PNEAC Fact Sheet
Enviromental Compliance Checklist

For Lithographic Printers

The Short Version

By Gary Jones

This checklist is being provided to highlight some of the essential environmental compliance obligations a printer may be required to meet. This checklist should be used as only a beginning to environmental compliance obligations as it is limited in scope, content, and is not all inclusive. A more extensive checklist is available from the Graphic Arts Technical Foundation at 412.741.6860.

Although every reasonable effort has been made to verify information contained in this publication, PNEAC does not assume responsibility for completeness, accuracy, or interpretation of the same. It is the responsibility of the printer to contact the respective federal/state/local agency for the specific requirements or any additional regulations.

General Recordkeeping

[ ] Create a central and duplicate filing system for originals and working files.

[ ] Summarize all conversations/interactions with agency personnel, including

names, dates, times, and subject matter.

[ ] Put all correspondence in writing and send certified mail with return receipt.

[ ] Develop data collection system and assign duties to responsible employees.

Air Pollution Control

[ ] Copy of current permit and control regulations applicable to the facility.

[ ] Determination of Applicability

[ ] Chemical and fuel consumption data.

[ ] VOC/HAP content determination confirmation and other measurements.

[ ] VOC, HAP, PM, NOx, and SOx emission estimate calculations.

[ ] Air Pollution Permit Information

[ ] Copy of letter stating permit/registration is not required.

[ ] Copy of application package and supporting data.

[ ] Copy of current permit and/or registration.

[ ] Notice of equipment/chemistry changes and resultant permit amendments.

[ ] Permit expiration dates or deadlines for obtaining permits.

[ ] Copies of permit renewal notices.

[ ] Compliance Demonstration

[ ] VOC/HAP content determination for "As Applied" materials.

[ ] Chemical consumption amount and rates.

[ ] Fuel consumption amount and rates.

[ ] Temperature monitoring data:

[ ] Control device (catalytic afterburner, thermal afterburner, and cooler/condenser units)

[ ] Fountain solution recirculating system.

[ ] Calibration records for measurement devices, flow meters, automixing equipment, CEMs, etc.

[ ] Copies of stack test results.

[ ] Copy of control device maintenance plan.

[ ] Copy of control device malfunction policy.

[ ] Equipment operation and maintenance logs.

[ ] Copies of CEM charts or electronic data from data logger.

[ ] Develop and enforce purchasing guidelines for:

[ ] VOC content of inks, solvents, and chemistry.

[ ] HAP content of inks, solvents, and chemistry.

[ ] Require suppliers to produce Method 24 data for VOC content.

[ ] Require suppliers to produce Method 311/Method 24 data for HAP content.

[ ] Consider periodic VOC/HAP content testing by outside laboratory.

Wastewater Discharges

[ ] Copy of current sewer code and other discharge regulations.

[ ] Copy of completed industrial wastewater survey.

[ ] Copy of Notification of Hazardous Waste Discharge.

[ ] Determination of applicability:

[ ] Calculations of contaminant concentrations.

[ ] Copy of test/measurement data for contaminant concentrations.

[ ] Flow rate determination data.

[ ] Wastewater discharge permit information:

[ ] Copy of letter stating permit/registration is not required (if applicable).

[ ] Copy of application package and supporting data.

[ ] Copy of current permit and/or registration.

[ ] Notice of equipment/chemistry changes and resultant permit amendments.

[ ] Permit expiration dates or deadlines for obtaining permits.

[ ] Copies of permit renewal notices.

[ ] Copy of permits for pretreatment equipment:

[ ] Silver recovery equipment.

[ ] Neutralization tanks.

[ ] Other equipment.

[ ] Permit/Registration for backflow prevention device for cross connections.

[ ] NPDES permit for industrial discharge to:

[ ] Septic system.

[ ] Leach field.

[ ] Ground water.

[ ] Surface water.

[ ] Compliance Demonstration

[ ] Flow rate measurement data.

[ ] Copies of test data for pH, temperature, BOD, COD, metals, and other contaminants.

[ ] Copy of annual backflow device inspections.

[ ] Wastewater treatment personnel training records and certification.

[ ] Wastewater treatment system operation and maintenance logs.

[ ] Copy of any spill event/cleanup response report for chemicals or oil.

[ ] Test data document levels of contamination and cleanup.

[ ] Federal industrial wastewater pretreatment reports:

[ ] Baseline monitoring.

[ ] Ninety-Day compliance monitoring.

[ ] Semi-Annual monitoring.

[ ] Permit/Test data for drinking water wells.

Stormwater Discharges

[ ] Determination of Applicability

[ ] Location of outfalls (e.g., discharge points) identified confirming that storm water actually flows to a

waterway (e.g., stream, river, lake, etc).

[ ] Sources of contamination identified and inventoried.

[ ] Wastewater Discharge Permit Information

[ ] Copy of letter stating permit is not required (if applicable).

[ ] Copy of General Permit Notice Of Intent or individual application package and supporting data.

[ ] Copy of current permit and/or registration.

[ ] Notice of equipment/chemistry changes and resultant permit amendments.

[ ] Permit expiration dates or deadlines for obtaining permits.

[ ] Copies of permit renewal notices.

 

[ ] Compliance Demonstration

[ ] Copy of storm water discharge test data.

[ ] Copy of storm water pollution prevention plan and inspection logs.

[ ] Copy of logs, polices, and procedures showing adherence to Best Management Practices.

[ ] Copy of any spill event/cleanup response report for chemicals or oil.

[ ] Test data document levels of contamination and cleanup.

Hazardous Waste Management

[ ] Copy of current state generator regulations.

[ ] Copy of current state regulations for on-site treatment units such as solvent recovery stills and silver

recovery equipment.

[ ] Waste Treatment Equipment Permit Information

[ ] Copy of letter stating permit/registration is not required (if applicable).

[ ] Copy of application package and supporting data.

[ ] Copy of current permit and/or registration.

[ ] Notice of equipment/chemistry changes and resultant permit amendments.

[ ] Permit expiration dates or deadlines for obtaining permits.

[ ] Copies of permit renewal notices.

[ ] Copy of permits for treatment and/or recycling equipment.

[ ] Silver recovery equipment.

[ ] Stills and solvent recovery equipment.

[ ] Neutralization tanks.

[ ] Other equipment.

[ ] Copy of permit for extended accumulation of hazardous waste.

[ ] Compliance Demonstration

[ ] Copy of waste classification tests, MSDSs, and other supporting documentation.

[ ] Documentation of monthly volume generation.

[ ] Copies of tolling agreements or receipts for waste disposal.

[ ] Copies of original and return copy of manifest and land ban notification forms.

[ ] Copies of any exception reports.

[ ] Copy of any spill event/cleanup response report for chemicals or oil.

[ ] Test data document levels of contamination and cleanup.

[ ] Hazardous waste accumulation area inspection logs.

[ ] Copy of biennial/annual reports of hazardous waste generation and minimization activities.

[ ] Copy of contingency response plan.

[ ] Copy of waste minimization plan.

[ ] Copy of employee training records.

Emergency Planning and Community Right-To-Know

[ ] Copy of applicable federal inventory or release reporting requirements.

[ ] Copy of any additional state or local requirements.

[ ] Determination of Applicability

[ ] Chemical and fuel inventory data and calculations for Section 311/312 reports.

[ ] Chemical use data and calculations for substances subject to Section 313 reports.

[ ] Compliance Demonstration

[ ] Copies of any accidental discharge reporting including initial and follow up requirements.

[ ] Copy of MSDS and Section 311 reports and updates.

[ ] Copy of Section 312 Tier I/II reports and supporting documentation.

[ ] Copy of Section 313 report(s) and supporting documentation.

[ ] Copy of written pollution prevention plan as required by state/local agency.

[ ] Purchase, consumption, waste, and test data to support pollution prevention activities.

Primary Author

Gary Jones
Graphic Arts Technical Foundation
GJones@printing.org
412.741.6860

Other PNEAC Contacts

Debra Jacobson
University of Illinois Sustainable Technology Center
djacobson@istc.illinois.edu
630.472.5019

Wayne Pferdehirt
Solid & Hazardous Waste Education Center
pferdehi@epd.engr.wisc.edu
608.265.2361

Written: July 20, 1999
Updated: March 21, 2001
Updated: June 8, 2011

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

© 1999 PNEAC