• It is specifically listed as a hazardous waste in 40 CFR part 261 in RCRA (four lists with over 400 hazardous wastes, including hazardous wastes from non-specific sources, specific sources, and commercial chemical products), or
• It exhibits one or more of the following characteristics:

Ignitability - the waste is easily combustible or flammable, with a flash point of 140· F (60·C) or less or an oxidizer. The EPA hazardous waste code for ignitable waste is D001.

- Corrosivity - the waste has a pH less than 2 or greater than 12.5. The EPA hazardous waste code for corrosive waste is D002.

- Reactivity - the waste is unstable or undergoes rapid or violent chemical reaction with water or other materials. The EPA hazardous waste code for reactive waste is D003.

- TCLP Toxic (toxicity characteristic leaching procedure) - the waste is tested and found to contain high concentrations of heavy metals (such as barium, silver, chromium, mercury or lead), certain organic chemicals, or specific pesticides that could be released into the ground water. The EPA hazardous waste codes are D004 - D043. For more information please see DNRP Technical Bulletin No. 93-2 (Appendix 10).

It is the owner/operator responsibility to determine whether the wastes generated at the facility are hazardous. EPA allows two approaches to determine if a waste is hazardous, applying process or product knowledge, or testing:

• Applying knowledge of the physical characteristics of a material and how it is used in a given process. The most common way for this determination is to examine the material safety data sheet (MSDS) provided by the manufacturer.
• Testing a waste using a variety of test methods, normally done by an outside certified laboratory or through a licensed disposal company.

Some examples of possible hazardous wastes generated by lithographic printing processes are listed below:

• RCRA listed wastes: acetone, benzene, formaldehyde, methanol, methyl chloroform, methylene chloride, methyl ethyl ketone (MEK), perchloroethylene, toluene, xylene.
• Ignitable wastes: blanket and roller washes, cleanup solvents, isopropyl alcohol, inks, contaminated shop towels.
• Corrosive wastes: film and plate processing chemicals, etching chemicals, acids, alkaline cleaners.

• Reactive wastes: bleaches and other oxidizers.
• TCLP toxic wastes: fixer, plate processing chemicals, cleanup solvents.

EPA Chemical Lists for the Printing Industry, which include Hazardous Air Pollutants, Priority Pollutants of Water, RCRA five lists of hazardous wastes, and the Toxic Chemical list for reporting under EPCRA are attached as Appendix 1. These lists have been prepared by the Design for the Environment Printing Project - EPA Office of Pollution Prevention and Toxics.

A. 3.1 GENERAL HAZARDOUS WASTE REQUIREMENTS CHECKLIST

The following general requirements apply to all lithographic operations generating hazardous waste. The checklist will assist you in determining which specific requirements are applicable to your facility and in evaluating your level of compliance with the regulations.

YES / NO

Have you identified all hazardous wastes generated during your operations?

If NO, please see examples mentioned above and consult Appendix 1.

What type of hazardous waste generator you are? Please check the applicable category:

· Conditionally Exempt Small Quantity Generator (CESQG),

if in a calendar month you generate less than 220 lbs (100 kg) of hazardous waste (approximately half of a 55 gal drum) or less than 2.2 lbs (1 kg) of acutely hazardous wastes (please see Appendix 4) and never accumulate more than 2200 lbs of total hazardous waste on-site at any one time (approximately 5 drums). If you accumulate 5 drums or more, you will be regulated as a Small Quantity Generator.

· Small Quantity Generator (SQG),

if in a calendar month you generate between 220 and 2200 lbs (100-1000 kg) hazardous waste (approximately half of a 55 gal drum and 5 drums), or have accumulated over 6000 kg (approximately 30 drums) hazardous waste. If you accumulate 30 drums or more, you will be regulated as a Large Quantity Generator.

Large Quantity Generator (LQG),

if in a calendar month you generate greater than 2200 lbs (1000 kg) hazardous waste or 2,2 lbs (1kg) or more acutely hazardous waste per month.

Most lithographic printers fall into CESQG and SQG categories. They are subject to fewer regulation than LQG. Hazardous waste compliance requirements for CESQG and SQG follow. Based on the hazardous waste generator determination above, please go to the section that applies to your facility. If your facility hapens to be a Large Quantity Generator (LQG), you are subject to numerous regulations which are beyond the scope of this document. It is recommended that you contact the DNRP for additional information concerning the hazardous waste compliance requirements for LQG.

A.3.1.1 Conditionally Exempt Small Quantity Generator (CESQG) (40 CFR 261.5)

YES / NO

Are all hazardous wastes stored in closed containers at all times except when adding or removing the waste?

If NO, keep containers closed at all times except for filling.

YES / NO

Are all containers labeled with the name of the contents?

If NO, label containers immediately with the name of containerized hazardous waste.

YES / NO

Are hazardous wastes delivered to a permitted treatment, storage, or disposal facility (TSDF) or a recycling facility?

If NO, ensure that all hazardous wastes are recycled or disposed of at a permitted TSDF and use a FDEP or DNRP licensed hazardous waste hauler. For your information, an up-to-date DNRP licensed hazardous waste hauler list is provided in Appendix 2.

YES / NO

Do you maintain records of hazardous waste disposal for five (5) years? If yes, do they include names and addresses of the generator and TSDF, type and amount of waste, and date of shipment?

If NO, ensure compliance with these requirenments.

The following items are Best Management Practices (BMP) for CESQG and are recommended to improve your waste management practices:

YES / NO

Do you have an EPA ID number? (In Florida, most hazardous waste haulers will require this number even if you are a CESQG)

If NO, obtain an EPA ID Number by calling FDEP at 904/488-0300.

YES / NO

Is secondary containment provided for drum storage?

If NO, provide a drip pan or a bermed area to prevent discharge to the environment in the event of a spill or accidental release. Please also see local requirements for storage of hazardous materials on page 38-39.

YES / NO

Are weekly inspections of the containers and storage area conducted and documented in writing?

If NO, implement a weekly inspection program and begin documenting the inspections.

YES / NO

Have emergency response procedures been developed and implemented in the event of a spill or accidental discharge?

If NO, develop procedures and train employees concerning emergency response procedures.

A. 3.1.2 Small Quantity Generators (SQG) (40 CFR 262.34 and 262.44)

A.3.1.2(a) Waste Accumulation and Storage (40 CFR 262.34(4)(b))

YES / NO

Did you exceed the 180 day accumulation and storage time limit or accumulate more than 6000 kg of hazardous waste on-site at any one time?

If NO, no action is necessary.

If YES, obtain an extension for up to 30 days from FDEP, Southeast District, phone (561) 681-6670, and make arrangement for immediate transportation of waste to a permitted TSDF.

YES / NO

Have you obtained a generator EPA ID Number for your facility?

If NO, contact immediately FDEP to obtain a generator EPA ID Number (904/488-0300).

YES / NO

Are all hazardous wastes stored in closed containers at all times except when adding or removing wastes?

If NO, keep lids closed on all containers when not in use.

YES / NO

Are all containers labeled with the name of the contents, marked with the words "Hazardous Waste" and the date that waste accumulation began?

If NO, instruct employees on the proper labeling of hazardous waste containers.

YES / NO

Are weekly inspections conducted of the containers and the central area where the containers are stored to detect any leaks or corrosion of containers, observe proper labeling, and to ensure adequate aisle space is being maintained?

If NO, implement a weekly inspection program.

YES / NO

Are the weekly inspections documented in writing and easily accessible?

If NO, begin documenting inspections and store records in an easily accessible location.

YES / NO

Is secondary containment provided for drum storage? (This is a local requirement provided in Broward County Code of Ordinances Chapter 27, Section 27-356.)

If NO, provide a drip pan or a beamed area to prevent discharge to the environment in the event of a spill or accidental release. Please see local requirements for storage of hazardous materials on page 38-39.

YES / NO

Do you have hazardous waste stored in a tank?

If YES, you are subject to additional requirements. Please see Storage Tanks section on page 42.

A.3.1.2(b) Incompatible Wastes (40 CFR 265.177)

The purpose of the following requirements is to prevent fires, explosions, gaseous emissions, leaching, or other discharge of hazardous waste or constituents which could result from the mixing of incompatible wastes or materials if containers break or leak. Examples of potentially incompatible wastes: alkaline caustic liquids with acid and water; alkaline cleaner with battery acid; caustic wastewater with etching acid liquid or solvent, spent caustic with spent mixed acid.

YES / NO

Are precautions taken to insure that incompatible wastes are not placed in the same container or in an unwashed container that previously held an incompatible waste?

If NO, instruct employees on proper handling and storage of incompatible wastes.

YES / NO

During storage, are containers of hazardous waste separated from other incompatible materials or wastes by a dike, berm, wall or other device?

If NO, arrange for incompatible wastes to be properly separated in the future.

A. 3.1.2(c) Preparedness and prevention (40 CFR 262.34(d)(4) and (5))

YES / NO

Is the facility maintained and operated in a clean and safe manner to avoid any unplanned releases, fires or explosions?

If NO, improve housekeeping, safety and/or operational practices immediately.

YES / NO

Is the facility supplied with the required emergency preparedness equipment (telephone, portable fire extinguishers, absorbent material, shovel, gloves, etc.)?

If NO, provide the required equipment and maintain in good condition and sufficient quantities.

YES / NO

Is adequate aisle space provided in the hazardous waste storage area to permit weekly inspections, unobstructed access of fire protection, spill control, and decontamination in the event of an emergency?

If NO, rearrange the containers to ensure adequate aisle space (generally a minimum of 3 feet).

YES / NO

Is at least one employee, designated as the Emergency Coordinator, on call 24 hours a day to coordinate all emergency response measures?

If NO, designate an Emergency Coordinator to be on call 24 hours a day.

YES / NO

Are employees informed of proper hazardous waste handling and emergency response procedures?

If NO, instruct employees on proper hazardous waste handling and emergency response procedures immediately. The training should be documented.

YES / NO

Is the following information posted near the telephone?

- Emergency Coordinator name and telephone number (work and home).

- Location of fire extinguishers, spill control material, and fire alarm (if applicable).

- Telephone number of fire department.

If NO, post the above information near the telephone immediately.

YES / NO

Have arrangements been made with the local fire and police departments, hospitals, and emergency response contractors in case of emergency?

If NO, proceed to make such arrangements. Prepare the facility layout and information regarding hazardous waste properties and associated hazards, where facility personnel normally work, entrances and possible evacuation routes, and send it to the appropriate responders.

A. 3.1.2(d) Record keeping and Reporting (40 CFR 262.44)

YES / NO

Is a manifest prepared for all the hazardous waste shipped off-site for disposal or recycling?

If NO, see Appendix 3 for a sample of manifest. The hauler should provide you the appropriate manifest and assist you in completing the manifest.

YES / NO

Is a copy of the manifest, signed by the generator and the hauler, kept on-site for five years or until the signed copy, verifying delivery of the waste, is returned to you?

If NO, establish procedures to ensure a copy of the manifest is maintained.

YES / NO

Is the signed copy of the manifest returned by the disposal facility kept on-site for five years?

If NO, establish procedures to ensure a copy of the manifest is maintained.

YES / NO

Was a manifest signed by the disposal facility received within 60 days of the date the waste was accepted by the initial transporter (hauler)?

If NO, submit a legible copy of the manifest to the EPA Region IV Administrator with a note that you did not receive the returned copy of the manifest (confirmation of delivery of the waste). The address is: EPA Region IV, 345 Courtland St., NE, Atlanta, GA 30365, phone (404) 347-3555.

YES / NO

Are records of all test results, waste analyses, and waste determinations kept on-site for five years?

If NO, establish a procedure to ensure these records are kept for the specified time.

Note: RCRA requests all the above records to be kept on-site for at least three years. The local environmental regulations require hazardous facilities to keep these records on-site for five years and be available upon request for inspection by DNRP (BCCO Chapter 27, Section 27-356b(4)d.1.).

A. 3.2 HAZARDOUS WASTE TRANSPORTATION and DISPOSAL

EPA has adopted certain regulations of the Department of Transportation (DOT) governing the transportation of hazardous materials. These regulation concern labeling, marking, placarding, packaging shipping papers, and reporting discharges (49 CFR 171.14).

The most important things to remember about shipping hazardous waste off-site are:

• Choose a disposal facility which have EPA identification number.
• Choose a DNRP licensed hauler (Appendix 2).
• Package and label your wastes for shipping (the hauler will help you with the requirements).
• Prepare a hazardous waste manifest (Appendix 3).

You are responsible for all hazardous waste that you generate from the moment it is created, while it is being transported, and after it has been disposed ("cradle to grave"). You also have liability in the future to assist in cleanup efforts if the waste was improperly disposed of. Thehauler will be handling your wastes beyond your control, but you are still responsible. Similarly, the waste management facility will be the final destination of your hazardous waste for treatment, storage, or disposal. Therefore, any measures you take to reduce your generation of hazardous waste will reduce your liability in the future. It is essential that you carefully choose a hauler a waste management facility. Florida's hazardous waste regulations for haulers and transfer facilities are more stringent than the Federal regulations. In addition, Broward County environmental regulations require that all hazardous wastes shall be hauled away by FDEP or DNRP licensed haulers. An updated list of DNRP discarded hazardous material haulers is provided in Appendix 2.

No hazardous waste disposal sites are licensed or permitted in Broward County. If your facility disposes of any hazardous waste in a Publicly Owned Treatment Works (POTW), you may be required to submit a one-time notification to the POTW, FDEP and EPA and to obtain approval of the owner of the sewer system. Please see local requirements of non-domestic wastewater on page 29 of this document.

A. 4 EMERGENCY PLANNING AND COMMUNITY RIGHT TO KNOW ACT

The EPCRA of 1986, also known as SARA Title III, was established to assist industry and government agencies in emergency planning concerning potential discharges or spills of hazardous materials. It also establishes reporting requirements for hazardous and toxic chemicals.

EPCRA is divided into three subtitles:

• Subtitle A concerns emergency planning and notification of a hazardous materials incident (Section 301-304).

• Subtitle B concerns the reporting of hazardous chemical inventories and toxic releases (Section 311-313).
• Subtitle C concerns administration, enforcement and trade secret protection (Section 321-330).

EPCRA utilizes the following three chemical lists:

• Extremely Hazardous Substances (EHSs);
• CERCLA Hazardous Substances;
• Toxic Chemicals.

These three lists are found in the "Consolidated List of Chemicals" provide in Appendix 4.

Any facility that has hazardous materials at or above established threshold amounts (usually 500 lbs for EHSs and 10,000 lbs for any other chemicals) may be subject to this law.

A summary of EPCRA requirements that may apply to lithographic printers follows:

• Submission of copies of Material Safety Data Sheets (MSDS) or list of substances to local and state authorities (mentioned below on Section A .4.1), and the local fire department for substances stored above threshold levels.
• Submission of Tier I/Tier II forms by March 1 for chemicals stored in excess of threshold levels during the previous calendar year (usually does not apply to small print shops).
• Submission of Form R, Toxic Chemicals Release Inventory Reporting Form by July 1 for each chemical used in excess of the threshold levels (25,000 lbs. for manufactured or processed chemicals, such as components of inks, or 10,000 lbs. for otherwise used chemicals, such as solvents) during the previous calendar year. The new Form R requires pollution prevention activity reporting.
• Procedures for notifying Federal, State and local authorities in case hazardous substances are accidentally released above reportable quantity amounts. Notification should be made immediately by phone and requires a written follow-up report detailing spill and remediation activities (please see Local Environmental Requirements section on page 40).

A. 4.1 HAZARDOUS MATERIAL SPILLS and EMERGENCY RESPONSE

A spill is an unauthorized release that is accidentally discharged at your facility. The discharge of any hazardous material/waste to the environment is prohibited by Federal, State, and local regulations. This includes a discharge in excess of the discharge limitation stated in your permit (e.g. POTW permit). All spills should be contained and cleaned up immediately.

You should take the following measures:

• Have a sufficient quantity of adequate absorbent materials stored in containers marked "Absorbent Material" near the operational area where hazardous materials are stored, handled or used.
• In the event of a spill, try to capture, stop or contain the flow of material by using a bucket, barrier, or similar device to make the cleanup and recovery of the material easier. Prevent the spill from entering any floor drains or contaminating the environment.
• Place a sufficient volume of absorbent material on the spilled substance to absorb the spill. Place the contaminated absorbent material in a drum. All waste generated during the cleanup process and the decontamination of equipment (e.g. shovel) should also be placed in a drum. Label the drum with the contents and dispose of properly.

There are three basic groups of chemicals that must be reported in the event of a spill of hazardous materials exceeding the reportable quantity threshold: CERCLA, EHS, and RCRA - Hazardous waste. A Consolidated List of Chemicals and their reportable quantity thresholds are provided in Appendix 4.

The agencies that you must report to for any spill exceeding the reportable quantity threshold are shown below:

A. 4.1.1 SPILL RESPONSE CHECKLIST

YES / NO

Do you have a secondary containment provided for hazardous material/waste storage areas?

If NO, install secondary containment for hazardous material/waste storage areas. Please see the secondary containment requirements provided in Section B.4. on page 36 of this document.

YES / NO

Do you have a written spill response procedure addressing how to cleanup each type of material that you handle (e.g. ink or solvent spill versus an oil or diesel fuel spill)?

If NO, develop one that outlines the procedures for spill cleanup for each type of material.

YES / NO

Are your employees familiar with the procedures to be followed in the event of a spill?

If NO, provide instruction to your employees concerning the proper spill cleanup procedures.

YES / NO

Do you attempt to stop the source of the spill or discharge immediately to minimize the size of the spill (e.g., secure a valve, turn off a pump or leaking equipment)?

If NO, establish this as your first step in your spill response procedure.

YES / NO

Do you try to contain the spill or discharge to minimize the size of the spill?

If No, familiarize your employees with methods to contain a spill.

YES / NO

Are spills reported to the proper regulatory agencies, when required?

If NO, please see the table provided on page 23. Check your MSDS for chemicals to determine their reporting thresholds.

YES / NO

Is the spill and cleanup materials containerized and properly disposed of or recycled?

If NO, ensure the implementation of these procedures.

YES / NO

Is the reason for the spill investigated and corrective actions implemented to prevent future spills/discharges?

If NO, implement these practices to reduce the incidence of spills/discharges.

YES / NO

Are records maintained of all spills/discharges?

If NO, maintain complete records of all spill/discharge incidents. These records should include the following information:

• The hazardous material involved and the quantity of material spilled or discharged.
• The date and time the spill occurred.
• How the incident occurred and who was involved.
• How the spill/discharged was cleaned up and any corrective actions implemented.
• Measures implemented to prevent a similar spill/discharge from occurring in the future.

YES / NO

• Are your employees instructed in the basic safety precautions applying to spills, such as:
• Keep people away from the spill, do not touch or walk in the spilled material.
• Wear appropriate equipment to prevent skin contact (e.g. gloves, boots, aprons).
• Promptly remove contaminated clothing.

If NO, provide appropriate instructions to all employees.

Back to the top

B. LOCAL ENVIRONMENTAL REGULATIONS THAT MAY APPLY TO LITHOGRAPHIC PRINTERS

BROWARD COUNTY CODE OF ORDINANCES CHAPTER 27

The Broward County Code of Ordinances (BCCO) Chapter 27, known as "Broward County Natural Resource Protection Code", regulates the activities, facilities and items which pose a threat to the public health, safety and welfare of the citizens of Broward County and endanger the environment and natural resources. The Department of Natural Resource Protection (DNRP) is responsible for the protection, restoration and enhancement of Broward County's natural resources and environmental quality of life. This mission is accomplished through programs which are governed by the provisions of the BCCO Chapter 27 mentioned above.

The intent and purpose of this chapter is to provide and maintain, for the citizens of Broward County, standards which will help prevent air, water and noise pollution and beach erosion; will ensure that the purity of all waters remain suitable for the public health and enjoyment; will ensure the propagation and protection of wildlife, birds, fish and other aquatic life; will preserve atmospheric purity and free the air and soil from contaminants, solid waste or synergistic agents injurious to human, plant or animal life or property; or will protect the environment.

In order to protect the air, waters, soils, and other natural resources, Broward County declares that the generation, use, storage, handling, processing, manufacturing, and disposal of hazardous material must be regulated. The unauthorized presence of hazardous material in the air, waters, soils, or other natural resources is prohibited and a responsible party shall take the necessary action to remediate and to remove such substances, in order to restore such natural resources to a condition which does not pose a threat to health, safety, or to the environment.

In this part of P2-BMP document, we have attempted to summarize the local environmental code requirements that may apply to lithographic printers operating in Broward County. A brief overview of BCCO Chapter 27 articles affecting this industry, pertinent prohibitions and general requirements are provided below, followed by a self-audit checklist and instructions on how to correct any discrepancy discovered, if applicable. It is the responsibility of the facility owner/operator to understand what regulations affect their business, determine if the facility is in compliance and correct any discrepancy discovered. Lithographic printers operating in Broward County must comply with all applicable requirements. Please read and comply with all applicable prohibitions and requirements of each of the following BCCO Chapter 27 articles.

B. 1 BCCO Chapter 27 Article IV. AIR POLLUTION

This article is promulgated to eliminate, prevent, and control air pollution in order to protect and enhance the air quality in Broward County. It establishes ambient air quality standards and emissions standards. This article shall apply to all sources of air pollution.

B. 1.1 PROHIBITIONS and REQUIREMENTS

The following prohibitions and requirements may apply to lithographic printers:

• No person shall construct or operate any facility that may emit air pollutants into the air of the county, except in accordance with a valid air pollution license issued by DNRP and all general and specific conditions contained therein (Sec.27-173).
• No person shall cause, suffer, allow or permit the discharge of air pollutants which cause or contribute to an objectionable odor (Sec. 27-176( a)).
• No person shall store, pump, handle, process, load, unload or use in any process or installation volatile organic compounds or organic solvents without applying known and existing vapor emission control devices or systems deemed necessary and ordered by the DNRP (Sec. 27-176 (b)(1)).
• All persons shall use reasonable care to avoid discharging, leaking, spilling, seeping, pouring or dumping volatile compounds or organic solvents (Sec. 27-176 (b)(2)).
• No person shall cause, let, permit, suffer, or allow to be discharged into the atmosphere any air pollutants from new, existing or post-July 1, 1975 sources, the opacity of which is equal to or greater than twenty (20) percent (Sec. 27-177 (a)(1)).
• The owner or operator of any source which emits or can reasonably be expected to emit any air pollutant shall obtain an appropriate permit from DNRP before beginning construction, modification or continued operation of the source (Florida DEP delegated Air Permitting Program to DNRP). An Air Construction and/or Operation Permit may be issued. Specific conditions are included in the permit regarding: Emission limiting and operational standards and requirements of Compliance testing, Recordkeeping and Reporting.

The owner/operator of a lithographic printer shall check with DNRP Air Quality Division if its facility needs an air license, by calling 519-1220.

B.2 BCCO Chapter 27 Article V. WATER RESOURCE MANAGEMENT

This article is promulgated in order to protect the waters of Broward County from pollutants and to maintain and enhance water quality within the county. This section will cover the potential wastewater issues that could be associated with your facility.

B.2.1 PROHIBITIONS (Sec. 27-193)

The following prohibitions may apply to lithographic printers:

• It shall be unlawful for any person to discharge any substance in such quantities as may cause the receiving waters to be of quality less stringent than the water quality standards or to cause pollution of water or a nuisance.
• It shall be unlawful for any person to permit, suffer, or allow the introduction of any of the following substances into the waters of the county: settleable, floating or deleterious substances, and hazardous materials as defined in Article XII of this code.
• After March 12, 1984, no new non-domestic discharge to surface waters or to ground waters is permitted, suffered or allowed except as provided for under a county license. Non- domestic wastewater discharges existing on March 12, 1984, and in use since that time shall not be increased in quantity or decreased in quality, unless approved by DNRP upon demonstration that the activity does not pose a significant threat to the public health or environment.
• Use of Storm Sewers and Sanitary Sewers: No domestic wastewater, non-domestic wastewater, or other wastewater shall be discharged into any sewer designated to carry storm water, unless the discharger has a NPDES permit and existing county license, nor shall stormwater be discharged into a sewer designated to carry domestic wastewater.

B.2.2 WASTEWATER REQUIREMENTS and CHECKLIST

Dependent on the composition of the wastewater, most wastewater discharges from your facility are classified as either:

• a domestic wastewater,
• a non-domestic wastewater, or
• a hazardous waste.

If your wastewater meets the criteria for hazardous waste, it will be regulated by the hazardous waste regulations (RCRA) and not by the wastewater regulations.

Domestic wastewater means the human body wastes from sanitary fixtures, domestic laundry wastes, or water-borne solid wastes collected or received from domestic food preparation or service. "Domestic wastewater" is considered to have the same meaning as "sanitary sewage" or "sanitary wastewater." If your domestic wastewater is discharged to a septic tank, you may be affected by these regulations. Septic tanks provide very limited treatment of waste. They are designed to treat domestic sewage only. Improper non-domestic discharges to a septic tank system could pass through the system untreated and result in groundwater contamination and could drastically shorten the useful life of the septic drain field.

Non-domestic means all non-sanitary liquid wastewaters, including but not limited to those from industrial processes, commercial processes, commercial laundries, and the cleaning of air conditioning cooling towers or heat exchange systems. "Non-domestic wastewater" is considered to have the same meaning as "industrial" or "commercial" wastewater. Examples are shown below. There are specific requirements that must be met dependent on where you discharge your non-domestic wastewater. This includes discharges to the sanitary sewer system. Hazardous materials and non-domestic wastewater discharged to the sanitary system can cause disruption in the operation of the sewage treatment plant, also known as a Publicly Owned Treatment Works (POTW). All non-domestic discharges to the sanitary sewer system should be coordinated and approved in writing with your local POTW. A one time notification identifying the type and amount of hazardous materials discharged annually to the POTW may also be required. Treatment of non- domestic wastewater or non-domestic discharges to a tank, the ground, a ditch or water body may require a non-domestic wastewater permit.

B.2.2.1 NON-DOMESTIC WASTEWATER (Sec.27-193(b)(3)a)

YES / NO

Have you identified all your non-domestic wastewater streams?

If NO, conduct an inspection of your facility operations (inside and outside) and list all wastewater that you are generating.

YES / NO

Have you identified how all non-domestic wastewaters are disposed of?

If NO, list the disposal method of each waste stream. Please seePROHIBITIONS .

YES / NO

Have you implemented the actions required for each disposal method at your facility?

If NO, implement the actions designated in Non-domestic Wastewater Disposal Requirements chart provided below:

NON-DOMESTIC WASTEWATER DISPOSAL REQUIREMENTS

YES / NO

Is any hazardous waste, process wastewater, equipment discharge, or other non- domestic wastewater discharged into the sanitary sewer system?

If NO, proceed to Direct Discharge Non-Domestic Wastewater section.

If YES, notify your local POTW in writing and request written approval for the discharge. If hazardous waste is involved, notify your local POTW, FDEP and EPA concerning the amount and type of discharge within 180 days of discharge.

YES / NO

Has the local POTW established pretreatment standards for your discharge?

If NO, no actions are necessary.

If YES, maintain monitoring records of your discharge to insure that you are complying with the pretreatment standards.

DIRECT DISCHARGE NON-DOMESTIC WASTEWATER TREATMENT FACILITY

If your facility currently has a non-domestic direct discharge wastewater treatment facility license, answer the following questions; otherwise proceed to the Domestic Wastewater section.

YES / NO

Is a copy of your permit located on-site?

If NO, maintain a readily accessible copy at the facility.

YES / NO

Have your operators of the non-domestic direct discharge wastewater system read the license and are they familiar with the requirements of the license?

If NO, provide a copy to the operators and instruct them to read it.

YES / NO

Are you operating the permitted discharge in accordance with the conditions listed in the license?

If NO, review the license and instruct employees on the proper operation of permitted discharges.

YES / NO

Operating reports or groundwater monitoring reports are required by the license. Have you submitted them in a timely manner?

If NO, establish a schedule to routinely submit these reports to comply with the license requirements.

YES / NO

Has a mechanism been established to renew the license at least ninety (90) days prior to the expiration date?

If NO, set up a system to insure your license is renewed at least ninety (90) days prior to the license expiration date.

B.2.2.2 DOMESTIC WASTEWATER (Sec.27-193(3))

Domestic wastewater is typically the wastewater from restrooms at your facility. This wastewater is usually discharged to the POTW or to an on-site septic tank. If you have a septic tank, please also see the Septic Tank section.

B.2.2.3 SEPTIC TANKS (Sec. 27-193(2)c)

YES / NO

Do you have any septic tanks on your property or are you planning to install a new septic tank at this facility?

If NO, skip this section and proceed to Stormwater Management.

If YES, please answer the following two questions.

YES / NO

If a septic tank is being installed at your facility, was a septic tank permit obtained from The Department of Health and Rehabilitative Services (HRS)?

If NO, obtain a permit for the existing septic tank or prior to installing the septic tank.

YES / NO

If repairs or modifications are needed, did you check with HRS to determine if a permit is required?

If NO, contact the HRS.

B.2.2.4 STORMWATER MANAGEMENT (Sec.27-199(c)(1)b)

YES / NO

If the stormwater management system for your facility is not permitted, do you maintain the system so it functions properly at all times?

If NO, develop a maintenance schedule to maintain and repair the system as needed.

YES / NO

Have any of the Best Management Practices to Reduce Pollutants in Rainwater Runoff listed below been implemented?

If NO, consider implementing them to reduce pollution from rainwater runoff at your facility.

YES / NO

Do you have a permitted stormwater system for your facility?

If NO, consult with your local Water Management District. The Water Management Districts and contact persons list is provided in Appendix 11.

YES / NO

Do you operate the stormwater system in accordance with the permit conditions?

If NO, read the permit and comply with the conditions listed in the permit.

YES / NO

Is a copy of the permit available on-site?

If NO, maintain a copy on-site.

YES / NO

Do you maintain the system in accordance with any FDEP/South Florida & Broward County Water Management District operating and maintenance requirements?

If NO, consult with your local Water Management District. Please see Appendix 11.

B.3 BCCO Chapter 27 Article VI. SOLID WASTE

This article is promulgated in order to prevent improper disposal of solid waste on or in the land or the water; and to prevent the use of dumps as a means of final disposal; any of which may result in or contribute to air pollution, water pollution, and land blight. This article requires that solid waste disposal be conducted in a manner and under conditions that will eliminate the dangerous effects of improper solid waste upon air quality, water quality, soils and human health.

B.3.1 PROHIBITIONS (Sec.27-214)

The following prohibitions may apply to lithographic printers:

• No person shall throw, discard, place, maintain or deposit any solid waste in any amount whatsoever in or on any public highway, road, street, alley, thoroughfare, or any public or private property in Broward County, or into any waters of Broward County.
• No solid waste shall be disposed of except by sanitary landfill, recycling process or other method approved by the board.
• No hazardous waste which would create a condition harmful to the environment shall be permitted at any sanitary landfill. When used in this section, hazardous waste means materials or combination of materials which require special management techniques because of their acute and/or chronic effects on air and water quality, on fish, wildlife or other biota, and on the health and welfare of the public. These materials include but are not limited to volatile, chemical, biological, explosive, flammable, radioactive and toxic materials.

The common non-hazardous solid wastes generated by lithographic processes are shown on page 7. All these wastes can be recycled and are discussed in the Pollution Prevention section of this document.

B.4 BCCO Chapter 27 Article XII. HAZARDOUS MATERIAL

The DNRP is authorized to license, evaluate, review, and administer all hazardous material activities, and all environmental assessment and remediation actions performed in Broward County (Sec. 27-351).

A hazardous material facility operating license shall be obtained by the owner/operator for any existing, new or proposed facility that generates, stores, processes, uses, handles, or manufactures hazardous material in quantities greater than specified in the definition of a hazardous material facility (Sec. 27-356(b)(1)a.). An Application for license shall be submitted on DNRP forms and shall provide all information as requested therein (Sec. 27-356(b)(2)). For more information on Hazardous Material (or Storage Tank) licensing, please call DNRP Land Use and Permit Division at (954) 519-1250.

B.4.1 PROHIBITIONS (Sec.27-353)

The following prohibitions may apply to lithographic printers:

• The abandonment or unauthorized release of a hazardous material is prohibited.
• No construction or other intrusive activities shall be initiated, proceed or continue without DNRP approval at any site where contaminants are known or discovered.
• Flammable liquids shall be stored in full accordance with the most current version of the National Fire Protection Association Code (NFPA).
• Storage, handling, usage or production of any hazardous material is prohibited within wellfield zone, unless licensed by DNRP.
• No hazardous waste disposal sites are licensed or permitted in Broward County.
• No person shall cause, permit, suffer, or allow the usage, storage, abandonment or disposal of hazardous material:

a. In a manner which violates a provision of any federal, state, or local regulation; or

b. In a manner which causes, or may cause, an unauthorized release of hazardous material.

• No remedial actions, with the exception of initial remedial actions, shall be initiated at a contaminated site until a remedial action plan (RAP) has been approved by DNRP or FDEP.
• Pumping of water, as a remedial action, and dewatering operations at or within a one-quarter- mile radius of a contaminated site shall not be conducted without DNRP approval.

B. 4.2 HAZARDOUS MATERIAL REQUIREMENTS and CHECKLIST

YES / NO

Within a one month period of time, do you have, generate, store, process, use or handle twenty-five (25) gallons or more of hazardous materials or is any extremely hazardous substance present in excess of the threshold planning quantity? Please see Appendix 4 and the Definition of Hazardous Material provided in Appendix 5.

If NO, your facility is not regulated by the Art. XII Hazardous Material.

If YES, your facility is governed by BCCO Chapter 27 Art. XII Hazardous Material, and is subject to the following requirements:

YES / NO

Do you have a valid DNRP HAZARDOUS MATERIAL FACILITY LICENSE?

If NO, you must apply and obtain from DNRP a hazardous material facility license to operate a lithographic printing facility in Broward County. An example of this license is provided in Appendix 6. An application for a license shall be submitted on DNRP forms (Appendix 7 for a new license, or Appendix 8 to renew a license). All information shall be provided as requested therein.

YES / NO

Do you fully comply with all General Conditions printed on the back of Hazardous Material Facility License? (These conditions are applicable to all licenses issued by DNRP)

If NO, take necessary measures to ensure full compliance with each General Condition.

YES / NO

Have you identified all the hazardous materials used, processed, stored or handled at your facility and all the hazardous wastes generated during your operation?

If NO, you are required to make this determination for your facility. Please see common chemicals used and waste generated listed on page 5- 6, possible hazardous waste generated listed on page 7, and Appendix 5. Material Safety Data Sheets (MSDS) should be used for an accurate determination of hazardous materials.

YES / NO

Have you complied with all federal and state hazardous waste requirements?

Before answering, please review and complete the checklist of Section A.3 RCRA which starts on page 15. Take the necessary actions to correct any discrepancies.

B.4.2.1 General operation requirements (Sec.27-356(b)(4)a.)

Please answer all the questions that apply to your facility. If a question does not apply, check N/A.

YES / NO

Are individual storage containers labeled and maintained in accordance with all applicable federal and state standards?

If No, instruct employees on proper labeling.

YES / NO

Are sump pumps used to remove rainwater from hazardous material containment manually operated to prevent an automatic release of hazardous material to the ground?

If NO, instruct employees to manually operate sump pumps at all times.

YES / NO

Are all monitoring wells installed, locked, tested and maintained as required on the license?

If NO, install any monitoring wells required in accordance with the most current version of DNRP's "Minimum Criteria for Monitoring Wells and Sampling" and perform testing as specified in the license.

B.4.2.2 Construction materials and methods (Sec.27-356(b)(4)b.)

YES / NO

Does storage tank configuration (with the exception of underground storage tanks) provide for complete visual inspection?

If NO, ensure that all aboveground storage tanks provide for complete visual inspection.

YES / NO

Are all primary containments product-tight?

If NO, take necessary actions to ensure compliance with this requirement.

YES / NO

Do you provide secondary containment for all hazardous materials?

If NO, provide secondary containment, unless the hazardous material is contained solely in consumer products packaged for distribution and use by the general public or is a commercial product used for janitorial or minor maintenance purposes.

Note:Secondary containment is an impermeable coating, membrane, surface or structure in which tanks or containers are placed. A double-walled tank is considered secondary containment.

YES / NO

For tanks or containers larger than one hundred ten (110) gallons, does secondary containment hold one hundred ten (110) percent of the volume of the largest tank or container?

If NO, provide the appropriate secondary containment to ensure compliance with this requirement.

YES / NO

For tanks or containers of one hundred ten (110) gallons or less, does the secondary containment hold twenty (20) percent of the combined volume of all tanks or containers within the secondary containment, but no less than the volume of the largest tank or container?

If NO, provide appropriate secondary containment to ensure compliance with this requirement.

YES / NO

Are all secondary containment areas constructed of materials of sufficient thickness, density, and composition so as not be structurally weakened as a result of contact with the released hazardous materials?

If NO, take necessary actions to ensure compliance with this requirement.

YES / NO

Are all secondary containment areas provided with a roof to prevent rainwater from entering the area or, as an alternative, equipped with a lockable valve to enable the controlled release of any accumulation of clean rainwater?

If NO, provide each secondary containment with a roof or lockable valve.

YES / NO

Is all rainwater removed from the secondary containment area within twenty- four (24) hours of its accumulation?

If NO, instruct employees to do so.

YES / NO

Is any and all rainwater which comes into direct contact with any hazardous material collected and disposed of in accordance with requirements established for hazardous waste?

If NO, establish procedures and instruct employees on proper handling of contaminated rainwater.

YES / NO

Did you secure or permanently seal all floor drains in a hazardous materialhandling, usage or storage area which lead to a drain field, septic tank, or storm water system?

If NO, immediately secure or permanently seal these floor drains to prevent the release of hazardous material to a drain field, septic tank or storm water system.

YES / NO

Are all storage containers designed and constructed in accordance with the applicable standards established by the National Fire Protection Association, the American Society for Testing and Materials, the EPA, or with alternate DNRP approved standards?

If NO, contact the agencies mentioned above for corrective actions.

B.4.2.3 Handling and storage (Sec.27-356 (b)(4)c.)

YES / NO

Are hazardous materials properly stored and handled on-site prior to disposal?

If NO, instruct employees on proper storage and handling on-site of hazardous materials.

YES / NO

Are hazardous materials accessible for inspection at any time?

If NO, ensure the accessibility for inspection of hazardous materials at any time.

YES / NO

Did you remove all defective containers from service?

If NO, remove immediately from service defective containers. Instruct employees on the repairing or decontamination and disposal of containers in accordance with federal, state and local regulations.

YES / NO

Do you avoid outdoor hazardous materials usage, including disassembly of any machinery, equipment or vehicles?

If NO, discontinue outdoor hazardous materials usage, unless drip pans, secondary containment, or other steps are taken to prevent any release.

YES / NO

Do you avoid outdoor storage of disassembled parts?

If NO, avoid storage of disassembled parts outdoor, unless emptied and in a manner which prevents contact with rainwater.

YES / NO

Are all drums containing hazardous material stored within a secondary containment area which is protected from weather or in a building and in accordance with all applicable fire codes?

If NO, instruct employees on proper storage of drums containing hazardous material.

YES / NO

Are reactive or incompatible materials stored in separate containers, in secondary containment areas, and in a manner which eliminates the potential for mixing in the event of an accidental release?

If NO, ensure proper storage of reactive or incompatible materials.

YES / NO

Do you perform all hazardous material transfer, dispensing, or mixing activities in a manner which prevents any unauthorized release to the environment?

If NO, develop procedures to ensure prevention of any unauthorized release of hazardous material to the environment.

YES / NO

Do you comply with Federal, State, and local regulations regarding non-domestic wastewater disposal?

If NO, take the necessary actions to correct any discrepancies.

YES / NO

Do you have Publicly Owned Treatment Works (POTW) permission or approval to release hazardous materials into a sanitary sewer system?

If NO, contact your POTW and obtain permission or approval for your industrial wastewater (waste photo chemicals, solvent-water mixture from water separator, etc.) discharge into the sanitary sewer.

YES / NO

Do you keep hazardous waste on-site for a longer period of time than allowed in accordance with federal and state regulations, such as 180 day accumulation and storage time limit if you are a Small Quantity Generator or 90 day accumulation and storage time limit if you are a Large Quantity Generator of hazardous waste?

If YES, you may be required to obtain an extension from FDEP. Alternatively, remove the waste before the deadline date.

YES / NO

Do you use DNRP licensed waste haulers for transporting all discarded hazardous materials, including used oils, to be disposed in accordance with federal, state and local regulations?

If NO, immediately contact a DNRP licensed waste hauler. An up-to-date list of DNRP licensed waste haulers is provided in Appendix 2, for your convenience.

B.4.2.4 Record keeping and reports (Sec. 27-356(4)d)

YES / NO

Do you keep on-site for five (5) years all reports and records, including hazardous waste manifests, bills of lading, or other equivalent manifesting for all hazardous material disposal and are they available upon request for inspection by DNRP?

If NO, establish procedures to maintain a copy of reports and records for five years. Please note that this local requirement is more stringent than the federal and state provisions which require these records to be kept for only three (3) years.

YES / NO

Are Material Safety Data Sheets (MSDSs) maintained on-site for each on-site listed toxic substance?

If NO, ask your suppliers to send to you up-dated MSDSs for all chemicals used or stored at your facility and develop and maintain a file with these MSDSs.

B.4.3 OTHER DNRP LICENSES THAT MAY APPLY TO LITHOGRAPHIC PRINTING FACILITIES

The facility's owner/operator must apply to DNRP and obtain all applicable environmental licenses required by the Broward County Natural Resource Protection Code. The following check list addresses some DNRP licenses that may apply to lithographic printing facilities.

YES / NO

Do you have installed on your facility or do you intend to install aboveground storage tanks which have individual capacities of greater than five hundred fifty (550) gallons and/or underground storage tanks which have individual capacities of greater than one hundred ten (110) gallons?

If NO, no action is necessary.

If YES, provide all information requested on the DNRP Application form (Appendix 7).

A combined Hazardous Material and Storage Tank Facility License will be issued by DNRP.

YES / NO

Is your facility located within Wellfield Zone 1 or 2? Maps illustrating wellfield zones in Broward County may be reviewed at the DNRP office.

If NO, no action is necessary.

If YES, provide all information requested on the Application forms (Appendix 7 or 8) and obtain a DNRP Hazardous Material Wellfield Facility License. This license replaces the Hazardous Material Facility License issued for facilities located in Wellfield Zone 3 or outside of all wellfield zones.

YES / NO

Have you experienced a spill or other discharge of hazardous material exceeding the reportable quantity threshold or have you discovered the presence of any contaminant in the air, water or soil at a level which exceeds any applicable federal, state or local regulatory cleanup standards?

If NO, no action is necessary.

If YES, take necessary measures to stabilize the situation. Immediately report such incidents by phone to the DNRP at (954) 519-1499 and provide written notification within seven (7) calendar days. Written notification should be addressed to Division Director, Pollution Prevention and Remediation Programs Division. A determination of whether your facility will need an Environmental Assessment and Remediation License will be made by DNRP following review of all pertinent information in accordance with BCCO Sec.27-356 (e).

B.4.4 CLOSURE REQUIREMENTS (Sec.27-356(b)(4)e. & 27-317(a)(4))

YES / NO

Do you intend to cease operations, initiate a temporary shutdown, transfer your license, permanently remove from use or close an underground or above ground storage tank which has a capacity of greater than one hundred ten (110) or five hundred fifty (550) gallons, respectively?

If NO, no action is required.

If YES, notify DNRP in writing at least thirty (30) days prior to initiating these activities. Failure to notify DNRP may subject the owner/operator to enforcement action. Conduct appropriate activities to ensure proper removal and disposal of all hazardous material at the facility.

B.5 BCCO Chapter 27 Article X. STORAGE TANKS

Large quantities of petroleum products and hazardous materials are stored in underground or aboveground storage tanks. In order to eliminate contamination of the soil and groundwater from leaking tanks, the Florida Administrative Code provides two sets of regulations: Chapter 62-761 for underground storage tanks (UST) and Chapter 62-762 for aboveground storage tanks (AST). These regulations govern both active and inactive storage tanks. BCCO Chapter 27 Art. X regulates existing and proposed installation within Broward County. These state and local regulations are more stringent than EPA regulations governing storage tanks.

Most lithographic printing facilities are not affected by these regulations. However, medium to large sized facilities may be regulated. Examples of tanks that may be regulated are fuel storage tanks for boilers and storage tanks for inks, solvents and other chemicals. You should conduct a self- audit of your facility utilizing the checklist provided below to determine if your facility is affected by storage tank regulations. Register your tanks with FDEP. Your tanks may be subject to additional notification, recordkeeping, reporting, and operational requirements.

If you have an inactive tank at your facility or a tank abandoned by a previous owner, you may be required to remove or abandon in-place the tank and remediate any contamination discovered at the site.

For additional information concerning the requirements affecting storage tanks, contact DNRP staff at 954-519-1260.

B.5.1 STORAGE TANKS REQUIREMENTS and CHECKLIST

B.5.1.1 ABOVEGROUND STORAGE TANKS (AST)

YES / NO

Do you have any aboveground storage tanks?

If NO, go to section B.5.2 Underground Storage Tanks (UST).

YES / NO

Do any aboveground tanks have a storage capacity greater than 550 gallons?

If NO, tanks containing 550 gallons or less are not regulated under storage tanks regulations. If none of the aboveground storage tanks at your facility are regulated, go to section B.5.1.2 UST.

If YES, proceed to the next question.

YES / NO

Do any aboveground tanks contain a hazardous material as defined by BCCO Sec. 27-352 (Appendix 5)?

If NO, these tanks are not regulated. If none of the ASTs at your facility contain hazardous materials, go to section B.5.1.2 UST.

YES / NO

Are any of your aboveground tanks exempt from regulation? Compare your AST to the list of exempt tank systems provided below.

If NO these are regulated and must be registered.

EXEMPT ABOVEGROUND STORAGE TANKS SYSTEMS

• Tanks containing LP gas.
• Flow-through process tanks.
• Stormwater or wash water collection or discharge systems.
• Emergency spill or overflow containment tanks.
• Equipment or machinery that contains pollutants for operational purposes.
• Storage tank systems containing hazardous wastes (they are regulated under RCRA).
• Any mobil tanks moved at least every 180 days.
• Tanks containing asphalt or pollutants with a softening point greater than 100· F.
• Any pipeline facility.
• Storage tank systems storing solids or gases at standard temperature and pressure.
• Tanks containing heating oil, with a capacity less than 30,000gal.

YES / NO

Are all regulated tanks registered with FDEP?

If NO, complete and submit FDEP Storage Tank Registration Form 17-761.900(2), provided in Appendix 9.

YES / NO

Is the tank registration placard issued by FDEP displayed in plain view?

If NO, post the placard in the office or other suitable location at the facility.

YES / NO

Do you have a DNRP combined Hazardous Material and Storage Tank Operation Facility License?

If NO, complete and provide all information requested on the Application form(Appendix 8) and submit to DNRP.

YES / NO

Have you submitted the required fees to FDEP and DNRP?

If NO, ensure fees are submitted in a timely manner in the future.

B.5.1.2 UNDERGROUND STORAGE TANKS (UST)

YES / NO

Do you have any underground storage tanks at your facility?

If NO, go to the Pollution Prevention section.

If YES, proceed to next questions.

YES / NO

Do any underground tanks have a storage capacity greater than 110 gallons?

If NO, tanks containing 110 gallons or less are not regulated.

YES / NO

Do any underground tanks contain a hazardous material as defined in BCCO Sec.27- 352 (Appendix 5)?

If NO, these tanks are not regulated.

YES / NO

Are any of your underground tanks exempt from regulation? Compare your underground tanks to the list of exempt tank systems provided below.

If NO, these are regulated and must be registered with FDEP and licensed by DNRP.

EXEMPT UNDERGROUND STORAGE TANK SYSTEMS

• Storage tanks containing hazardous waste (these tanks are regulated under RCRA).
• Any septic tank system.
• Any stormwater or wastewater collection system.
• Any emergency spill or overflow containment tank system.
• Flow-through process tanks (e.g., oil-water separator).
• Any storage tank located inside a floored, underground area.
• Any residential storage tank system.
• Any tank system storing gaseous or solid pollutants.

YES / NO

Have all identified regulated underground tanks been registered with FDEP?

If NO, complete and submit a FDEP Storage Tank Registration Form 17-761.900(2) (Appendix 9).

YES / NO

Is the FDEP underground tank registration placard displayed in plain view?

If NO, post the placard in the office or other suitable location at the facility.

YES / NO

Do you have a DNRP combined Hazardous Material and Storage Tank Operation Facility License?

If NO, complete and provide all information requested on the Application form (Appendix 8) and submit to DNRP.

YES / NO

Have you submitted the required fees to FDEP and DNRP?

If NO, submit fees in a timely manner in the future.

Back to the top

POLLUTION PREVENTION OPPORTUNITIES FOR LITHOGRAPHIC PRINTERS

I. OVERVIEW

The Federal Pollution Prevention Act (PPA) was passed in 1990 to focus national attention on reduction of volume and toxicity of wastes at the source of their generation. Congress declared a national policy to prevent or reduce pollution at the source whenever feasible. According to PPA "source reduction" means any practice which

• (i) reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment (including fugitive emissions) prior to recycling, treatment, or disposal; and
• (ii) reduces the hazards to public health and the environment associated with the release of such substances, pollutants, or contaminants.

The term includes equipment or technological modifications, process or procedural modifications, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training, or inventory control.

The PPA sets forth a hierarchy of waste management options in descending order of preference: prevention/source reduction, recycling, treatment, and disposal. Pollution should be prevented or reduced at the source whenever feasible, while pollution that cannot be prevented should be recycled in an environmentally safe manner. In the absence of feasible prevention or recycling opportunities, pollution should be treated. Disposal or other release into the environment should be used as a last resort.

EPA has defined Pollution Prevention (P2) as reduction or elimination of waste at the point of generation, as well as protecting natural resources through conservation or increased efficiency in the use of energy, water, or other materials. P2 includes the following activities:

• source reduction that results in the reduction of total volume of hazardous and non- hazardous waste and/or reduction of toxicity of hazardous waste,
• on-site recycling as part of the technological process, and
• conservation of energy, water and other natural resources.

Pollution prevention is not:

• off-site recycling,
• concentration of hazardous components to reduce volume,
• diluting hazardous constituents to reduce toxicity,
• transferring hazardous components from one environmental medium to another (e.g., evaporating solvents from contaminated wastewater to the air),
• waste treatment (e.g., wastewater pretreatment before disposal to a sewer), and
• waste disposal.

However, these may be effective waste management or treatment options after pollution prevention is considered.

II. NATION-WIDE NEW PROGRAMS

The U.S. Environmental Protection Agency's (EPA) pollution prevention program began in the late 1980s to advance prevention over EPA's traditional pollution control and cleanup actions and to incorporate prevention as the principle of first choice into the mainstream work of the Agency. EPA has moved vigorously in recent years to establish programs which move away from the traditional approach of managing waste at the "end of the pipe" to preventing its production at the source. Two of these new programs are accelerating waste reduction in the printing industry:

• The Common Sense Initiative (CSI) is a fundamentally different vision of environmental policy. EPA has created new cross-Agency teams to work with industry, states, the environmental community and others in six pilot sectors (printing, electronics, auto assembly, metal finishing, iron and steel, and petroleum refining) to identify and implement "cleaner, cheaper, smarter" preventive environmental management solutions. For the first time, these diverse interests, in the past often playing adversarial roles, are joining together to examine the full range of environmental requirements affecting six industries, with the shared goal of creating environmental protection strategies that are cleaner for the environment and cheaper for industry and taxpayers. The participants are looking for solutions that are: industry specific, focused on industry as a whole rather than one pollutant at a time, based on the concept of pollution prevention rather than End-of-Pipe-Only Controls, consensus-based solutions, and a flexible means of achieving tough environmental standards. For more information on CSI call EPA at 202-260-1023.
• Design for the Environment (DfE). Through this program, EPA creates voluntary partnerships with industry, professional organizations, state and local governments, other federal agencies, and the public. Designing for the environment is a strategy for managing the variety of competing demands, such as keeping costs low and quality up, staying competitive in global markets, and meeting consumer preferences for environmentally friendly products. EPA's DfE program helps businesses incorporate environmental considerations into the design and redesign of products, processes, and technical and management systems. How does a business design for the environment?
• By implementing pollution prevention, energy efficiency, and other resource conservation measures;
• By using and producing less toxic and non-toxic materials;
• By making products that can be refurbished, disassembled, and recycled: and
• By keeping careful track of the environmental costs associated with each process.

The DfE Printing Project is a cooperative EPA-industry project aimed at developing pollution prevention information specific to small and medium-sized printers. Project committees are developing cleaner technology substitutes, outreach strategies, and informational products to communicate the results to printers. The committees are also working to identify incentives that will encourage printers to use this information. In lithography, this project is focused on reducing solvent usage from blanket washes. The EPA DfE Printing Project Fact Sheets are included as attachments to this document. For more information on DfE call EPA at 202-260-1023.

EPA's Office of Compliance and Pollution Prevention Policy staff is partnering with industry and environmental experts to develop "Printers' National Environmental Assistance Center" (PNEAC) which includes compliance assistance and pollution prevention information. A PNEAC fact sheet, partners, program description and contacts are included as an attachment to this document for your information.

In addition, the Council of Great Lakes Governors, working with the Environmental Defense Fund and representatives of the printing industry, has initiated the Great Printers Project to prepare a pollution prevention strategy for printers in the Great Lakes region. For more information call Printing Industries of America at 703-519-8114.

On the other hand, printers are facing stiffer environmental regulation by the implementation of the Clean Air Act Amendment, increased hazardous waste disposal costs, and tighter restrictions on allowable discharges from wastewater treatment plants. At the same time, more and more businesses are viewing waste as a reflection of production inefficiency and not as an inevitable part of doing business. All waste represents loss of resources and money. Finally, future waste regulations will likely increase in severity by restrictions associated with waste generation. Businesses are beginning to understand that the best way to avoid these problems is to reduce or eliminate waste generation.

III. WASTE REDUCTION BENEFITS

In general, waste management is becoming increasingly more burdensome in terms of time, resources, and costs. Printers throughout the country have implemented waste reduction programs and found that there are many potential benefits, such as:

• Reduced operational costs through material, energy, and manpower savings typically spent on waste management.
• Reduced waste transportation and disposal costs associated with decreased quantities of waste.
• Reduced long-term liability for off-site disposal of hazardous wastes associated with improper waste transportation, handling or treatment by disposal facilities.
• Safer workplace for employees resulting from reduced exposure to hazardous wastes, which can also reduce the liability of worker health lawsuits and may increase employee loyalty.
• Improved company public image by helping sustain environmental quality, which can result in increased sales.

Reduction or elimination of waste generation by lithographic processes can be achieved by implementing pollution prevention techniques. Many pollution prevention practices are low-cost and do not require sophisticated technologies to effectively reduce waste and improve printing efficiency. These simple practices do not involve intensive capital investment and can be implemented relatively easily by small businesses.

IV. POLLUTION PREVENTION PROGRAM

By signing a hazardous waste manifest, the owner/operator of a facility is certifying that they have a hazardous waste minimization program in place. Large Quantity Generators must have a formal written program with documentation. Small Quantity Generators are not required by law to have a formal program, but should be prepared to prove they are performing some type of waste minimization, or have explored alternatives for waste minimization.

DNRP recommends that the owner/operator of each lithographic printing facility develop a Pollution Prevention (P2) Program. Development of a P2 Program is advantageous to each facility because it establishes a system that facilitates the objective evaluation of a facility's pollution management capabilities and mechanisms for implementing cost-effective pollution prevention opportunities. Suggestions for developing a comprehensive Pollution Prevention Program follow:

1. Set Overall Pollution Prevention Program Goals.

Identify the goals and objectives of the facility's Pollution Prevention Program. The goals should include minimizing the release of hazardous materials to the environment and the generation of hazardous wastes. The objectives should clearly define what must be done to accomplish these goals.

2. Conduct a Facility Pollution Prevention Assessment.

A facility pollution prevention assessment is a review of current facility operations to identify the sources of waste generation. Once having pinpointed the sources of pollution, the company will identify changes that can save money and reduce pollution risk. The following are a few of the typical steps taken when conducting a facility pollution prevention assessment:

• Prepare drawings of the facility layout, including the location of all major equipment and storage areas.
• List all processes that use hazardous materials and their potential for release to the environment.
• List all processes that generate hazardous and non-hazardous wastes.
• Inventory all hazardous substances and the amount handled and used by the facility.
• Inventory all wastes, hazardous and non-hazardous, and the amounts generated.
• Identify major losses by comparing raw materials entering the facility with products and wastes leaving the facility.
• List by priority areas for improvement and waste stream reduction.

• Identify current on-site reuse and/or recycling activities, as well as off site recycling activities. Evaluate their efficiency.
• Determine all costs relating to waste generation, including regulatory compliance and licensing costs, on-site maintenance, transportation and off site disposal costs, long-term liability cost, material loss through evaporation, spills and other releases to the environment.
• Determine all cost savings or profits associated with material reuse or recycling.

3. Prepare a Pollution Prevention Plan (P2 Plan).

A Pollution Prevention Plan is an important element of a Pollution Prevention Program. Based on the facility's current procedures, the P2 Plan identifies improvements, establishes a schedule for implementation of selected improvements, and describes how accomplishments will be tracked and measured. In addition, a written plan becomes an excellent reference guide to ensure the Pollution Prevention Program is being implemented as planned.

The P2 Plan should be developed by the facility with consideration given to the following recommended criteria, as appropriate:

· A written statement of the company's pollution prevention policy, goals and objectives.

State the company's pollution prevention goals and objectives developed under item 1 above. Include a description of management commitment and involvement in the program. Owners/managers set the tone of a company's activities. Through them employees learn the importance of pollution prevention and waste minimization. Prepare a written statement that expresses management's support for the Pollution Prevention Program and their commitment to implementing planned activities and achieving established goals on schedule.

· Provide a summary of the facility pollution prevention assessment.

Summarize the findings of the pollution prevention assessment incorporating the elements described above under item 2.

· Identify pollution prevention opportunities for waste reduction, and on-site reuse/recycling. Evaluate each available opportunity and select cost-effective options.

General and site-specific factors must be considered when evaluating pollution prevention opportunities. Evaluation of waste minimization options should include consideration of the following questions:

• What are the main benefits to be gained by implementing an option?
• How much will it cost to implement the option?
• Is the option economically feasible to implement (what is the net present value, payback period or expected return on investment )?

• Can the option be implemented within a reasonable amount of time?
• Does the option have a good"track record"?
• Will other areas of facility operations be affected?
• Which option will best achieve the facility's waste reduction goals?

Include a schedule of when selected options will be implemented.

A schedule helps management to plan for implementing the new pollution prevention and waste minimization procedures and to keep track of progress.

Describe how progress towards reducing the volume of hazardous wastes disposed will be measured.

Establish quantitative goals for waste reduction to measure progress. Management can then measure their progress towards meeting established goals. Include a discussion of what data will be collected, how results of the program will be tracked and analyzed, how progress will be measured against goals, and how frequently a Pollution Prevention Program status report will be prepared (quarterly, semiannually or annually).

Include a description of the employee awareness and training programs that will be implemented to achieve the goals of the facility's Pollution Prevention Program.

Develop employee awareness and training programs. Provide a description of these programs in the facility's P2 Plan. Create a schedule for implementing these programs and follow the schedule.

4. Involve facility employees in the Pollution Prevention Program.

Although pollution prevention commitments often begin with management, employees are usually the best source for suggesting improvements in the day-to-day operations of the business. Employee incentive programs encourage employees to design and use new pollution prevention ideas. Good suggestions should be put into practice and recognized. One way to reward employee participation in the facility's P2 Program is to establish a monetary reward system. For example, if an employee's suggestion is implemented and results in a cost savings to the facility, the monetary reward to the employee could be set as a percentage of the estimated annual savings to be realized by facility. Rewards for intangible benefits, or suggestions where cost savings cannot be determined should also be granted.

5. An annual review of the Pollution Prevention Program is recommended.

Pollution Prevention is an ongoing effort and facility operations can change. Consequently, a facility assessment and a reevaluation of the Pollution Prevention Program, including the P2 Plan, should be repeated at least once a year. Annual review and revision of the P2 Program should be based on the facility assessment. In addition to continually maximizing pollution prevention opportunities, annual review and revision of the program will demonstrate the facility's continued commitment to achieving pollution prevention goals.

The strategies noted above for developing a comprehensive pollution prevention program will be beneficial for the company and the environment. Implementation of pollution prevention procedures can reduce facility operating costs. Such cost savings can quickly compensate for any costs associated with implementing new pollution prevention procedures.

V. SELECTION OF POLLUTION PREVENTION METHODS

Since the most appropriate method of pollution prevention can depend on site-specific considerations, each facility should identify, select and implement the cost-effective options appropriate for the needs and capabilities of each individual facility.

A successful program includes the following pollution prevention steps:

1. Commit to pollution prevention. Nothing will happen without your commitment.

2. Identify pollution-related problems you want to address and associated pollution prevention opportunities based on a review of facility activities.

3. Identify, evaluate and select appropriate pollution prevention techniques.

4. Implement the techniques and monitor their effectiveness.

A summary of the pollution prevention opportunities follows:

Good Operating Practices

• Segregate wastes to increase recyclability.
• Keep records of inventory. Implement a "first-in, first-out" policy of chemical use. Do not order more than can be used within the shelf life of the product. Labels and expiration dates should be legible.
• Designate one person to manage raw materials for proper inventory control and to ensure that hazardous materials are properly contained and labeled and Material Safety Data Sheets (MSDS) are on file.
• Keep lids on bulk solutions to prevent evaporation, oxidation and contamination.
• Minimize spills and use dry methods for cleanup wherever possible. If a spill of a hazardous substance occurs, use a rag or an absorptive material to soak it up and dispose of it in accordance with all local, state, and federal regulations.
• Be innovative in trying new procedures and products, including recycled paper with a high post-consumer content.
• Find ways to reuse paper. Make notepads, poster-paper, or other products from extra paper. Recycle all paper waste.
• Conserve energy by using energy-efficient lights and equipment and turning them off when not in use.
• Conserve water by installing water-saving devices and using only what you need.
• Your local electric utility or water supplier may offer free energy and water conservation audits.

Prepress Operations

• Use computers to set up and edit jobs to produce proofs for client approval. This technique reduces photo processing wastes.
• Adjust chemical replenishment and washwater flow rates on photo processor to optimize bath life and reduce wastewater quantity.
• Reduce unnecessary photographic chemical changeouts by monitoring bath solutions closely.
• Employ photographic intensifiers that don't contain mercury or cyanide salts.
• Use silverless films, such as vesicular, diazo and electrostatic films, that have speeds and resolution comparable to silver films.
• Install an automatic wash bath which saves water and reduces waste by turning on washwater only when film is being processed.
• Use squeegees or rollers between baths to remove residual fluid from the film before it is placed in the next bath. This prevents bath contamination and reduces material use.
• Employ silver recovery units "in-line" to extend the life of the developer and to help meet wastewater discharge limits.
• Contract with a waste hauler to send used film and film scraps offsite for silver recycling.
• Use presensitized plates that only generate small volumes of spent developer (usually nonhazardous) and are reusable.
• Employ aqueous platemaking to reduce or eliminate the use of hazardous developers and fixers. You may be able to discharge wastewater from the aqueous process directly to the sanitary sewer. Check with your wastewater utility.
• Consider new prepress technologies like electronic image processing (e.g., desktop publishing, digital cameras), direct-to-plate, direct-to-press and digital proofing to reduce or eliminate prepress wastes.

Press Operations

• Maximize use of vegetable-based and ultra violet inks that significantly reduce or eliminate volatile organic compound (VOC) emissions. Soy-based inks with 1% VOC content are available. These inks reduce air emissions and improve workplace safety.
• Select inks that minimize the use of metallic pigments.
• Try fountain solutions that don't contain isopropyl alcohol (IPA) to eliminate or significantly reduce VOC emissions and minimize employee exposure to toxics.
• Use low-VOC and citrus-based solvents that generate less air emissions.
• Buy recycled solvents.
• Install an automatic ink leveler to ensure that ink is evenly distributed.
• Gang print or run similar jobs simultaneously to minimize waste generation between cleanup and starting the next run.
• Look into waterless presses which require no fountain solution or water.
• Refrigerate fountain solution to maintain solution concentration by reducing evaporation. VOC emissions are reduced.
• Use hot parts washers or solvent sinks to clean removable parts. Ask for non-chlorinated solvents if you use sinks.
• Use dirty solvents or lower VOC cleaners for initial wipe down of press equipment, followed by final cleanup using a higher VOC solvent.
• Keep used cleaning rags in closed containers. Cleaning rags contaminated with ink pigments and/or solvents should be laundered off-site by an industrial service or disposed of as hazardous waste. Clean rags can be obtained from the laundry service.
• Use excess ink for future jobs, or mix it together to create a "shop black."
• Recycle ink. If possible, purchase inks from a distributor who will take back unused inks.
• Recycle press cleanup solvents. If you use large amounts, an onsite recovery unit may be practical.
• Find a recycler for press lubricating oils.

Postpress Operations

• Talk to your vendor and review material safety data sheets to identify lower VOC and less toxic glues that will work for you.
• Collect and segregate all paper trimmings, color and white waste paper, and cardboard for recycling purpose.
• Use water-based adhesives.

Important technical information on waste reduction opportunities and pollution prevention techniques are provided in this document to assist lithographic printers to choose and implement the most valuable options for their specific operation. The following information are included:

• Excerpt from "Waste Reduction Manual For Lithographic And Screen Printers" prepared by the University of Tennessee.
• Excerpt from "Practical Pollution Prevention Techniques for Lithographic Printers" prepared for U.S. Environmental Protection Agency Region IX.
• Fact sheets on pollution prevention opportunities for printers developed by the EPA-DfE program, the University of Wisconsin, the Minnesota Technical Assistance Program, and the Nevada Small Business Development Center.

Back to the top

Pollution Prevention Technique Review Checklist

A Pollution Prevention Technique Review Checklist can help you select the best pollution prevention technique to address the pollution-related problems and opportunities you have identified. It is a tool to help you evaluate pollution prevention techniques by looking at a range of business factors. Check off the factors that are important. The checklist provides an area to write down the problems and opportunities you are addressing. Determine which business factors may apply and make notes as necessary.

POLLUTION PREVENTION TECHNIQUE REVIEW CHECKLIST

POLLUTION RELATED PROBLEMS:

POTENTIAL TECHNIQUES:

BUSINESS FACTORS TO CONSIDER FOR EACH POTENTIAL TECHNIQUE:

• TECHNICAL FEASIBILITY:
• EQUIPMENT AND MATERIALS COSTS:
• LABOR COSTS:
• WASTE MANAGEMENT COSTS:
• TRAINING EFFORTS (for new procedures):
• PERMIT REQUIREMENTS (new or modified permit):
• HEALTH AND SAFETY:
• PRODUCT OR SERVICE QUALITY:
• ENVIRONMENTAL BENEFITS (reduced raw materials consumption, hazardous and solid waste generation, etc.):
• ANNUAL COST SAVINGS (annual cost of current practice minus annual project costs):

· PAYBACK PERIOD (capital project costs divided by expected annual savings): _______

WHICH TECHNIQUES CAN BE IMPLEMENTED IMMEDIATELY?

WHICH REQUIRE MORE INFORMATION?

WHICH ARE PROBABLY NOT PRACTICAL?

Pollution prevention techniques solve many pollution-related problems associated with waste generation and disposal, discharges and emissions. Pollution prevention is a powerful way to save money and protect the environment by:

• Reducing raw materials use and costs.
• Reducing waste treatment, disposal costs, liability and associated costs.
• Improving operations and efficiency.
• Protecting employee health and safety.

Pollution prevention can also enhance a positive image within your community.

Making changes in your facility requires the understanding and commitment of managers and employees. Therefore, the techniques described above should be implemented with a program to inform, train and involve employees.

Also, tell your customers about the environmentally friendly materials that you have available. For example, inform customers about the availability and quality of soy-based inks and recycled paper. Display examples of finished products made with these materials. Customer interest in these "green products" may surprise you.

Overall, the P2-BMP document is intended to assist lithographic printers in achieving environmental compliance while maintaining a profitable business. This document will be distributed county-wide. The DNRP's Pollution Prevention Division staff will supplement this document by providing training workshops and technical support to facilities requesting assistance. Confidential, non- regulatory on-site visits will also be made available to assist facilities in developing Pollution Prevention Plans.

For FURTHER INFORMATION on this topic, contact:

• Broward County Department of Natural Resource Protection Pollution Prevention and Remediation Programs Division at 954-519-1260. World Wide Web: http://www.co.broward.fl.us/dnrp.htm
• Florida Department of Environmental Protection Small Business Assistance Program at 1-800-722-7457.
• U. S. Environmental Protection Agency (EPA) at 202-260-1023.

Back to the top

Attachments

Waste Reduction Manual for Lithographic and Screen Printers [entire manual - originally only pages 25-40 were attached]

Practical Pollution Prevention Techniques for Lithographic Printers [excerpt - pages 5-28] 

Printing Sector Compliance Assistance

Introducing the Printers' National Environmental Assistance Center

Design for the Environment - Printing Project

Design for the Environment - Lithography Project - Blanket Wash Solutions for Small Printers