HomeMy WebLinkAboutQuali-Tee Productions Hazardous Waste Inspector Memo 08.05.2025TO:
TOWN OF YARMOUTH BOARDTHF
HEAL
1 146 ROUTE 28, SOUTH YARMOUTH, MASSACHUSETTS 02664-24451 HEALTH
Telephone (508) 398-2231, ext_ 1241 DIVISION
Fax (508) 760-3472
MEMORANDUM
Zoning Board of Appeals
FROM: Carl E. Lawson, Jr., Hazardous Waste Inspector C [—
SUBJECT: Zoning Board of Appeals Petition Number 5187
Quali-Tee Productions
Proposed Relocation
From 657 Route 28, Unit A-2
To 46 Commonwealth Ave., Unit 4
and
Request to store toxic or hazardous materials in amounts greater
than those commonly associated with normal household use as
referenced in Yarmouth Zoning Bylaw Section 406,5.1.1 (3).
DATE: August 5, 2025
Background
Quali-Tee Productions is a textile screen printing and embroidery business located in
West Yarmouth. The business was founded in 1981 in Marshfield, Massachusetts,
relocating to the Town of Barnstable in 1983, and occupying several locations in
Barnstable County prior to establishing at the present location of 657 Route 28, Unit A-
2. Mr. Steven Slawsby, the son of the founder of Quali-Tee Productions, began working
in the business at the onset in 1981, assumed leadership in 1988, sold the business in
2023 to Mr. Benjamin Dupell, and continues to serve in an advisory role, spending
several days per month onsite, in addition to making himself available to Mr. Dupell for
consultation. The Health Dept. has licensed and inspected this business since 2009.
Proposal
Quali-Tee Productions proposes relocating from their present location of 657 Route 28,
Unit A-2, a site which is not within the Aquifer Protection District (APD) for the Town's
drinking water supply to 46 Commonwealth Ave., Unit 4, a location which is within the
Town's APD.
The relocation is proposed for the purpose of securing a larger workspace which
provides a more efficient floor plan and room for the business to grow.
The projected growth in business includes an increase in the volume of toxic or
hazardous materials storage to the amounts itemized below.
Emulsion stripper: 20-30 gallons (this material removes emulsion from the screens and
is the only material not currently used)
Haze remover: 1-2 gallons (this material removes haze from screen by wiping them if
needed)
Emulsion: 4-6 gallons (this material remains on the screens and constitutes the design
to be transferred to the textile, which is usually a T-shirt or sweatshirt).
Screen opener: 12-15 (15oz cans), 15 cans X 15 oz. = 225 oz. = 1.8 gallons (this
aerosol removes ink from the screens by wiping)
Screen printing ink: 40-60 individual 1-gallon tubs (also known as plastisol, transfer to
the textile, thereby creating the design)
The calculation of the total volume of toxic or hazardous materials using the projected
maximum volumes is as follows:
30 gallons + 2 gallons + 6 gallons + 1.8 gallons + 60 gallons = 99.8 gallons -- 100
gallons.
The only difference between the present toxic or hazardous materials storage volumes
and types is the addition of emulsion stripper in the amount of 20-30 gallons. This
material will be used in the removal of cured emulsion from print screens, a process not
presently conducted, yet crucial to the growth of the business.
Regulatory Items
Zoning
Quali-Tee Productions has applied for zoning relief with the Zoning Board of Appeals
(ZBA) for toxic and hazardous materials storage of more than normal household
quantities, within the APD as outlined in Yarmouth Zoning Bylaw Section 406.5.1.1 (3).
Normal household quantities are twenty gallons total for an operation.
Board of Health (BOH):
The Board of Health Regulation "Handling and Storage of Toxic or Hazardous
Materials," effective May 2, 1990, applies to the proposal from Quali-Tee Productions,
as the planned quantity of materials is greater than the licensing threshold of 10 gallons.
Furthermore, the business, at its present location, has been licensed by the Health
Dept. since 2009 and inspections have been favorable, finding the business in good
order.
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Toxic and Hazardous Materials Delive
Toxic and hazardous materials consisting of those listed previously are presently
delivered to the inside of the business by UPS, during normal business hours and that
practice is planned to continue. The container sizes are one gallon or less.
Toxic and Hazardous Materials Storage
Except for emulsion remover in use (and within a proposed double walled tank system),
all toxic and hazardous materials present onsite will be stored within a secondary
concrete, bermed containment area to be constructed inside the proposed business
unit. The secondary containment area is required by BOH regulation to be 150% of the
total volume of toxic and hazardous materials stored. As stated previously, Mr. Dupell
identified the need for 100 gallons total of toxic or hazardous materials to operate.
During discussion I recommended he request an upper limit that allows for future
business growth. I have encountered businesses with zoning restrictions that
underestimate their needed volume of toxic or hazardous materials and then are unable
to take advantage of discount product pricing or be inhibited in their ability to operate.
Mr. Dupell and I made some initial trial calculations for bermed areas of various sizes.
Following below is an example of the reasoning for a specific volume secondary
containment area and the size calculations.
100 gallons of toxic or hazardous materials stock were initially listed.
Add 50 gallons of latitude for a requested total of 150 gallons.
An additional 50 gallons of material would not alter the delivery, storage, container
sizes, use or disposal methods described in this memorandum.
150 gallons X 150% volume of secondary containment required by Board of Health
Regulation = 225-gallon size, regulatory -complaint, secondary containment area.
One gallon = 231 cubic inches. 225 gallons X 231cublic inches per gallon = 51,975
cubic inches of volume.
Depth X Length X Height = Volume.
There are several construction methods for secondary containment areas. One
common method is to contract the area from cinder blocks mortared in place and coated
with a liquid -proof masonry treatment compatible with the material being stored. Mr.
Dupell expressed an interest in using this method.
A common size for a cinder block is 8" X 8" X 16". Given this size, an internal
containment area depth of 32" and a height of 8" can be readily achieved.
At this point, three of four variables are known.
32" depth X Length X 8" height = 51,975 cubic inches of volume
256 X Length = 51,975 cubic inches of volume
Length = 51,975 / 256
Length = 203 inches
203 inches 1 12 inches per foot = 16.91-foot-long containment area.
This calculation is only one possibility regarding secondary containment area
dimensions, but this design would fit within the proposed new unit.
One material, which is the emulsion remover, will be stored in an open -top tank with a
secondary containment tank.
Toxic and Hazardous Materials Use
Toxic or hazardous materials will only be only by present or future staff of Quali-Tee
Productions and only for the purpose of printing graphics on textiles such as T-shirts
and sweatshirts and cleaning screens.
The steps of the screen -printing process are as follows.
1) New screens are washed to remove any dirt or dust that may be present. This
washing process uses only soap and occurs in the restroom of the business in a
basin that drains to the building's Title 5 system. A sign is posted over the basin
that states only soap products can be used in the sink.
2) The screens are then air-dried.
3) Once the screens are dry, emulsion is applied evenly over the entire surface of
the screen.
4) A plastic film of the print design is then placed in the desired area of the emulsion
on the screen surface.
5) The emulsion -covered screen is then placed on a special light table, sealed in
place with a light -proof cover and exposed to light.
6) The light cures in place the emulsion that is not covered by film. The emulsion on
the remainder of the screen area, which is covered by film, remains uncured.
7) The screen is then washed with only fresh water in a wash basin that drains to an
above ground translucent holding tank. The uncured emulsion washes off the
screen revealing the design. The resultant solution is process wastewater, not
hazardous waste, and is disposed of at a sewage treatment plant.
8) The screen is again air-dried.
9) Once the screen is dry, ink is applied with a rubber wiper.
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10)The screen is now pressed against the garment receiving the design.
11) The ink is cured on the garment through heat applied by a conveyor dryer.
12) Once all the garments receiving a particular design and color are printed, the ink
is manually cleaned from the screen using a rag (usually an old T-shirt) and
screen opener, which is a cleaner for removing inks.
13) The screen is then stored in a rack with other screens if it is expected the same
design will be needed soon.
14) If the same design is requested again soon the screen will be reused.
15) If the same design is not requested in the short-term, the screen will be cleaned
of the uncured emulsion so that a new design can be applied. This is the only
step of the process that is not presently conducted. This will be a new step to
maximize the use of each screen and limit the number of screens that require
replacement, which is the current method. This step will be completed by
manually submerging print screens into an open -top tank filed with emulsion
remover. The emulsion dip tank will be 20-30 gallons in size and be placed within
a secondary containment tank. Mr. Dupell and I have already reviewed
acceptable products.
Toxic and Hazardous Materials Disposal
Presently Quali-Tee Productions does not produce any hazardous waste.
With the addition of removing cured emulsion from the screens, hazardous waste will be
generated in the form of spent emulsion remover. Based on his research, Mr. Dupell
estimates the emulsion remover will have to be replaced following the treatment of
approximately 200 screens and has investigated hazardous waste removal companies.
Other Waste Items
Non -hazardous industrial wastewater results from the washing of uncured emulsion
from the print screens. This water is not flammable, reactive or caustic and is not
hazardous waste, but must be managed properly and is removed by a septic hauler for
disposal at a septic treatment plant. The most similar material I can relate this to, and
with which the BOH is familiar, is vehicle wash water.
Used rags are disposed in the general trash once they are dry. According to the former
owner of Quali-Tee Productions, these rags contain dried ink. The ink is not flammable
because it must be suitable for tolerating the heat applied by the conveyor dryer. The
Safety Data Sheet (SDS) for the ink supports the nonflammable designation.
Wash System for Removing Uncured Emulsion from Screens
This system is operating at the present location and will be moved to the proposed new
location.
Following is a list of the components that comprise the uncured emulsion wash system.
1) The print screens are washed of uncured emulsion in a dedicated booth
designed for this purpose. The unit consists of (1) a basin with a drain and
screen supports (or brackets) built into the surface of the basin for holding
screens and (2) booth sides for containing overspray generated by the washing
process.
2) PVC pipe connects the drain of the basin to the inlet of an electric pump.
3) The electric pump receives uncured emulsion wash water from the washout
booth and then pumps it to one of two aboveground, plastic, translucent, double -
walled holding tanks.
4) PVC pipe connects the electric pump outlet to a flexible plastic line using steel
hose clamps.
5) PVC pipe also is used for the vent line from the pump and exiting through the
ceiling.
6) The flexible plastic line connects the PVC pipe that exits the pump to one of two
aboveground, plastic, translucent, double -walled holding tanks.
7) Metal brackets anchored to the wall route the flexible plastic line from the pump
to one of the two holding tanks
8) The two plastic, translucent, double -walled holding tanks each have a 65-gallon
capacity and store the uncured emulsion wash water until it is removed by a
sewage hauler.
Additional Information
1) The system was built by a master plumber working with a Town plumbing permit.
2) Cured emulsion is not cleaned from the screens.
3) Nonflammable ink is only wiped from the screens using rags.
4) The tanks are translucent and aboveground so the operator of the system can
visually determine when to change the tank that is receiving wash water and
when to have the tanks pumped.
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Environmental Safe -guards
1) All toxic or hazardous materials proposed to be onsite will have secondary
containment, as described previously.
2) An Emergency Spill Response Plan has been developed and is included for
BOH review.
Health Dept. Requirements
Yarmouth Health Regulation requires the following regarding toxic or hazardous
materials handling and storage, which applies to the proposal by Quali-Tee Productions.
1) The business must register annually for a Yarmouth Board of Health Handling
and Storage of Toxic or Hazardous Materials License.
2) No materials may be discharged to the environment.
3) No outdoor storage of materials is allowed.
4) All materials must be protected from vandalism.
5) All materials must be stored inside secondary containment of 150% volume of
the total amount of materials stored.
6) Containers of materials must be stored in such a manner to facilitate visual
inspection of each container.
7) Any waste material must be properly disposed of by a licensed hazardous waste
hauler.
8) Absorbent material must be kept onsite for use in the event of spills.
9) Safety Data Sheets (SDS) for each toxic or hazardous material must be
maintained onsite and be readily available.
License Condition Recommendations
Mr. Benjamin Dupell, owner of Quali-Tee Productions, presented his proposal to the
BOH at the regular board meeting on August 4, 2025. After discussion, the BOH
approved recommending the proposal of Quali-Tee Productions to the ZBA by a
unanimous vote with four members present and voting. This recommendation is based
on the ability of the business to comply with the Town of Yarmouth Board of Health
Regulation: "Handling and Storage of Toxic or Hazardous Materials" and based on the
following four (4) conditions listed below. These conditions are in addition to the strict
scope of the regulation and are intended to provide additional protection for the APD.
1) The maximum allowed total combined storage of toxic and hazardous materials
is 150 gallons.
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2) A detailed material spill containment plan must be conspicuously posted at all
times, and all employees must be familiar with the plan.
3) A sufficient supply of inert absorbent must be maintained onsite for use in the
event of a spill.
4) All systems must be fully self-contained with no discharge of any toxic or
hazardous material (including process wash and rinse water) to the ground.
The Board of Health and Health Department respectfully request that if this proposal is
approved by the ZBA, the preceding four (4) conditions please be included in any ZBA
Decision. Furthermore, if the proposal is allowed by the ZBA, these items will be
included as conditions of the annual Board of Health license for Quali-Tee Productions.
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