From:Debra Jacobson( firstname.lastname@example.org)
Date:Wed, 29 May 2002 07:57:00
PNEAC will be glad to assist you in any way we can. On our web site we have a number of fact sheets on regulations, contacts for each state, and expertise in flexographic printing as well as a partnership with the Flexographic Technical Foundation. I will try to address your comments and questions as best I can based on the limited information that you have provided. You do not specify whether you are discharging into a municipal waste water system or a septic system. The conditions and limitations of discharging your waste water are significantly different if you are dealing with a septic system. The following discussion is based on the assumption that you are discharging your waste water to a municipal waste water treatment facility also called a Publicly Owned Treatment Works (POTW). Without knowing the specific chemistry of the inks and cleaning products that you are using and the local waste water regulations (each municipality has different limits) we cannot accurately assist you with making a determination of whether your production waste water is permitted to be discharged into the sanitary sewer. You refer to alcohol being used in your process in some way. Alcohol is a flammable substance and is prohibited from being discharged into a sanitary sewer according to federal regulations. In your message you refer to working in other states and the regulations. Each state, county and city have different regulations for what can be discharged into the waste water. At a minimum every state, county and city government must adopt regulations that are at least as stringent as the federal regulations. Note my comment above about flammable substances. I acknowledge the fact that you have worked in other states and have discharged untreated water or that you know of other printers discharging their water. Whether they legally discharged the process water is strictly dependent on what contaminants were in the water and the state, county and city limitations. Additionally, the practice of discharging the waste water that had not been completely evaluated to determine the level of regulated contaminants is not recommended. Other issues to keep in mind are that water based flexographic inks are formulated with both pigments and dyes. Some municipal waste water treatment work limit the amount of coloring and suspended solids (pigment) permitted in the discharge water. In terms of treatment, there are many water based flexographic printers who pre-treat their waste water on site with special treatment systems that remove some of the pigments and other contaminants before discharging the water. Operating and installation permits are required by some states. Other printers opt to ship their waste water to a waste treatment facility and pay for the service. If you are interested in more information about these treatment systems we will be glad to advise you. In the mean time, I suggest you visit the PNEAC web site and review some of the fact sheets on flexographic printing and compliance, see http://www.pneac.org/sheets/ Keep in mind two things when dealing with your waste water issue. If you are putting hazardous materials in your waste water you should not try to dilute the waste stream to reduce the concentration. Dilution of hazardous waste is not permitted according to federal regulations. Two, instead of treating the problem of hazardous materials in your waste water we recommend you investigate eliminating the use of hazardous materials so they are not there in the first place. Thank you for contacting PNEAC and I hope this response begins to clarify your questions about waste water regulations.