Guide for Commercial Imaging

Guide for
Commercial Imaging
The Silver Council
The Silver Council is a national group focussed on the environmentally sound management
of silver derived from the processing of photographic images. The Silver Council is
supported by the photographic chemical and equipment manufacturers and represents
more than 360,000 users. The purpose is to encourage communications between the
regulatory and regulated communities, to support scientific research, and to share current
scientific, technical and economic information so that the common goals of pollution
prevention, recycling, water conservation, and compliance can be met.
The Silver Council
550 Mamaroneck Road
Suite 307
Harrison, NY 10528-1612
Phone: (914) 698-7603
Fax: (914) 698-7609
This document may be reproduced in its entirety without permission for distribution
at no charge to commercial imaging facilities.
© 1997 by National Association of Photographic Manufacturers, Inc.
Code of Management Practice Guide for Commerical Imaging
4/1/97
The Commercial Imaging Guide to the Code of Management Practice
The Commercial Imaging Guide to the Code of Management Practice is a set of
recommended operating procedures designed to reduce both the amount of silver and the
overall volume of photographic processing solutions discharged to the drain. This guide has
been written for pre-press operations, micrographics and other commercial imaging
facilities.
Limitations of the Commercial Imaging Guide to the Code of Management
Practice
The Commercial Imaging Guide to the Code of Management Practice does not supercede
existing local regulations. Use this Guide only after the local municipality has adopted the
Code of Management Practice for Silver Dischargers (CMP) into regulation. Use of this
Guide where the CMP has not been adopted may cause the commercial imaging facility to
be out of compliance with local regulations. Before using the Guide, each commercial
imaging facility should check with the local government agency to determine its regulatory
requirements. For more information contact The Silver Council.
Code of Management Practice Guide for Commerical Imaging
4/1/97
Acknowledgements
Many individuals representing the commercial imaging industry have contributed to the
Commercial Imaging Guide to the Code of Management Practice. This Guide is the direct result of
their participation in the committee process. We gratefully acknowledge all of these contributions.
The participants volunteered their time and expertise, thus ensuring this Guide provides an
approach written by commercial processors. Our thanks to each of these people and their
companies. Special thanks go to Ms. Susan Borea, Agfa Division, Bayer Corporation, Mr. Dan
Sinto, Anitec and Mr. Thomas Purcell, The Silver Council for their assistance to this publication.
This project was funded by The Silver Council.
Association of Graphic Communications
Environmental Conservation Board for the Graphics Communication Industries (ECB)
Envision Compliance Ltd.
Graphic Arts Technical Foundation (GATF)
The Silver Council
Agfa Division, Bayer Corporation
Anitec
Eastman Kodak Company
FUJIFILM America, Incorporated
Ilford Photo
Imation Corporation
Konica Corporation
National Association of Photographic Manufacturers (NAPM)
Photo Marketing Association International (PMAI)
Code of Management Practice Guide for Commerical Imaging
4/1/97
i
Table of Contents
1.0 Introduction
................
1.1
Regulating Silver . . . . . . . . . . . .
a.
Concentration-based Limits
b.
Performance-based Limits
What’s the Concern with Silver? . . . . . . .
1.2
Implementing the Code . . . . . . .
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1
2
2
3
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4
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5
2.0
Determining the Category
3.0
Small Commercial Imaging Facility
3.1
3.2
4.0
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Compliance Options . . . . . . . . . . . . . . . . . . . .
Equipment Configurations
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1.
One or Two Chemical Recovery Cartridges
2.
Terminal electrolytic Unit Followed by a
Chemical Recovery Cartridge
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3.
Off-Site Management
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6
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8
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Medium Commercial Imaging Facility
4.1
4.2
5.0
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Compliance Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Equipment Configurations
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1.
Terminal electrolytic Unit Followed by a Chemical
Recovery Cartridge
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2.
In-line electrolytic Unit Followed by a Chemical Recovery Cartridge
3.
Two or More Chemical Recovery Cartridges . . . . . . . . . . . . . . .
4.
Off-Site Management
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Large Commercial Imaging Facility
5.1
5.2
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Compliance Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Equipment Configurations
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1.
Terminal electrolytic Unit Followed by Two or More Chemical
Recovery Cartridges
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2.
In-line electrolytic Unit Followed by a Chemical Recovery Cartridge
3.
Off-Site Management
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Code of Management Practice Guide for Commerical Imaging
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4/1/97
ii
Table of Contents
6.0
Pollution Prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6.1
6.2
6.3
6.4
6.5
Put a Team Together
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a.
Management Activities
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b.
Staff Activities . . . . . . . . . . . . . . . . . . . . . .
P2 Team Checklist . . . . . . . . . . . . . . . . . . . . . . . .
Review Your Options . . . . . . . . . . . . . . . . . . . . . .
a.
Management Practices
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Preventive Maintenance
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Process Control . . . . . . . . . . . . . . . . . . . . .
Inventory Control
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Spill Response Planning
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Good Housekeeping . . . . . . . . . . . . . . . . .
Safety and Security
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Management Practices Checklist
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b.
Equipment Modifications . . . . . . . . . . . . . .
Squeegee Rollers . . . . . . . . . . . . . . . . . . . .
In-line Silver Recovery
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Stand-by Wash
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Equipment Modifications Checklist
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c.
Process Modifications
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Low Replenishment Chemicals
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Solution Regeneration and Reuse . . . . . . . .
Water Reuse and Recycling . . . . . . . . . . . .
Dry Chemicals and Automated Mixing . . . .
Process Modifications Checklist . . . . . . . . .
d.
Solid Waste
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Solid Waste Checklist
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Develop a P2 Plan
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Screening Your Options . . . . . . . . . . . . . . .
Example Worksheet for Screening Options .
Point System . . . . . . . . . . . . . . . . . . . . . . .
Writing the P2 Plan . . . . . . . . . . . . . . . . . .
Example Pollution Prevention Plan Worksheet
Put the Plan in Place . . . . . . . . . . . . . . . . . . . . . .
Track Your Results . . . . . . . . . . . . . . . . . . . . . . . .
Example Worksheet for Evaluating P2
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Spread the Word . . . . . . . . . . . . . . . . . . . .
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19
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4/1/97
iii
Table of Contents
Appendices
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Glossary of Terms
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Electrolytic Silver Recovery . . . . .
Chemical Recovery Cartridges . . .
Off-Site Silver Management . . . . . .
Evaporation and Distillation
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Ion Exchange
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Testing for Silver . . . . . . . . . . . . .
Forms . . . . . . . . . . . . . . . . . . . . .
Sample Spill Contingency Plan
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Worksheet for Screening Options .
Pollution Prevention Plan Worksheet
Worksheet for Evaluating P2
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Processor Log Form . . . . . . . . . . .
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38
41
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4/1/97
1
1.0 Introduction
Photo processing effluent is a by-product
of processing film. After silver recovery,
this effluent is generally discharged to the
drain where it goes to the publicly owned
treatment works (POTW) for treatment and
eventual release back to the environment.
Processing solutions must not be
discharged to a septic system.
Silver is the component of film and paper
that makes it possible to form an image.
While it’s not an ingredient of fresh
solutions, during processing the silver is
removed from the film and paper and goes
into the solutions. Silver should be
recovered from silver-rich solutions before
they are discharged to the drain because:
• silver is a non-renewable resource,
• some sewage treatment plants
(POTWs) and states restrict the amount
of silver that can be discharged, and
• silver has economic value.
A silver-rich solution is a solution that
contains sufficient silver that
cost-effective recovery can be done
either on-site or off-site. Silver-rich
solutions include fixers and may include
water from recirculated washwater
systems.
Effective silver recovery requires equipment
that is appropriate to the size and activities
of the commercial imaging facility. It also
requires implementing a sound preventive
maintenance program for silver recovery
equipment.
Providing you with this information is the
primary focus of the Commercial Imaging
Guide to the Code of Management Practice.
The principal elements of the
Commercial Imaging Guide to the Code
of Management Practice is a set of
recommended operating procedures
designed to reduce both the amount of
silver and the overall volume of
processing solutions discharged to the
drain.
The other element of the Guide is voluntary
pollution prevention. In addition to
recovering silver efficiently, commercial
imaging processors should be concerned
with minimizing the amount of waste they
create. Waste solutions are literally money
down the drain. In cases where the solutions
can’t be discharged to drain, such as when
the processor discharges to a septic system,
it costs money for off-site disposal. That’s
why it makes sense to minimize waste in
the first place. The second half of the guide
details several activities a commercial
imaging processor can voluntarily
undertake to reduce waste and save money.
The Commercial Imaging Guide to the
Code of Management Practice is a guide of
industry recommended practices. It is NOT
a legal requirement. It was written by
people just like yourselves—people who
manage imaging operations.
Code of Management Practice Guide for Commerical Imaging
4/1/97
2
The Guide takes the guesswork out of
determining the specific silver recovery
configurations and preventive
maintenance activities you need. Terms
used throughout this Guide are defined in
the Glossary of Terms (Appendix A).
1.1 Regulating Silver
Silver discharges can be regulated or
controlled by two different approaches.
The first approach establishes limits on the
concentration or total amount of silver in
the wastewater. The second approach
requires suitable treatment be applied
before the wastewater is discharged to the
drain. These categories are
“concentration-based” or “performancebased,” respectively.
a. Concentration-based limits
2. Municipal and state sewage treatment
authorities ideally develop pretreatment
limitations by comparing wastewater
coming into the sewage treatment plant
and the treated water leaving the plant.
The discharge of treated wastewater
must meet limits set by the sewage
authority/EPA to avoid impact on the
water quality of the receiving body of
water. Local development of
pretreatment limitations has resulted in
widely varying and often unrealistic
restrictions across the country.
3. The sampling point used to determine
whether or not a limit is being met is
determined by the local sewer
authority. It may be the property line
manhole, a point where all process
wastewater is combined or at the point
of generation. This introduces
additional variation from city to city.
The traditional means of restricting silver is
through concentration-based numerical
limits in the state law or the city sewer
ordinance. For example, silver may be
restricted to 4 parts per million (ppm).*
This means that for every million parts of
effluent, there can be no more than four
parts of silver.
4. Our industry’s ability to recover silver
cost-effectively is dependent upon the
equipment available in the
marketplace. Restrictions in some
jurisdictions are so stringent they can
not be met with any cost effective
technology available.
Concentration-based limits have been
shown to be a poor way to regulate
commercial imaging operations for several
reasons:
e
Silv
1. Our industry strives to conserve water
through standby washing, wash water
recycling and lower replenishment rates
for process chemicals. As we use less
water, the concentration of silver in the
effluent **increases. Concentrationbased limits, therefore, actually
penalize those who practice water
conservation.
r
b. Performance-based limits
Performance-based limits are spelled out as
a percentage of the silver that must be
recovered from discharged materials.
* ppm is the same measurement as milligrams per liter
(mg/L).
** Effluent is the liquid waste generated from the
processing of photographic material.
Code of Management Practice Guide for Commerical Imaging
4/1/97
3
These limits provide environmental
protection while taking into consideration
the amount of silver-rich solutions
generated by the imaging operation and the
capability of the technology (equipment)
available.
The Code of Management Practice places
commercial imaging facilities into one of
four categories and provides specific silver
recovery equipment recommendations for
each category. The category could vary for
each processor in your facility. For
example, there may be a processor that
runs only a few films per day. This
machine would fall into the small category.
In the same shop, there may be a busy
processor that runs numerous films per day
and would fall into the medium or large
category.
If the POTW were classifying your facility,
it might take into consideration all the
process effluent produced per day in the
entire facility. For our purposes that’s not
very helpful. It could easily result in
requiring an extensive silver recovery
system on every processor—even one on
which only a few films per day are
processed. If you have this type of situation
in your facility, you may need to discuss
this with your POTW when it comes to
categorizing your equipment.
The exception is in facilities where silver
recovery operations are centralized. In
these cases, where fixer from many
processors are collected and desilvered in
a central location, the category is based on
a total volume of fixer and processing
effluent produced at the centralized
treatment site.
What’s the Concern With Silver?
We wear silver jewelry, eat off
silverware and carry silver fillings in our
teeth. Then why is the silver in
commercial imaging processing
solutions regulated? The answer has to
do with the different forms silver can
take. The metallic silver that we use in
eating utensils and jewelry is nontoxic.
But some forms of silver can be very
toxic to aquatic organisms. In fact, years
ago, silver was used as a biocide in
wastewater treatment. Even today, silver
nitrate is sometimes added to the eyes of
new infants in order to kill bacteria.
Because the silver ion is highly reactive,
it quickly and easily complexes with
materials in the environment such as
sulfides and chlorides, to yield
compounds with little or no toxicity.
This means that silver rarely occurs in
ionic or noncomplexed forms. The silver
found in used fixer, for example, is in
the form of silver thiosulfate, a nontoxic
form.
While there is general agreement among
regulators that it’s the ionic form of silver
that’s most toxic, there’s no accurate and
repeatable analytical test method to
measure the ionic species. Therefore,
regulations are based on total silver, with
no differentiation between ionic and
complexed forms of silver.
So silver discharge regulations impact all
pre-press processors. While individual
dischargers may have little impact on
the POTW, collectively, commercial
imaging facilities discharge a significant
amount of silver.
Code of Management Practice Guide for Commerical Imaging
4/1/97
4
The four categories of film processors, as
identified in the Code of Management
Practice are as follows:
•
•
•
•
A small commercial imaging
facility is one that produces
less than two gallons per day
of silver-rich solutions and no
more than 1000 gallons per day of total
process effluent. Small facilities must
recover silver to at least 90 percent
efficiency.
90%
A medium commercial
imaging facility is one that
produces less than 20 gallons
per day of silver-rich solutions
and no more than 10,000 gallons per
day of total process effluent. Medium
facilities must recover silver to at least
95 percent efficiency.
95%
A large commercial imaging
facility is one that produces
more than 20 gallons per day
of silver-rich solutions and no
more than 25,000 gallons per day of
total process effluent. Large facilities
must recover silver to at least
99 percent efficiency.
99%
A significant industrial user (SIU) is
one that discharges more than
25,000 gallons per day of total
effluent.* SIUs have no set percentage
recovery efficiency as each SIU is
individually permitted by the city.
Through the use of this guide, the
commercial processor, together with the
local agency can cooperatively regulate
silver discharges to sewer.
* The EPA defines a significant industrial user as a facility that discharges
an average of 25,000 gallons per day or more of process wastewater to
the publicly owned treatment works (POTW) (excluding sanitary,
noncontact cooling and boiler blowdown waste water). Individual
municipalities are free to use a more stringent definition. (40 CFR 403.3
(t)(ii))
This Guide offers a uniform approach to
regulation from city to city. Most existing
restrictions are unachievable given today’s
technology and the industry goal of
conserving water.
Performance-based limits are realistic,
given the technology currently available to
commercial imaging operations.
Performance-based limits that are uniform
across the country would allow the
industry to self-regulate.
Performance-based limits are the best way
to ensure environmental protection while
providing economic incentive to the
commercial imaging operation.
1.2 Implementing the Code
Who is responsible for ensuring this
performance-based silver management
program is implemented?
In a medium or large operation, the
responsible person is most likely the film
processing manager. While the technical
service or even the processor operator
may be assigned the job of putting certain
aspects of the CMP in place, the final
responsibility rests with management. That
responsibility cannot be delegated. Even if
an outside contractor services the
processors and silver recovery systems, the
responsibility stays with the facility
manager.
In a small facility, the owner is most likely
the responsible person. The same holds
true in this situation; while a technician or
assistant may undertake part of the duties
of silver management and pollution
prevention, the final responsibility lies
with the person in charge.
Code of Management Practice Guide for Commerical Imaging
4/1/97
5
2.0 Determining the Category
The first step is to determine which of the
four categories best describes your facility:
small, medium, large or significant
industrial user (SIU). Remember, if you
have centralized silver recovery, you must
consider the amount of fixer produced
throughout the entire facility, rather than
by individual processing machines.
Step 1
For a specific processor (or central silver
recovery site), calculate or measure the
amount of fixer overflow produced in one
day. For a more accurate estimate, average
the fixer overflow over several days. Make
sure you are using typical processing
volume days.
Example: If in step 1 you estimated that a
given processor produced 6 gallons per
day (GPD) of fixer, that processor would be
categorized as medium and the silver
recovery efficiency required would be
95 percent.
Note: If your facility produces in total more
than 20 gallons per day (GPD) of fixer then
you must also consider the total amount of
process wastewater produced. If the total
process wastewater volume is less than
25,000 GPD then you can consider each
processor individually. If it is greater than
25,000 GPD you are considered a
Significant Industrial User and need to talk
to your POTW.
Step 3
Step 2
On the chart below, locate the Fixer
Overflow column. Look down that column
and find the amount of fixer overflow you
estimated in step 1. Identify the processor
category size and the silver recovery
efficiency which corresponds to this
volume.
Category
Small
Medium
Large
SIU
Fixer
Overflow
If you have more than one processor, use
the Processor Log Form in Appendix H to
list each processor, the category size, and
the required silver recovery efficiency.
Wastewater
Volume
% Silver
Recovery
<2
<1000
90%
>2 but <20
<10,000
95%
> 20
<25,000
99%
-
>25,000
by permit
all fixer and wastewater measurements are in gallons per day, GPD
Code of Management Practice Guide for Commerical Imaging
4/1/97
6
3.0 Small Commercial Imaging Facility
A small commercial imaging facility is
one that produces less than 2 gallons
per day of silver-rich solution
Small facilities must recover silver to at
least 90 percent efficiency.
If you are a small facility, you have four
practical options for compliance
(achieving a 90 percent removal). These
can be configured in several ways,
discussed below.
3.1 Compliance Options
3.2 Equipment Configurations
In this section for small facilities, we’ll
review typical silver recovery equipment
configurations for each of the compliance
options. Detailed information is available
in the appendices.
We’ll also describe the testing methods
and procedures to use with the equipment
to verify that it is recovering at least 90
percent of the silver.
Finally, we’ll show you samples of simple
silver recovery logs to use for recording
the results of the testing.
The following silver recovery options are
recommended for recovering at least 90%
of the silver from silver-rich solutions:
1. one or two chemical recovery
cartridges (CRCs) with manufacturer
specified flow control,* or
2. terminal electrolytic unit followed by a
chemical recovery cartridge (CRC) with
manufacturer specified flow control, or
For detailed information about a specific
type of silver recovery equipment, how it
works, and preventive maintenance
recommendations, refer to:
Appendix B Electrolytic Silver Recovery
Appendix C Chemical Recovery Cartridges
Appendix D Off-Site Management
3. off-site management, or
4. alternative technology providing at
least 90 percent silver recovery.
* Facilities that generate less than 0.5 gallons per day of
silver-rich solutions need only one CRC. Due to the
low volume, a second CRC would oxidize and
channel by the time the first CRC was exhausted
resulting in no additional silver recovery.
Code of Management Practice Guide for Commerical Imaging
4/1/97
7
1. One or two chemical recovery cartridges (CRCs) with manufacturer
specified flow control
How it works
In this configuration, the silver-rich overflow
from the processor (A) is directed to an a
holding tank (B - optional). Next, it is
metered (C - optional) at a fixed rate
through the chemical recovery cartridges
(CRCs) set up in series (E and G). In this
diagram two CRCs are shown. Once the
solution exits the last cartridge in series (H)
at least 90 percent of the silver has been
recovered and the solution can be
discharged to the drain (I).
Optional
2. To verify the percent efficiency of the
system, use an analytical laboratory to
test the solution once every year, from
two locations:
• before the first CRC at (B)
• after the last CRC at (H)
Testing methods for silver recovery efficiency
There are two types of testing methods
you must use:
See Appendix G for more information
about testing for silver.
• once each week, silver estimating test
papers or another method of approximating silver concentration must be used
to indicate whether the system is working
(if the paper shows any change in color,
the system is not working), and
Testing records
• All test results must be recorded in a
silver recovery log. See the examples
below. Check with the publicly owned
treatment works (POTW) to find out
how long to keep records on file.
• once every year, highly accurate
analytical laboratory testing such as
atomic absorption (AA) or inductively
coupled plasma spectroscopy (ICP) must
be used. Use an outside service for
analytical testing.
Testing procedures
1. To indicate whether the system is
working, check the solution weekly
with silver estimating test papers at two
locations:
• after the first CRC at (F)
• after the last CRC at (H)
Silver Recovery Log
Weekly Effluent Check*
Silver Recovery Log (ppm)
Date
Date
CRC #1
CRC #2
7/1/96
P
P
7/1/96
7/8/96
P
P
7/1/97
7/15/96
F
P
7/1/98
Annual Test
%
Influent Effluent Recovery
2800
280
90%
* Pass (P) = no color, Fail (F) = color
When the weekly check indicates
cartridge failure, refer to the
equipment manual for the
manufacturer’s recommendations.
Code of Management Practice Guide for Commerical Imaging
To obtain the percent recovery, use
the following formula:
100 - (effluent x 100 ÷ influent).
4/1/97
8
2. Terminal electrolytic unit followed by a chemical recovery cartridge (CRC)
with manufacturer specified flow control
How it works
In this configuration, the silver-rich
overflow from the processor (A) is
directed to the electrolytic unit (B).
When sufficient silver-rich solution has
accumulated, the electrolytic unit begins
to desilver the solution. When the batch is
completed, the partially desilvered
solution is pumped out of the electrolytic
unit (C) into the holding tank (D-optional).
From here, it is metered (E-optional) at a
fixed rate through the chemical recovery
cartridge (G). Once the solution exits the
cartridge (H) at least 90 percent of the
silver has been recovered and the solution
can be discharged to the drain (I).
Testing methods for silver recovery efficiency
There are two types of testing methods
you must use:
• once each week, silver estimating test
papers or another method of
approximating silver concentration must
be used to indicate the system is working,
(if the paper shows any change in color,
the system is not working), and
• once every year, highly accurate
analytical laboratory testing such as
atomic absorption (AA) or inductively
coupled plasma spectroscopy (ICP) must
be used. Use an outside service for
analytical testing. Review Appendix G for
detailed information about testing.
Optional
with silver estimating test papers at two
locations:
• after the electrolytic unit at (D)
• after the CRC at (H)
2. To verify the percent efficiency of the
system, use an analytical laboratory to
test the solution once every year, from
two locations:
• before the electrolytic unit at (A)
• after the CRC at (H)
See Appendix G for more information
about testing for silver.
Testing records
• All test results must be recorded in a
silver recovery log. See the examples
below. Check with the POTW to find
out how long to keep records on file.
Silver Recovery Log
Weekly Effluent Check*
Date Electrolytic
CRC
Silver Recovery Log (ppm)
Date
7/1/96
P
P
7/1/96
7/8/96
P
P
7/1/97
7/15/96
P
F
7/1/98
Annual Test
%
Influent Effluent Recovery
2350
240
90%
* Pass (P) = no color, Fail (F) = color
Testing procedures
1. To indicate whether the system is
working, check the solution weekly
When the weekly check indicates
cartridge failure, refer to the
equipment manual for the
manufacturer’s recommendations.
Code of Management Practice Guide for Commerical Imaging
To obtain the percent recovery, use
the following formula:
100 - (effluent x 100 ÷ influent).
4/1/97
9
3. Off-site management
• Comply with all applicable hazardous
waste and DOT regulations.
• Keep records of volumes and types of
solutions transferred off-site. See the
example log below.
O ff - S i t e C h e m i c a l L o g
Date
Date
How it works
In this configuration, the silver-rich
solution overflow from the processor is
stored in a container (A) until it is pickedup by a licensed hauler for off-site silver
recovery, treatment and/or disposal (B).
Testing requirements
There are no Code of Management
Practice testing requirements for verifying
silver recovery efficiencies. State waste
agencies, however, may require testing in
order to characterize the waste.
Additional requirements
Commercial imaging facilities using offsite management must meet the following
requirements:
Amount
(gallons)
Type of
Solution
Manifest
Number
2/6/96
44
silver - rich photo
MI 3084201
3/5/96
44
silver - rich photo
MI 3084202
4/2/96
55
silver - rich photo
MI 3084203
5/7/96
48
silver - rich photo
MI 3084204
6/4/96
55
silver - rich photo
MI 3084205
• Maintain logs, hazardous waste
manifests, land disposal restriction
forms and other records for at least five
years. Make the records available for
inspection by the sewage treatment
authorities.
• Verify that the contractor is properly
licensed to transport your waste and is
handling it correctly.
• Accumulate the silver-rich solutions in
a container that’s compatible with
processing solutions.
• Provide secondary containment for
storage tanks or containers, if required
in your jurisdiction.
Code of Management Practice Guide for Commerical Imaging
4/1/97
10
4.0 Medium Commercial Imaging Facility
A medium commercial imaging facility
is one that produces more than 2 but
less than 20 gallons per day of silverrich solutions. Medium facilities must
recover silver to at least
95 percent efficiency.
Remember: the category size of medium is
based on an individual machine, not the
whole facility, unless centralized treatment
is used. This is done to ensure the silver
recovery equipment and testing
recommendations are appropriate for the
size and utilization of the processing
equipment.
If you are a medium facility, you have five
practical options for compliance
(achieving a 95 percent removal). These
can be configured in several ways,
discussed below.
4.1 Compliance Options
The following silver recovery options are
recommended for recovering at least 95
percent of the silver from silver-rich
solutions:
1. terminal electrolytic unit followed by a
chemical recovery cartridge (CRC) with
manufacturer specified flow control*,
or
2. in-line electrolytic unit with a chemical
recovery cartridge (CRC) with
manufacturer specified flow control, or
3. two or more CRCs with manufacturer
specified flow control, or
4. off-site management (including
evaporation/distillation), or
5. alternative technology providing at
least 95 percent silver recovery.
4.2 Equipment Configurations
In this section for medium commercial
imaging facilities, we’ll review typical
silver recovery equipment configurations
for each of the compliance options
Detailed information is available in the
appendices.
We’ll also describe the testing methods
and procedures to use with the equipment
to verify that it is recovering at least
95 percent of the silver.
Finally, we’ll show you samples of simple
silver recovery logs to use for recording
the results of the testing.
For detailed information about a specific
type of silver recovery equipment, how it
works, and preventive maintenance
recommendations, refer to:
Appendix B Electrolytic Silver Recovery
Appendix C Chemical Recovery Cartridges
Appendix D Off-Site Management
Appendix E Evaporation/distillation
* Flow control may be gravity feed or a metering pump,
depending upon the design capabilities of the cartridge and
the processing workload. Work with your supplier to
determine the flow control appropriate for your system.
Code of Management Practice Guide for Commerical Imaging
4/1/97
11
1. Terminal electrolytic unit followed by a chemical recovery cartridge (CRC)
with manufacturer specified flow control
How it works
In this configuration, the silver-rich
overflow from the processor (A) is directed
to the electrolytic unit (B). When sufficient
silver-rich solution has accumulated, the
electrolytic unit begins to desilver the
solution. When the batch is completed, the
partially desilvered solution is pumped out of
the electrolytic unit (C) into the holding tank
(D-optional). From here, it is metered (Eoptional) at a fixed rate through the chemical
recovery cartridge (G). Once the solution
exits the cartridge (H) at least 95 percent of
the silver has been recovered and the
solution can be discharged to the drain (I).
Testing methods
There are two types of testing methods you
must use:
• once each week, silver estimating test
papers or another method of approximating silver concentration must be used to
indicate whether the system is working (if
the paper shows any change in color, the
system is not working), and
• once every six months, highly accurate
analytical laboratory testing such as atomic
absorption (AA) or inductively coupled
plasma spectroscopy (ICP) must be used.
Use an outside service for analytical
testing.
Testing procedures for silver recovery efficiency
1. To indicate whether the system is
working, check the solution weekly with
Optional
silver estimating test paper at two
locations:
• after the electrolytic unit at (D)
• after the CRC at (H)
2. To verify the percent efficiency of the
system, use an analytical laboratory to
test the solution once every six months,
from two locations:
• before the electrolytic unit at (A)
• after the CRC at (H)
See Appendix G for more information
about testing for silver.
Testing records
• All test results must be recorded in a
silver recovery log. See the examples
below. Check with the POTW to find
out how long to keep records on file.
Silver Recovery Log
Weekly Effluent Check*
Date Electrolytic
CRC
Silver Recovery Log (ppm)
Date
7/1/96
P
P
7/5/96
7/8/96
P
P
1/5/97
7/15/96
P
F
7/1/97
* Pass (P) = no color, Fail (F) = color
When the weekly check indicates
cartridge failure, refer to the
equipment manual for the
manufacturer’s recommendations.
Code of Management Practice Guide for Commerical Imaging
Six Month Test
%
Influent Effluent Recovery
2650
133
95%
To obtain the percent recovery, use
the following formula:
100 - (effluent x 100 ÷ influent).
4/1/97
12
2.. In-line electrolytic unit with a chemical recovery cartridge (CRC) with
manufacturer specified flow control
How it works
In this configuration, the silver-rich
overflow from the processor (A) is
continuously recirculated through the
electrolytic silver recovery unit (B) and
back into the fixer tank (A). Fixer overflow
(C) is fed into the holding tank (D). From
here, it is metered (e) at a fixed rate
through the chemical recovery cartridge
(G). Once the solution exits the cartridge
(H) at least 95 percent of the silver has
been recovered and the solution can be
discharged to the drain (I).
Testing methods for silver recovery efficiency
There are two types of testing methods
you must use:
• once each week, silver estimating test
papers or another method of
approximating silver concentration must
be used to indicate whether the system is
working (if the paper shows any change
in color, the system is not working), and
• once every six months, highly accurate
analytical laboratory testing such as
atomic absorption (AA) or inductively
coupled plasma spectroscopy (ICP) must
be used. Use an outside service for
analytical testing. Review Appendix G for
detailed information about testing.
Testing procedures
1. To indicate whether the system is
working, check the solution weekly
with silver estimating test papers at two
locations:
• after the electrolytic unit at (D)
• after the CRC at (H)
2. To verify the percent efficiency of the
system, use an analytical laboratory to
test the solution once every six months,
from two locations:
• before the electrolytic unit at (A)
(in the fixer processing tank)†
• after the CRC at (H)
See Appendix G for more information
about testing for silver.
Testing records
• All test results must be recorded in a
silver recovery log. See the examples
below. Check with the POTW to find
out how long to keep records on file.
Silver Recovery Log
Weekly Effluent Check*
Date Electrolytic
CRC
Silver Recovery Log (ppm)
Date
7/1/96
P
P
7/5/96
7/8/96
P
P
1/5/97
7/15/96
P
F
7/1/97
* Pass (P) = no color, Fail (F) = color
When the weekly check indicates
cartridge failure, refer to the
equipment manual for the
manufacturer’s recommendations.
Six Month Test
%
Influent Effluent Recovery
2500
129
95%
To obtain the percent recovery, use
the following formula:
100 - (effluent x 100 ÷ influent).
† Because no pre-silver recovery measurement is possible, a
baseline silver level of 2500 ppm is assumed.
Code of Management Practice Guide for Commerical Imaging
4/1/97
13
3. Two or more chemical recovery cartridges (CRCs) with manufacturer
specified flow control
How it works
In this configuration, the silver-rich overflow
from the processor (A) is directed to the
holding tank (B). Next, it is metered (C) at a
fixed rate through the chemical recovery
cartridges (CRCs) set up in series (E and G).
In this diagram two CRCs are shown. Once
the solution exits the last cartridge in series
(H) at least 95 percent of the silver has been
recovered and the solution can be
discharged to the drain (I).
Testing methods for silver recovery efficiency
There are two types of testing methods
you must use:
• once each week, silver estimating test
papers or another method of approximating silver concentration must be used
to indicate whether the system is working
(if the paper shows any change in color,
the system is not working), and
• once every six months, highly
accurate analytical laboratory testing such
as atomic absorption (AA) or inductively
coupled plasma spectroscopy (ICP) must
be used. Use an outside service for
analytical testing. Review Appendix G for
detailed information about testing.
2. To verify the percent efficiency of the
system, use an analytical laboratory to
test the solution once every six
months, from two locations:
• before the first CRC at (B)
• after the second CRC at (H)
See Appendix G for more information
about testing for silver.
Testing records
• All test results must be recorded in a
silver recovery log. See the example
below. Check with the POTW to find
out how long to keep records on file.
Silver Recovery Log
Weekly Effluent Check*
Silver Recovery Log (mg/L)
Date
Date
CRC #1
CRC #2
7/1/96
P
P
7/5/96
7/8/96
P
P
1/5/97
7/15/96
F
P
Six Month Test
%
Influent Effluent Recovery
1784
89
95%
7/5/98
* Pass (P) = no color, Fail (F) = color
Testing procedures
1. To indicate whether the system is
working, check the solution weekly
with silver estimating test papers at two
locations:
• after the first CRC at (F)
• after the second CRC at (H)
When the weekly check indicates
cartridge failure, refer to the
equipment manual for the
manufacturer’s recommendations.
Code of Management Practice Guide for Commerical Imaging
To obtain the percent recovery, use
the following formula:
100 - (effluent x 100 ÷ influent).
4/1/97
14
4. Off-site management
• Provide secondary containment for
storage tanks and drums, if required in
your jurisdiction.
• Comply with all applicable hazardous
waste and DOT regulations.
• Keep records of volumes and types of
solutions transferred off-site. See the
example log below.
How it works
In this configuration, the silver-rich
solution overflow from the processor is
stored in a drum (A) until it is picked-up
by a licensed hauler for off-site silver
recovery, treatment and/or disposal (B).
Commercial imaging operations can
reduce the volume of waste using
evaporation or distillation to reduce
hauling charges. This technique does not
change the total amount of silver
available. (see Appendix E.)
Testing requirements
There are no Code of Management
Practice testing requirements for verifying
silver recovery efficiencies. State waste
agencies, however, may require testing in
order to characterize the waste.
Additional requirements
Commercial imaging operation using offsite management must meet the following
requirements:
O ff - S i t e C h e m i c a l L o g
Date
Date
Amount
(gallons)
Type of
Solution
Manifest
Number
2/6/96
44
silver - rich photo
MI 3084201
3/5/96
44
silver - rich photo
MI 3084202
4/2/96
55
silver - rich photo
MI 3084203
5/7/96
48
silver - rich photo
MI 3084204
6/4/96
55
silver - rich photo
MI 3084205
• Maintain logs, hazardous waste
manifests, land disposal restriction
forms and other records for at least five
years. Make the records available for
inspection by the sewage treatment
authorities.
• Verify that the contactor is properly
licensed to transport your waste and is
handling it correctly.
• Store the silver-rich solutions in a
container that’s compatible with
Commercial imaging processing
solutions.
Code of Management Practice Guide for Commerical Imaging
4/1/97
15
5.0 Large Commercial Imaging Facility
A large commercial imaging facility is
one that produces more than 20 gallons
per day of silver-rich solutions.
Large operations must recover silver to
at least 99 percent efficiency.
2. in-line electrolytic unit with two
chemical recovery cartridge (CRC) with
manufacturer specified flow control, or
3. off-site management (including
evaporation/distillation), or
4. alternative technology providing at
least 99 percent silver recovery.*
Remember: the category size of large is
based on an individual machine, not the
whole facility,unless centralized recovery
is used. This is done to ensure the silver
recovery equipment and testing
recommendations are appropriate for the
size and utilization of the processing
equipment.
If you are a large facility, you have four
practical options for compliance
(achieving a 99 percent removal). These
can be configured in several ways,
discussed below.
5.1 Compliance Options
The following silver recovery options are
recommended for recovering at least 99
percent of the silver from silver-rich
solutions. Ion exchange may be used in
combination with other compliance
options to achieve 99 percent recovery
with the wastewater from the processors:
1. terminal electrolytic unit followed by
two chemical recovery cartridge (CRC)
with manufacturer specified flow
control, or
5.2 Equipment Configurations
In this section for large facilities, we’ll
review typical silver recovery equipment
configurations for each of the compliance
options. Detailed information is available
in the appendices.
We’ll also describe the testing methods
and procedures to use with the equipment
to verify that it is recovering at least
99 percent of the silver.
Finally, we’ll show you samples of simple
silver recovery logs to use for recording
the results of the testing.
For detailed information about a specific
type of silver recovery equipment, how it
works, and preventive maintenance
recommendations, refer to:
Appendix
Appendix
Appendix
Appendix
Appendix
B
C
D
E
F
Electrolytic Silver Recovery
Chemical Recovery Cartridges
Off-Site Management
Evaporation & Distillation
Ion Exchange
* This option allows for improvements to existing technology and
for new technology developed after this guide was written. It
also allows for less commonly used technology that is
available and can meet the percent recovery requirements.
Code of Management Practice Guide for Commerical Imaging
4/1/97
16
1. Terminal electrolytic unit followed by two or more chemical recovery
cartridges (CRC) with manufacturer specified flow control
How it works
In this configuration, the silver-rich
overflow from the processor (A) is
directed to the electrolytic unit (B). When
sufficient silver-rich solution has
accumulated, the electrolytic unit begins to
desilver the solution. When the batch is
completed, the partially desilvered solution
is pumped out of the electrolytic unit (C)
into the holding tank (D). From here, it is
metered (E) at a fixed rate through the CRCs
(G, J). Once the solution exits the last CRC
(I) at least 99 percent of the silver has been
recovered and the solution can be
discharged to the drain (K).
Testing methods for silver recovery efficiency
There are two types of testing methods
you must use:
• once each week, silver estimating test
papers or another method of approximating
silver concentration must be used to
indicate whether the system is working (if
the paper shows any change in color, the
system is not working), and
• once every three months, highly
accurate analytical laboratory testing such
as atomic absorption (AA) or inductively
coupled plasma spectroscopy (ICP) must
be used. Use an outside service for
analytical testing. Review Appendix G for
detailed information about testing.
Testing procedures
1. To indicate whether the system is
working, check the solution weekly
with silver estimating test papers at
three locations:
• after the electrolytic unit at (D)
• after the first CRC at (H)
• after the last CRC at (J)
2. To verify the percent efficiency of the
system, use an analytical laboratory to
test the solution once every three
months, from two locations:
• before the electrolytic unit at (A)
• after the last CRC at (J)
See Appendix G for more information
about testing for silver
Testing records
• All test results must be recorded in a
silver recovery log. See the example
below. Check with the POTW to find
out how long to keep records on file.
Silver Recovery Log
Silver Recovery Log (mg/L)
Weekly Effluent Check*
Three Month Test
%
Influent Effluent Recovery
Date Electrolytic CRC #1 CRC #2
Date
7/1/96
P
P
P
7/5/96
1876
17
99%
7/8/96
P
P
P
10/5/96
2016
18
99%
7/15/96
P
F
P
* Pass (P) = no color, Fail (F) = color
When the weekly check indicates
cartridge failure, refer to the
equipment manual for the
manufacturer’s recommendations.
Code of Management Practice Guide for Commerical Imaging
1/5/97
To obtain the percent recovery, use
the following formula:
100 - (effluent x 100 ÷ influent).
4/1/97
17
2.. In-line electrolytic unit with a chemical recovery cartridge (CRC) with
manufacturer specified flow control
How it works
In this configuration, the silver-rich
overflow from the processor (A) is
continuously recirculated through the
electrolytic silver recovery unit (B) and
back into the fixer tank (A). Fixer
overflow (C) is fed into the holding
tank (D). From here, it is metered (E) at a
fixed rate through the chemical recovery
cartridges (E). Once the solution exits the
cartridge (H) at least 99 percent of the
silver has been recovered and the solution
can be discharged to the drain (I).
Testing methods for silver recovery efficiency
There are two types of testing methods
you must use:
• once each week, silver estimating test
papers or another method of approximating silver concentration must be used
to indicate whether the system is working
(if the paper shows any change in color,
the system is not working), and
• once every three months, highly
accurate analytical laboratory testing such
as atomic absorption (AA) or inductively
coupled plasma spectroscopy (ICP) must
be used. Use an outside service for
analytical testing.
Testing procedures
1. To indicate whether the system is
working, check the solution weekly
with silver estimating test papers at
three locations:
• after the electrolytic unit at (D)
• after the first CRC at (F)
• after the second CRC at (H)
2. To verify the percent efficiency of the
system, use an analytical laboratory to
test the solution once every three
months, from two locations:
• before the electrolytic unit at (A)
(in the fixer processing tank)+
• after the last CRC at (H)
See Appendix G for more information
about testing for silver.
Testing records
• All test results must be recorded in a
silver recovery log. See the examples
below. Check with the POTW to find
out how long to keep records on file.
Silver Recovery Log
Weekly Effluent Check*
Date Electrolytic
Silver Recovery Log (ppm)
Date
CRC
7/1/96
P
P
7/5/96
7/8/96
P
P
1/5/97
7/15/96
P
F
7/1/97
* Pass (P) = no color, Fail (F) = color
When the weekly check indicates
cartridge failure, refer to the
equipment manual for the
manufacturer’s recommendations.
Three Month Test
%
Influent Effluent Recovery
2500
129
95%
To obtain the percent recovery, use
the following formula:
100 - (effluent x 100 ÷ influent).
† Because no pre-silver recovery measurement is possible, a
baseline silver level of 2500 ppm is assumed.
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4. Off-site management
• Provide secondary containment for
storage drums, if required in your
jurisdiction.
• Comply with all applicable hazardous
waste and DOT regulations.
• Keep records of volumes and types of
solutions transferred off-site. See the
example log below.
How it works
In this configuration, the silver-rich
solution overflow from the processor is
stored in a drum (A) until it is picked-up
by a licensed hauler for off-site silver
recovery, treatment and/or disposal (B).
Commercial Imaging operations can
reduce the volume of waste using
evaporation or distillation to reduce
hauling charges. This technique does not
change the total amount of silver
available. (see Appendix E.)
Testing requirements
There are no Code of Management
Practice testing requirements for verifying
silver recovery efficiencies. State waste
agencies, however, may require testing in
order to characterize the waste.
Additional requirements
Commercial imaging processing
operations using off-site management must
meet the following requirements:
O ff - S i t e C h e m i c a l L o g
Date
Date
Amount
(gallons)
Type of
Solution
Manifest
Number
2/6/96
44
silver - rich photo
MI 3084201
3/5/96
44
silver - rich photo
MI 3084202
4/2/96
55
silver - rich photo
MI 3084203
5/7/96
48
silver - rich photo
MI 3084204
6/4/96
55
silver - rich photo
MI 3084205
• Maintain logs, hazardous waste
manifests, land disposal restrictions
forms and other records for at least five
years. Make the records available for
inspection by the sewage treatment
authorities.
• Verify that the contractor is properly
licensed to transport your waste and is
handling it correctly.
• Accumulate the silver-rich solutions in
a drum that’s compatible with
commercial imaging processing
solutions.
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6.0 Pollution Prevention
This section of the guide introduces several
voluntary activities that can result in preventing
pollution. We recommend that you read
through it and adopt any ideas that are
appropriate to your processing operation. While
many of these activities are better suited to
larger operations, there are some that can also
benefit even the smallest film processor
Your industry has a long history of
practicing waste minimization or waste
control, whether it’s through the use of
photo processing solutions with reduced
replenishment rates or reduction of silver in
films. Using good waste control practices
has two benefits: it can lower the impact
our businesses have on the environment
and it can save money through reduced
material consumption and labor.
In today’s language, waste control is
called pollution prevention. Pollution
prevention, or P2, is the name given to
good management practices, as well as
equipment and chemical modifications
that result in reducing or eliminating
waste—before it’s generated.
Most commercial imaging facilities are
already using some pollution prevention
practices. In this section of the Commercial
Imaging Guide to the Code of
Management Practice we’re going to give
you a method to look at your imaging
operation, identify options for pollution
prevention, put a voluntary P2 plan in
place and follow-up on the success of that
plan. The diagram on the next page
shows the five steps of P2 planning:
1. Put a team together of interested and
capable staff and management employees
to develop and oversee pollution
prevention activities in your facility.
2. Identify and review your options by
examining your current practices in light
of alternative or additional measures that
can reduce or eliminate waste.
3. Develop a P2 plan by deciding which
options you’ll adopt, the time frame for
adopting them, and who will be
responsible for overseeing the option is
implemented and maintained.
4. Put the plan in place by providing the
staff with pollution prevention training and
resources. Do not underestimate the
importance of the human factor.
5. Track your results and provide
feedback by keeping records where they
are helpful and by routinely auditing or
inspecting your imaging operation for
pollution prevention.
Not every pollution prevention activity
discussed in this section will make sense
for your facility. For example, if the
processing volume is low, an in-line silver
recovery system may not be a good
choice. This is just one example of why
it’s so important for you to conduct a
thorough review of your facility and
examine your options before you begin to
develop a P2 plan.
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Planning for Pollution Prevention
1
5
Put a
team together
2
Track your
results
Identify and review
your options
3
4
Develop a P2
plan
Put the
plan in place
In the following pages of this section, we
provide you with specific P2 information
and checklists to assess your performance.
6.1 Put a Team Together
A pollution prevention policy
A pollution prevention policy is a simple
and clear statement that waste reduction
and elimination are important goals of your
company. The policy can be developed
with the help of the P2 team (discussed
next). We’ve provided an example of a
policy. Make sure it’s signed by the
president, owner or plant manager to show
commitment and responsibility to P2
activities.
Once the policy is developed, it should be
posted for all employees, and customers,
to see.
Remember—the success of P2 depends
upon support from all the people in the
company.
Commitment from management and staff
is an essential element of a successful
pollution prevention plan.
Management shows its support by
1) developing, implementing and
maintaining a P2 policy, 2) forming a P2
team and 3) by allowing adequate time
and resources for P2 activities.
Staff shows its support by working with
management to ensure pollution
prevention is a priority.
a. Management activities
There’s no substitution for good leadership
in pollution prevention. Management has a
key role to play by setting direction,
eliminating barriers to change and
motivating employees.
Pollution prevention is a key
consideration in all our business
decisions and is the responsibility of
every employee including management
We have a P2 plan in place
incorporating internal practices and
procedures that result in reducing both
liquid and solid waste. The plan is
routinely evaluated and modified to
improve our P2 accomplishments.
Manager and date
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The P2 team
b. Staff activities
The pollution prevention team is the group
of managers and staff people who
develop, implement and evaluate all the
activities that go into making up the P2
plan.
Everyone has a part to play in pollution
prevention. Some staff will be part of the
P2 team. Their responsibilities will include
participation in the development and
implementation of the plan.
• How many people should be on the
team? That depends upon the size of your
operation. In a three or four person
printing company, it might be a team of
one—the manager. In a large company, it
might be a team of five or six. You decide
how many people you need.
The rest of the staff will be trained to
recognize pollution prevention
opportunities and to work in such a way
that doesn’t create waste in the first place.
• Who makes the best team member?
The best team member is someone who’s
interested in pollution prevention, wants
to be on the team and has a good
understanding of the entire Commercial
imaging system. In large companies, try to
get representatives of different departments
• What about a team leader? The P2
team needs a leader. Management can
leave that decision up to the team or it
can designate someone.
Time and resources for the P2 team
The P2 team needs time and resources to
do its job properly. Time means time to
meet, audit the facility, develop the P2
plan, implement it and periodically
evaluate it. Resources means training and
technical information such as equipment
operation, maintenance procedures, film
volume and replenishment rates.
Management must provide these as part of
its commitment to P2.
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Checklist
This checklist reviews all the elements for putting together a P2 team. When you have the team
in place, you should be able to answer “Yes” to all questions. “No” answers are potential
pollution prevention opportunities. When you don’t have adequate information to answer, mark
the “?” Then get the information you need to make an assessment.
Pollution Prevention Team
Yes
No
?
• Do you have a company P2 policy?
• Has it been signed and dated by management?
• Is the policy posted where all employees can see it?
• Is the policy posted where all customers can see it?
• Have employees been told about the P2 policy and its purpose?
• Has the P2 team been formed?
• Are the team members knowledgeable about film processing?
• Has a team leader been chosen?
• Does management provide the team with the time and resources
needed for P2 planning and implementation?
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as a starting point for your preventive
maintenance program.
6.2 Review Your Options
Pollution prevention options for processing
solutions can be broken into three
categories:
Process control
Process control is the routine monitoring
of variables that affect the quality of your
product. These variables include:
1) management practices,
2) equipment modifications, and
3) process modifications.
•
•
•
•
Each of these will be examined here. We’ll
also look at options for managing the solid
waste produced in a Commercial imaging
operation.
replenishment rates,
processing temperatures,
processing time, and
chemical mix procedures.
They should be checked on a periodic
basis to ensure that the film image quality
is good and waste is minimized. These
variables should be monitored on a set
schedule tied to the preventive
maintenance schedule.
At this phase of the P2 process, we’re only
looking at the available options. After each
discussion, we’ve included a checklist for
you to evaluate your practices and
equipment. A “Yes” answer means you’re
already practicing that P2 activity. Anytime
you answer “No” you’ve found a potential
pollution prevention opportunity. Anytime
you answer “?” it means you need more
information to evaluate the option. When
you finish, look back at the checklists and
with the team, choose the best P2 options
for your company.
Commercial imaging operations should
also routinely run control strips, chart the
results of each strip (as shown on the chart
below) and take action based on the
results.
Example process control chart
Process Control Chart
a. Management practices
Developer Speed
Effective Contrast Index
Developer Whatadot
Date Installed December 22
Repl Rate
9
Fixer
Date Installed December 12
Repl Rate
9
Supra Universal
6.6
6.1
18
13
8
Time
5
8
9
10
11
15
16
17
18
19
22
23
25
30
31
31
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
Code of Management Practice Guide for Commerical Imaging
5
2
6
2
7
2
8
2
9
9
2
2
12
13
14
14
16
19
20
24
26
28
2
2
2
2
2
2
2
2
2
2
1
4
3
5
3
5
3
6
3
3
Dev switch
stuck
4
1
Repl Dev
& Fix
4
Fresh Fixer
3
1 1
Repl Dev
Day
Month
Repl Dev
Preventive maintenance
Preventive maintenance should be your
first pollution prevention option. By
implementing a complete preventive
maintenance program, the equipment will
work at its optimum level, keeping waste
at a minimum. Use the recommendations
found in the equipment operating manual
Machine Speed 30 seconds
90°F
Developer Temp
Notes
Some of the easiest and least expensive
management practices produce the most
effective pollution prevention results. Keep
this in mind as we look at the following
management practices.
#138
Control Strip #
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24
Inventory control
Managing the chemical inventory includes
rotating the stock so that the oldest is used
first and maintaining an appropriate supply
of chemicals on-hand. This reduces the
risk of having old chemicals in inventory
and reduces the amount of money tied-up
in overstock.
Spill response planning
Any time a solution is unintentionally
released it’s a spill. The key word is
unintentional. When you produce a waste
solution during rack washing, it’s
intentional. But if a container of
photographic processing solution is
dropped on the floor, ruptures and leaks,
you have an unintentional spill.
Most spills are minor splashes or leaks and
can be cleaned up with a sponge or mop.
Occasionally, however, a larger spill could
occur requiring specialized clean-up
materials and procedures.
• a description of the containment used
for silver recovery cartridges, mixing
tanks, chemical storage tanks and any
other containers that could leak or
rupture;
• a list of spill response supplies and
equipment such as mop, pail, sponge,
co-polymer or other absorbent
materials, neutralizing materials and
personal protective equipment; and
• a set of tested procedures for
responding to a spill. A sample spill
response procedure, as shown below is
included in Appendix H.
Mr. Opaque Pre-Press Ltd.
SPILL CONTINGENCY PLAN
Spill Response Personnel
Don Spillit
999-5555
Name
pager/phone
Ruth Typeset
555-9999
Name
The time to plan for a spill is long before it
happens. A good spill response plan will
help minimize the effects of the spill on
the environment and ensure the
Commercial imaging facility returns to
normal as quickly as possible. Some of the
things to include in your spill response
plan include:
pager/phone
Bill Sorbit
898-5656
Name
Environmental
Emergency
Phone
pager/phone
(999) 999-9999
24 hours a day
7 days a week
EQUIPMENT REQUIRED
• Gloves
• Apron
• Goggles
• Bucket
• Mop
• Sponge
•
•
Absorbent Materials
Neutralizing Materials
SPILL RESPONSE PROCEDURES
1. Put on gloves, goggles and an apron.
2. Contain the spill with a mop or absorbent materials available.
3. Check the appropriate material safety data sheet (MSDS) for special
handling, ventilation, personal protection or other pertinent data.
4. Clean up the spill, as directed, using generous amounts of water.
• an inventory of all the chemicals used
in the commercial imaging operation;
5. Use the mop and sponge to clean the area thoroughly.
6. Package and label all contaminated absorbent materials for off-site
disposal.
7. Notify the supervisor or manager that a spill has occurred.
8. (If required) Notify appropriate government agency that a spill has
occurred.
• a floor plan showing the location of all
chemicals in the processing area, floor
drains, exits, fire extinguishers and spill
response supplies;
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Good housekeeping
In a clean and orderly operation, there’s
better control over materials and
equipment and less likelihood of spills.
This results in less operational waste and
prevents pollution.
Good housekeeping is one of those
inexpensive and simple management
practices that can significantly reduce
waste, increase productivity and lower
costs. You can’t afford to neglect it.
Here are three basic good housekeeping
guidelines:
1. Designate an appropriate storage area
for all materials and equipment.
2. Require every employee to return all
materials and equipment to their
designated area.
Safety and security
Keeping chemical areas safe and secure
can minimize spills and other upsets.
• Make sure there is always someone
trained in spill response procedures in
the facility or who can be contacted to
respond immediately.
• Restrict staff admittance to areas where
chemicals are used and stored to staff
who have had hazard communication
training.
• Make sure there’s an MSDS on file for
every chemical in the facility.
• Maintain a security system so that you
know when someone is in the facility,
both during and after working hours.
3. Establish a procedure and a schedule
to inspect chemical receiving, storage,
mixing and use areas for spills, leaks,
cleanliness and orderliness.
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Checklist
This checklist reviews all the elements for evaluating management practices. “Yes” answers
indicate that you’re already using that pollution prevention measure. “No” answers are potential
pollution prevention opportunities. When you don’t have adequate information to answer, mark
the “?” Then get the information you need to make an assessment.
Management Practices
Preventive Maintenance
Yes
No
?
Yes
No
?
Yes
No
?
Yes
No
?
• Is there a preventive maintenance program in place incorporating
all the equipment manufacturer recommendations?
Process Control
• Are solution replenishment rates routinely monitored?
• Are processing tank temperatures routinely checked?
• Are processing times routinely checked?
• Are standard chemical mix procedures used by all staff?
• Are control strips run on processors at least once per shift?
• Are all control strips plotted on control charts?
• When corrective action is taken, is it noted on the control chart?
Inventory Control
• Is the oldest chemical stock always used first?
• Are appropriate levels of stock maintained?
Spill Response Planning
• Is there a spill response plan?
• Is it posted in the chemical mix area?
• Is an inventory of all chemicals posted in the imaging area?
• Is there a floor plan detailing the location of chemicals, floor
drains, exits, fire extinguishers and spill response supplies?
• Is there containment around all permanent chemical containers?
• Are the spill response supplies easily accessible?
• Are spill response personnel properly trained?
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Management Practices (continued)
Good housekeeping
Yes
No
?
Yes
No
?
• Are all materials and equipment kept in a specified location?
• Are all chemical containers routinely checked for cracks or leaks?
• Is all equipment wiped clean of chemical residue and dirt?
• Are all floors free of chemical spills and residue?
• Are aisles and walkways clear?
• Does the Commercial imaging area look orderly and clean?
• Are all employees held accountable for good housekeeping?
Safety and Security
• Is there at least one staff member trained in spill response in
the facility at all times?
• Are areas where chemicals are used and stored restricted to
staff trained in safe chemical handling?
• Is there an MSDS for every chemical in the facility?
• Is there a security system in place during working and
nonworking hours?
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b. Equipment modifications
A second category of pollution prevention
options is equipment modifications. This
refers to the changes made to film and
paper processors to reduce the amount of
waste solution produced through
processing. As we examine each of these
options remember what we said earlier:
Not every one of these options is
appropriate for your equipment. In some
cases, equipment cannot be modified or is
not an economical option. Check with
your equipment manufacturer.
Squeegee Rollers
Squeegees rollers are an effective P2
option that improves silver recovery. As
the film exits the fix tank, it carries over a
certain amount of silver-rich solution into
the wash. Squeegee rollers reduce
carryover, therefore keeping the silver in
the fix tank where the overflow can be
sent to silver recovery instead of being lost
in the wash tanks.* Care and routine
maintenance can extend the life and
effectiveness of squeegee rollers.
There are other benefits of in-line silver
recovery. Generally, it’s possible to use a
lower fix replenishment rate which means
lower fixer consumption. Additionally, the
silver recovered is high grade silver flake.
If you use in-line silver recovery, check
with your chemical supplier to determine
if you need a specially formulated fixer.
Stand-by Wash
Today, most processors come equipped
with an extremely efficient water saving
device called stand-by wash. This controls
the wash water so it runs only when the
film is being processed. When the film
clears the machine, the wash goes into
standby position and doesn’t begin again
until the next film is processed. This
equipment modification can save
hundreds of gallons of water. If you have
an older machine, check with your
supplier to find out if it is possible to have
it modified for a standby wash.
In-line silver recovery
Another way to reduce the silver carried
over from the fix tank into the wash tanks
is to reduce the concentration of silver in
the fix. This can be done with in-line
silver recovery.
In-line silver recovery is an electrolytic
unit through which the fix in the processor
tank is recirculated and constantly
desilvered. Because the silver
concentration is kept at a low, fixed
amount, this significantly reduces the
concentration of silver carried over into
the wash.
*
Squeegee rollers are also used between the developer
and fixer tanks. This minimizes developer carryover that
contaminate the fixer.
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Checklist
This checklist reviews all the elements for evaluating equipment modifications. “Yes” answers
indicate that you’re already using that pollution prevention measure. “No” answers are potential
pollution prevention opportunities. When you don’t have adequate information to answer, mark
the “?” Then get the information you need to make an assessment.
Equipment modifications
Squeegee Rollers
Yes
No
?
Yes
No
?
Yes
No
?
• Are there squeegee rollers on processors capable of being equipped?
• Are all squeegee rollers routinely checked and replaced?
• Are all squeegee rollers cleaned as part of the shut-down procedure?
In-line Silver Recovery
• Is there an in-line electrolytic unit on all film fixer tanks?
• Is the silver concentration in the tank monitored so that it
doesn’t get below 500 ppm or above 1000 ppm?
• Is the fixer appropriate for in-line silver recovery?
• Has the fixer replenishment rate been reduced?
Standby Wash (if applicable)
• Are the processors equipped with standby wash?
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c. Process modifications
The third category of pollution prevention
options is process modifications. Just as
with equipment modifications, not all
processors can be changed to
accommodate every one of these process
modifications.
Solution regeneration and reuse
Regenerating and reusing fixer may reduce
the amount of chemicals to be desilvered
or discharged to the drain. If the
equipment can be modified and the film
use is high enough, this pollution
prevention option can significantly reduce
waste. Talk with your film and chemical
suppliers to find out if this option is
appropriate for your facility.
Because wash water has a direct affect on
image stability, always consult with your
film manufacturer before making water
conservation modifications to the
processors.
Dry chemicals and automated mixing
Under some conditions, dry chemical
packaging and automated mixing can
contribute to waste minimization through
extended shelf life and less packaging
material.
Off-site chemical recycling may also be an
option. In this case, the film processing
facility collects the fixer overflow at the
processor and periodically ships the
collected solution to the recycler, From
here, the fixer is desilvered and also
regenerated for reuse. The regenerated
fixer is then returned to the film
processing facility to be used as fresh
chemical.
Water reuse and recycling
Reducing the amount of water used in
processing reduces waste and conserves a
valuable resource. Optional process
modifications for water conservation
include:
• wash water recycling equipment
• manufacturer kits such as metered
wash water replenishment and wash
water timers.
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Checklist
This checklist reviews all the elements for evaluating process modifications. “Yes” answers
indicate that you’re already using that pollution prevention measure. “No” answers are potential
pollution prevention opportunities. When you don’t have adequate information to answer, mark
the “?” Then get the information you need to make an assessment.
Process modifications
Replenishment
Yes
No
?
Yes
No
?
Yes
No
?
Yes
No
?
• Have replenishment rates been measured or adjusted
to manufacturer specifications
Solution Reuse
• Are chemicals regenerated where it’s practical?
• Is the portion of the silver-rich chemicals that is not regenerated
sent for silver recovery?
• Are chemicals reused where it’s practical?
Water Reuse and Recycling
• Are wash water rates set at manufacturer recommendations?
• Does the wash water run only during processing?
• Is wash water conservation being used?
(e.g., metered wash water replenishment or wash water timer)
Other Process Modifications
• Are dry chemicals used where it’s practical?
• Are automated mixers used where it’s practical?
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Some cities have recycling programs for
corrugated cardboard, office paper and
other materials. Reusing and recycling
reduces the amount of solid waste going
to landfill and lowers your waste disposal
fees.
d. Solid waste
There are pollution prevention
opportunities for reducing the solid waste
produced in Commercial imaging. For
example, film can be sent out for
processing and silver removal. Some
manufacturers will recycle plastic end
caps and chemical cubitainers.
The example below is from a pre-press
facility. Use it as a guideline in developing
a pollution prevention guide for your
operation.
P2 Opportunities in a Commercial Imaging Operation
Packaging
Materials
Supplies
film, plates
acetate,
cutting blades
proof materials
tissue
boxes
film
Chemicals
developers
fixer, film cleaners
glass cleaners
system cleaners
Pre-press Facility
waste film
recycled
waste plates
recycled
waste vinyl
trash
waste acetate
trash
Products
film
proofs
plates
silver-rich solutions
silver recovery
packaging materials
trash
recycled
sewer
low-silver solutions
sewer
systems cleaner
sewer
recycled
waste water
sewer
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Checklist
This checklist reviews all the elements for evaluating your solid waste management program.
“Yes” answers indicate that you’re already using that pollution prevention measure. “No”
answers are potential pollution prevention opportunities. When you don’t have adequate
information to answer, mark the “?” Then get the information you need to make an assessment.
Solid Waste
Are the following solid wastes reused:
Yes
No
?
Yes
No
?
• Plastic core protectors?
• Paper cores (cardboard)?
• Photographic paper bags?
• Processing equipment filters?
• Packing materials including pallets and plastic wrap?
Are the following solid wastes recycled:
• Films and plates?
• Chemical containers or cubitainers?
• Unwanted or excess exposed and processed film
• Paper cores (cardboard)?
• Office paper?
• Corrugated cardboard?
• Box board?
• Packing materials including pallets and plastic wrap?
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6.3 Develop a P2 Plan
Now that the P2 team has finished the
audit or review, it’s time for them to look
at all the options and prioritize them as:
• High priority—needs immediate
action
• Medium priority—needs action within
3 to 12 months
• Low priority—needs consideration
within the next 1 to 2 years
Screening your options
Screen each option by asking the
following questions and writing out your
answers:
1. What is the potential for reducing
waste and providing other
environmental benefits?
2. What is it going to cost in time,
materials and equipment costs?
3. How much money will it save in time
and materials?
4. How difficult is it to implement?
To show you how this works, look at the
following example of screening the option
of using in-line silver recovery on the film
processor. A blank worksheet is included
in Appendix H. Make copies as you need
them and leave the original in this Guide.
Example Worksheet for Screening Options
Date 1/17/97
Option: Installing and maintaining an in-line silver recovery unit on the processor
1. What is the potential for reducing waste and providing other environmental benefits?
Less silver will be lost to the wash tank and therefore the drain. In addition, we may be able to
reduce replenishment rates.
2. What is it going to cost in time and materials?
Cost of the electrolytic unit, labor for installation and periodic replacement, and labor for
maintenance. (Estimate actual costs as closely as possible.)
3. How much money will it save in time and materials?
The savings will come in the increased amount of silver recovered (estimate actual savings as
closely as possible) and lower fix replenishment rates.
4. How difficult is it to implement?
Not difficult, We can schedule the installment during the next preventive maintenance check on
the machine. We need to buy the electrolytic unit. We also need to train process operators to
keep the silver concentration about 500 ppm to reduce the potential for sulfiding.
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Screening all the options you’ve identified
will take time but it’s time well spent. It’s
very important that you actually write out
your answers. Doing your homework here
makes the difference between a P2 plan
that exists only in your head vs. one that is
implemented and working.
Point system
You might find it useful to develop a point
system for rating all the options. For
example, you could assign a plus value to
every potential benefit and a minus value
to every negative impact.
these into place and evaluate your success
before addressing the medium and low
priority options. Don’t make too many
changes as once—start with only 1 or 2
items.
Keep your P2 plan simple. Here is the
information you should include:
• Spell out each option and its purpose
• State a specific date when the option
will be implemented
• List who is responsible
Writing the P2 plan
Whatever system you use, you need to get
to the point where you’ve prioritized all of
the options. Now you can begin to draft
the P2 plan. For your first attempt at
systematic pollution prevention, we
recommend that you start with only the
high priority options. Work at getting
• Note if a record will be kept
Review the example below. A blank
Pollution Prevention Plan Worksheet is
included in Appendix H. Make copies as
you need them and leave the original in
this Guide.
Example Pollution Prevention Plan Worksheet
Date 2/08/97
Option or activity: We’re going to install the in-line unit on the film processor in order
to reduce the amount of silver in the wash water.
Implementation date: The unit will be installed during the December preventive
maintenance check.
Responsibility:
Joe Smith, maintenance supervisor, will spec the unit, arrange for purchase,
develop an installation plan, ensure it is installed and be responsible for seeing it is
maintained. He will also train the process operators how to maintain and harvest the silver.
Record: In-Line electrolytic maintenance will be added to the preventive maintenance
checklist.
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6.4 Put the Plan in Place
Now that you have a P2 plan it’s time to
put it into action. These are the steps:
1. Make the plan known - Post it, explain
its purpose and details to the employees,
and talk it up. Through both your words
and actions, make all employees aware of
how committed management is to
pollution prevention. Keep employees
updated on both the successes and failures
of the plan.
2. Provide training and education - Make
sure that anyone who is given responsibility
in the P2 plan has the training and
knowledge to carry out his/her tasks.
need to periodically review it, evaluate
which elements are working, which need
to be modified and which need to be
discontinued. A review every six months
should be often enough.
As you evaluate your P2 plan, keep in
mind your original intent for pollution
prevention: minimizing or eliminating
waste for both environmental and
economic benefit.
Answer each of the following questions for
each pollution prevention option or
activity listed in your plan:
• How much waste has been reduced or
eliminated as a result of this activity?
• How much has it cost?
3. Provide the necessary resources - Make
sure that anyone who is given responsibility
in the P2 plan has the time and materials
required to fully implement the P2 plan.
6.5 Track Your Results
Your P2 plan isn’t a “Now I’ve done it so I
can forget about it” kind of thing. You
• How much money has it saved?
In some cases, it may be hard to get exact
answers to these questions. But try. It’s
important that you fully evaluate every P2
option implemented in your commercial
imaging operation. Once again, let’s look
at installing an in-line unit as an example.
Example Worksheet for Evaluating P2
Date 4/20/97
Option: Installing and maintaining in-line electrolytic silver recovery unit on the film
processor
1. Waste reduction results
After analyzing the wash water, we found the concentration of silver went from 95 ppm to 12 ppm.
Over the 6 month period, we estimate this represents 386 troy ounces of silver.
2. Costs
Materials - unit= $1240. Labor - installation 1 1/2 hours x $20/hour = $30. Daily maintenance - 1
minute at $12/hour = $.20 daily or $24 for 6 months. Total costs = $1294
3. Savings
386 tr. oz. of silver at $5.40 tr. oz. = $2084. This was the amount of silver diverted from the wash.
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A successful P2 option or activity is one
that reduces waste and saves more money
than it costs. Consider whether changing it
would make it even more successful or
whether to let it continue as is.
An unsuccessful option or activity is one
that doesn’t reduce waste, or it costs more
money than it saves. With an unsuccessful
option, consider whether changing it
would make it successful or whether to
discontinue using it.
Once you’ve done this evaluation for
every option, you can also consider
whether it’s time to put some of those
medium priority options in place.
Remember not to make too many changes
at once.
Spread the word
Every time you evaluate the success of the
P2 plan, let the staff know the results—
both the positive and the not so positive.
When you decide to make changes or
implement new P2 activities, remember to
train the staff if there are any new
procedures.
Include your P2 success stories in your
facility's annual report or newsletter. If
there’s no environmental section in the
report, now is a good time to start one.
With pollution prevention, everyone’s a
winner: the impact of your business on the
environment is reduced and the cost
savings from lower waste means more
money in your pocket.
P2
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Appendix A
Glossary of Terms
AMSA: The Association of Metropolitan
Sewerage Agencies represents the interests
of the country’s largest wastewater
treatment agencies. AMSA maintains a key
role in the development of environmental
legislation and implementation of
environmental rules, guidance and policy.
Anode: The positively charged electrode.
When electrolytically desilvering
commercial Imaging processing solutions,
the thiosulfate is oxidized at the anode.
Batch Process: The collection of silver-rich
solution into a tank or container which is
processed through a silver recovery or
management system.
Biocide: A chemical that discourages the
growth of bacteria.
Cathode: The negatively charged
electrode. When electrolytically
desilvering commercial imaging
processing solutions, metallic silver is
deposited on the cathode.
Commercial Imaging Facility: A facility
processing pre-press film, micrographics
or any other nondiagnostic black and
white photographic process.
Code of Management Practice (CMP): The
site-specific plan implemented by the
individual processing facility for the
purpose of controlling and reducing
discharges of silver to the POTW.
Continuous Process: The processing of
silver-rich solution in a continuous flow
from the processing machine through a
silver recovery or management system.
Cradle-to-Grave: A phrase used to
describe the tracking system for hazardous
waste. All parties in the waste chain—
generator, transporter, storage and disposal
facilities—use a common manifest that
identifies them, the waste, and the final
disposition of the waste.
CRC: A chemical recovery cartridge which
recovers silver through a process known
as metallic replacement.
Distillate: The liquid recovered by
condensation during the process of
distilling or concentrating used processing
solutions and wash waters.
DOT: Department of Transportation
Effluent: The solution exiting a process or
piece of equipment.
Electrolytic Silver Recovery: A method of
recovering silver in which a direct current
is applied across two electrodes immersed
in a silver-rich solution. Silver plates onto
the cathode and the thiosulfate is oxidized
at the anode.
Good Housekeeping: Maintenance of a
neat, orderly and clean working
environment.
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Influent: The solution entering a process
or piece of equipment.
Ion Exchange: A reversible exchange of
ions between a solid (resin) and a liquid
(water containing ionized salts). When
used with photo processing solutions, ion
exchange removes silver and replaces it
with ionized salts.
Large Commercial Imaging Facility: A
facility which produces on average more
than 20 gallons per day (GPD) of silverrich solution.
Low-Silver Solution: A solution containing
insufficient silver for cost effective silver
recovery. Low-silver solutions include
used developers, stop baths and wash
waters.
Manufacturer Specified Flow Control:
means a pump or restricted orifice
required by the manufacturer to meet and
maintain the silver recovery efficiency for
metallic replacement cartridges.
Medium Commercial Imaging Facility: A
facility which produces on average more
than 2 but less than 20 gallons per day
(GPD) of silver-rich solution and uses less
than 10,000 GPD of process wash water.
Metallic Replacement: A method of
recovering silver from silver-rich solutions
by an oxidation-reduction reaction with
elemental iron and silver thiosulfate to
produce ferrous iron and metallic silver.
The device used is commonly called a
chemical recovery cartridge (CRC).
Milligrams per Liter (mg/L): mg/L is the
same measurement as parts per million
(ppm).
Off-Site Silver Recovery and
Management: Removal of silver-rich
solutions from a facility by a hauling
service to a recovery facility.
On-Site Silver Recovery and Management:
The management and treatment of silverrich solutions on the premises in which the
silver-rich solutions are generated.
pH: An expression on a scale from 0 to 14
of the extent of acidity or alkalinity of a
substance. Materials with a pH of 7 are
neutral. Those below pH 7 are acidic and
those above pH 7 are alkaline.
Pollution Prevention: Any practice that
reduces or eliminates waste at the source.
POTW: Publically Owned Treatment
Works. A wastewater treatment facility
(WWTF) owned by the public
(municipality or service authority).
Pre-Press: The photographic process used
in preparing film and separations.
Preventive Maintenance: A set of
procedures routinely performed on
equipment and processes to reduce the
risk of a malfunction.
Pretreat: To change the characteristic of a
waste by treatment before it is discharged
to a POTW.
Significant Industrial User (SIU): Any
industrial user that: discharges an average
of 25,000 GPD or more of process
wastewater to a POTW; contributes a
process waste stream which makes up 5%
or more of the average dry weather
hydraulic or organic capacity of the
POTW; or, is designated as such by the
Control Authority on the basis that the
industrial user has a reasonable potential
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for adversely affecting the POTW’s
operation or for violating any pretreatment
standard.
Source Reduction: A decrease in the
production of both the volume and
toxicity of liquid waste.
Silver Recovery: The process of reclaiming
silver from silver-rich solutions such as
fixers and low flow washes.
Spill: Unintended release of liquid that is
not in the ordinary course of events.
Silver-Rich Solution: A solution containing
sufficient silver that cost effective recovery
could be done either on-site or off-site.
Silver-rich solutions include fixers and low
flow wash.
Silver Estimating Test Paper: A test paper
coated with an analytical reagent which
reacts by changing color in relationship to
the amount of silver in solution. A
reference color code allows users to
estimate the approximate amounts of silver
in solution.
Small Commercial Imaging Facility: A
facility which produces on average less
than 2 gallons per day (GPD) of silver-rich
solution.
Squeegee: Physical device (e.g. rollers.)
used on processors to remove residual
surface liquids before the film or paper
travels from one processor tank to the
next.
Sewer: An underground conduit for
carrying wastewater to a POTW.
The Silver Council: A national group
supported by the photographic chemical
and equipment manufacturers and
representing more than 360,000 users
whose focus is to achieve source
management of silver-bearing
photographic imaging materials in the
least restrictive regulatory environment.
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Appendix B
Electrolytic Silver Recovery
Electrolytic recovery is an efficient and
cost-effective silver recovery technology
first used in 1931. Since then the
equipment has evolved and been refined
so that today’s electrolytic units are
reliable and can consistently achieve 90%
recovery efficiency. The equipment is
continuously reused and few additional
chemicals are required to perform the
recovery operation.
Electrolytic Unit
B.1 How it Works
Throughout this discussion, refer to the
diagram in the right-hand column. In
electrolytic silver recovery two electrodes
are immersed in silver-rich solution.
Electric current reduces the silverthiosulfate complex in the solution and
plates almost pure silver metal onto the
cathode—the negatively charged
electrode. The cathode is typically made
of stainless steel. The amount and quality
of the silver plated out depends upon the
operating amperage and the length of time
the solution is exposed to the current.
There are two basic types of electrolytic
equipment: one in which the cathode
rotates in the solution and the other in
which the solution flows around a stationary
cathode. Either type of equipment is
capable of recovering a significant amount
of the silver from the silver-rich solutions.
In Addition, there are batch units and
flow-though units. In the batch unit, the
solution is collected within a chamber
inside the electrolytic unit until there is
sufficient quantity to constitute a batch.
The solution is then pumped out all at
once, usually into a secondary recovery
system. In a flow-through unit, the silver is
recovered continuously as it flows into the
unit. This solution is displaced as more
processor overflow enters the electrolytic
unit.
Depending on the percentage removal
required, electrolytic units must be used in
conjunction with another system.
In-line electrolytic silver recovery
By using in-line electrolytic silver recovery
on fix solutions, the amount of silver in
solution is significantly reduced. This
results in less silver carried over into the
final wash water and subsequently
discharged to the sewer. Where the use of
in-line silver recovery is possible, mixing
and chemical usage can be reduced by up
to 50 percent, further increasing the cost
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effectiveness of this technology. This
approach may not be feasible in all
circumstances. Solution overflow from inline systems must be treated by another
system to further reduce the silver
concentration.
B.2 Proper Operation
The electrolytic unit must have enough
capacity to treat peak volumes of silverrich chemical effluent produced by the
printer. The manufacturer/supplier of the
electrolytic unit can help the commercial
imaging processor choose the appropriate
equipment and provide preventive
maintenance information. Generally
electrolytic unit are monitored for the
following: pH; silver concentration; sulfite
concentration; time and amperage; and,
mechanical operation. All of these are
discussed below.
a. pH
Fix solutions from commercial imaging
processes are usually easy to desilver
electrolytically and require little, if any,
pH adjustment.*
b. Silver concentration
The concentration of silver in the
overflows from commercial imaging
operations will typically range from
approximately 2,000 - 4,000 ppm prior to
electrolytic recovery.
Recovery efficiency is directly related to
silver concentration; the higher the silver
concentration, the higher the plating
efficiency. Replenishment rates play an
important role in determining this
concentration level. Over replenishment
dilutes the amount of silver. When silver
concentration falls below 500 mg/L,
plating efficiency decreases significantly
thus reducing the recovery rate of the
electrolytic unit.
It's very important to calibrate
replenishment rates on the processors
routinely.
c. Sulfite concentration
In the plating process, for each atom of
silver plated out of solution the process
consumes one atom of sulfite. It’s
necessary, therefore, to have sufficient
sulfite in the solution. This is particularly
important in in-line electrolytic silver
recovery where the fix solution is
continually recirculated through the
processing tank. Any degradation of the
fixer can affect the final product. Check
with the equipment manufacturer or
chemical supplier to find out if you should
be using a fix with an increased level of
sulfite.
d. Time and amperage
Many of the electrolytic silver recovery
units sold today are automatic so the
operator doesn't have to set plating
current and batch times—two critical
factors in electrolytic silver recovery. The
correct plating current must be maintained
to drive the silver out of solution onto the
cathode. If the plating current is too high
or the plating time too long, the silver
deposited on the cathode will be black
and sludgy, with much of it falling off the
cathode and collecting on the bottom of
* It is highly recommended not to exceed a pH of 8.5.
Above this level significant ammonia air emissions are
released.
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the electrolytic unit. This situation, known
as sulfiding, results in a low quality silver
and a mess to clean. To avoid sulfiding,
follow the manufacturer recommendations
for setting both the plating time and
amperage.
Attempts to achieve higher efficiencies
than those recommended by the
manufacturer can actually lead to lower
silver recovery. By over extending the
plating time or significantly raising the
current density, sulfiding will occur. This
results in coating the cathode with a black
sulfide precipitate rendering it unsuitable
for continued silver recovery.
e. Mechanical operation
General mechanical preventive
maintenance should be conducted
periodically to ensure the plating current
is correct, the cathode is rotating or the
pump is working, and the color of the
silver on the cathode is creamy-grey rather
than black or white. The silver should be
harvested (removed from the cathode)
periodically and sent to the refiner.
The person who is responsible for silver
recovery should follow all manufacturer
recommendations for preventive
maintenance and keep accurate records
of any maintenance performed.
•
Make sure you receive the
operations and maintenance
manuals for your silver recovery
equipment. These manuals are part
of the purchase price of your
equipment and you are entitled to
them.
•
Obtain data from the silver
recovery equipment manufacturer/
supplier demonstrating the
performance capability of the
equipment. For example, if you are
required to recover silver to
99 percent efficiency, ask the
manufacturer to provide you with
data showing the equipment can
achieve this level.
The most common mechanical problem
with electrolytic units is a poor electrical
connection to either the anode or the
cathode. It is important that terminals and
wires do not come in contact with
solutions. Corroded terminals or cables
will result in poor plating.
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Appendix C
Chemical Recovery Cartridges
Chemical replacement cartridges are a
relatively low cost method of achieving a
fairly high level of silver recovery.
Chemical Recovery Cartridge
C.1 How it Works
Metallic replacement is a process that
occurs when a solution containing
dissolved ions of an active metal such as
silver, contact a more active solid metal
such as iron. The more active metal, iron
which is contained in a cartridge, reacts
with the silver and dissolves in solution.
The less active metal, silver, becomes a
sludge or solid and collects in the
cartridge.
In essence, the dissolved silver in solution
changes places with the solid iron in the
cartridge. The exchange reaction is
dependent on the contact of the silverthiosulfate in solution with the iron
surface. To ensure good and controlled
contact, metallic replacement is
accomplished by metering the silver-rich
solutions through a cartridge of iron. As
silver is removed from the solution, the
iron metal filler in the cartridge becomes
depleted. The cartridge is then replaced
with a new cartridge and the accumulated
silver sludge is sent to be refined.
A typical metallic replacement cartridge
generally called a chemical recovery
cartridge (CRC) is shown in the diagram
on the right.
There are a variety of CRCs on the market
today. They contain iron in the form of
chopped steel wool, spiral wound steel
wool, a heavy iron mesh similar to door
screening material, or iron chips
imbedded into a fiberglass support.
A properly designed and maintained
single-cartridge CRC system is capable of
recovering more than 95 percent of the
silver from silver-rich solutions when used
in accordance with manufacturer specified
flow rates. A two-cartridge system is
capable of recovering 99 percent of the
silver.
Where the flow of solution through the
cartridge exceeds its rated capacity, flow
control must be used. While a metering
pump is generally recommended, in
extremely low volume situations, a flow
restrictor may be adequate.
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C.2 Operation/Maintenance
The manufacturer/supplier of the CRC can
help the photo processor choose the
appropriate equipment. This is also the
best source of preventive maintenance
information. Generally chemical recovery
cartridges are monitored for the following:
flow rate; channeling; obstruction; pH;
and, cartridge capacity.
only a small amount of the iron to be used
(that along the channel). When channeling
occurs, only low levels of silver are
recovered and high levels are discharged
from the CRC.
To avoid channeling: (1) select the proper
size CRC for the average volume of film
and paper processed in your lab, and (2)
prefill the CRC with water just prior to
introducing chemical solutions into it.
a. Flow rate
The length of time the silver-rich solution
is in contact with the iron is critical for
effective silver recovery. If the solution
flows through the CRC too quickly, it will
not contact the steel wool long enough for
the iron/silver reaction to occur. The lower
the flow rate, the better the recovery.
A pump or restricted orifice is used to
meter the solution at a prescribed rate from
the holding tank to the first CRC in the
series. To ensure proper flow rate, calibrate
the metering pump each time the CRCs are
replaced. Consult the manufacturer for the
optimum flow rate.
b. Channeling
As the recovery cartridge is used, the
active surface area is used up and small
channels will begin to develop in the iron
material. This is known as channeling. It
also occurs when a CRC is used only
intermittently due to low volume. When a
small volume of solution enters the CRC
and sits on the surface, it slowly eats
through the steel wool, forming a vertical
shaft or channel as it goes. As more
solution enters the CRC, it takes the path
of least resistance and flows through the
channel, thus contacting very little of the
steel wool in the cartridge. This causes
c. Obstruction
When the iron in solution contacts air,
iron hydroxide or rust forms. If the rust is
allowed to build up in the lines leading
into and out of the CRCs, it can eventually
restrict the flow of solution causing the
solution to back up. The CRC may also
leak around the fittings and cover.
Obstruction also occurs when the center
core of the CRC is crushed or damaged
and the solution cannot pass through it. If
this happens, replace the CRC with a new
one. Consult the CRC supplier for
information.
Finally, rust that passes through the CRC
can eventually build up in the floor drain,
requiring expensive drain cleaning.
Monitor the system regularly for
obstruction. Remove the lines and rinse
them with hot water each time the CRCs
are replaced. Do this more often if there
are several hours each day when no
solution is flowing through the CRCs. Be
sure to run the overflow system downhill
so there’s no chance of back-up.
To reduce the possibility of rust in the
lines, make a loop in the line that will
create an airlock.
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d. pH
For best results with CRCs, the pH should
be between 4.5 to 5.5. If the pH is too
low, the steel wool is etched too quickly
reducing the life of the CRC. If the pH of
the solution is too high, etching does not
occur so the silver/iron exchange reaction
can't take place. Also, at higher pH levels,
iron hydroxide (rust) is formed which can
cause obstructions in the lines and drains.
new CRC, mark the installation date on the
cartridge.
Check with your local POTW authorities to
find out how long to keep these records on
file.
Blank silver recovery log forms are
provided in Appendix H. Make copies of
these forms when you need them. Keep the
originals in this Guide.
Try to maintain a consistent pH in the
influent going to the CRCs. This is best
accomplished by plumbing the silver-rich
overflow directly from the processors to
the silver recovery system. Typically the
pH of commercial imaging fixers are
between 4.5 and 6.5, and will not require
pH adjustment. Work with your
equipment supplier to determine the best
pH for your CRCs.
The person who is responsible for silver
recovery should follow all manufacturer
recommendations for preventive
maintenance and keep accurate records
of any maintenance performed.
e. Cartridge capacity
•
Make sure you receive the
operations and maintenance
manuals for your silver recovery
equipment. These manuals are part
of the purchase price of your
equipment and you are entitled to
them.
•
Obtain data from the silver
recovery equipment manufacturer/
supplier demonstrating the
performance capability of the
equipment. For example, if you are
required to recover silver to
99 percent efficiency, ask the
manufacturer to provide you with
data showing the equipment can
achieve this level.
Each type of CRC has a limited capacity to
recover silver depending on the type and
amount of iron. Manufacturers generally
rate the capacity of their CRCs in both
gallons of solution and time. For example,
depending on the silver concentration of
the solution going in, a CRC might have
the capacity to desilver 100 gallons of
solution or last 12 weeks, whichever
comes first. Ask the manufacturer to help
you in selecting CRCs appropriate for your
lab.
Keeping a log
Keep a silver recovery log to record all of
the checks and testing you do on your
silver recovery equipment. As soon as the
weekly check (done with silver estimating
test papers) shows color, you know the
chemical recovery cartridge has failed and
it’s time to change it. When you install a
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Appendix D
Off-Site Management
The following information applies only to
commercial imaging operations that ship
waste off-site.
In some situations, off-site silver recovery
is the best option. For example:
• Commercial imaging operations
required to meet excessively restrictive
silver concentration limits may be forced
to ship the solutions off-site for treatment.
• If an imaging operation produces less
than one gallon of silver-rich solution/day,
a chemical recovery cartridge may oxidize
and channel long before the iron is
exhausted. This may create more waste
than it prevents.
• For commercial imaging operations
discharging to a septic tank and leach
field, there is no option; they must haul.
Commercial imaging processing
chemicals must not be discharged to
septic systems. This could cause an upset
that would destroy the microorganisms
responsible for breaking down the waste
water.
F.1 Off-Site Requirements
Solutions containing 5 mg/L or greater of silver
are currently classified as hazardous waste. In
order to transport these solutions off-site, the
facility must fulfill the requirements for
transporting hazardous waste. In this section,
we’re going to discuss the Federal
requirements for off-site silver recovery. Since
individual states may enact stricter regulations,
make sure you check with your state agency
for its specific requirements.
a. Generator category
If you’re shipping off-site waste pre-press
processing solutions containing 5 ppm or
more of silver, it’s important that you know
how to determine your hazardous waste
category. This category is based on the total
amount of hazardous waste produced by
your company. The specific requirements
for accumulation, storage, and manifesting
vary depending on the category.
The chart on the next page shows the
three categories established in the federal
Resource Conservation and Recovery Act
(RCRA). These categories, as shown across
the top of the chart, are:
• Conditionally exempt small quantity
generator
• Small quantity generator
• Large quantity generator
To determine your category, track the
monthly volume of hazardous waste
including waste processing solutions
containing 5 ppm or more of silver
produced in your facility to be sent offsite.
For example, if you process film in several
locations within your facility and the
solutions are accumulated and taken offsite, add all the fixer produced in all
locations for one month. If it’s less than
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H a z a r d o u s Wa s t e C a t e g o r y *
Conditionally Exempt Small
Quantity Generator (CESQG)
Facility that produces less
than 100 kilograms per
month of hazardous waste
Small Quantity
Generator (SQG)
Large Quantity
Generator (LQG)
Facility that produces more
than 100 but less than 1,000
kilograms per month of
hazardous waste
Facility that produces more
than 1,000 kilograms per
month of hazardous waste
* Any photo processing waste containing 5 ppm or more of silver is considered hazardous under the Resource
Conservation and Recovery Act (RCRA). Most states and municipalities have additional regulations for discharge and
transport of silver and silver-bearing wastes. For more information contact your local state hazardous waste agency.
100 kilograms (approximately 220 pounds
or 25 gallons), your facility falls into the
category of conditionally exempt small
quantity generator.
b. Generator identification number
SQGs and LQGs must obtain an EPA
identification number before shipping
waste off-site. This 12-character number
identifies both your site where the waste is
produced and the type of waste. It’s a key
element of tracking the waste from cradleto-grave. Your state hazardous waste
agency can provide you with the proper
paperwork.
In some states, CESQGs do not have to
obtain an ID number.
c. Accumulation and storage
CESQGs must never accumulate more
than 1000 kilograms (kg) of waste at any
time. (1000 kg is approximately 300
gallons).
day period. (6000 kg is approximately
1600 gallons).
LQGs must not accumulate hazardous
waste on-site longer than 90 days.
In all cases, wastes must be stored in tanks
and containers suitable for commercial
imaging processing waste. In addition:
• Clearly mark each container with the
words Hazardous Waste and with the
date you began to collect waste in that
container.
• Use only containers in good condition.
• Keep containers closed except when
you fill or empty them.
• Inspect areas where containers are
stored, at least weekly, looking for
leaks and deterioration.
• Provide secondary containment where
it’s required.
SQGs must never accumulate more than
6000 kg of hazardous waste in any 180
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HAZARDOUS WASTE
Federal Law Prohibits Improper Disposal
If found, contact the nearest police or public safety authority, or the U.S.
Environmental Protection Agency
Accumulation Start Date: Jan 12, 1997 EPA Waste #:
Generator Name:
D011
Mr. Opaque Pre-Press Ltd.
Address: 1500 Main Street
City: Your Town
State:
EPA ID #: XX9876543210
NY
Zip Code: 02143
Manifest #: 554332
DOT Proper Shipping Name, Class, UN#, and packing group:
RQ Hazardous waste liquid, n.o.s. (silver), Class 9,
NA 3082, Packing group III
d. Labels and marks
Containers of silver-rich chemicals must
be properly labeled and marked. The label
shown above contains the six required
elements:
1. accumulation start date,
2. EPA waste identification number,
3. site name and address where the waste
was produced (generator name),
4. EPA generator identification number,
5. manifest number, and
6. Department of Transportation (DOT)
shipping name for the waste.
e. Manifests
The manifest is a multi-copy document
used to track the waste from the time it
leaves the producer (the commercial
imaging facility), to the time the receiver
treats, recycles or disposes of it. Each
party in the link—producer, transporter,
receiver—have EPA identification numbers
and each must complete its portion of the
manifest.
The producer is responsible for obtaining
numbered manifest forms from the state
hazardous waste agency. All links in the
chain keep a copy of the manifest and
receive copies from the other links to
acknowledge receipt of the waste.
Manifests must be kept on file by the
producer for at least three years.
Manifests are not required for CESQGs.
Some transporters, however, may still ask
they be used to help the transporter and
receiver fulfill their requirements.
f. Spill response and training
SQGs and LQGs are required to develop
emergency plans and train employees on
emergency response so that if a spill or
accident occurs, the facility is ready.
Generally, the plans must include
procedures and identify the necessary spill
control/response equipment.
F.2 Precautions
One important element of the cradle-tograve waste management system is
liability. Once you’ve produced the waste,
you retain some responsibility even after
turning it over to a licensed transporter
and a licensed receiver. This means you
must choose your waste management
partners carefully.
Talk with your colleagues, trade
associations and state hazardous waste
agency to get the names of licensed
companies that could handle silverbearing processing wastes. Choose a firm
with a good reputation. Verify their EPA
identification numbers and any required
permits. Keep copies of their permits on
file. Visit their site to look at their
equipment and the general condition of
their operation. Choose carefully and with
confidence.
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Appendix E
Evaporation/Distillation
Evaporation and distillation are generally
used in conjunction with off-site
management. These processes reduce the
volume of effluent to be taken off-site for
treatment and disposal. When the off-site
management costs are based on the
volume of solution, evaporation and
distillation may help to reduce costs.
Evaporation/Distillation Unit
E.1 How it Works
Because evaporation releases fumes to the
air, permits are often required to operate
an evaporator. Hazardous waste permits
may be required. Most equipment used
today consists of both evaporation and
distillation where the water vapor is
boiled-off, captured and condensed and
the fumes are contained.
In distillation, the liquid portion of the
process overflow is heated to its boiling
point. Then the vapors are captured and
cooled resulting in a distillate of
essentially distilled water that can be
discharged to the drain or used to mix
fixers. Since the distillate contains
ammonia and sulfite, using it to mix
developers is not generally recommended.
E.2 Proper Operation
Routine cleaning of the evaporation or
distillation unit is the most important
preventive maintenance operation. Dried
chemistry and dust can easily accumulate
reducing the performance of the
equipment. Intake and overflow screens
along with air filters must be checked and
cleaned periodically. The distillation
chamber should be inspected and
cleaned.
Depending upon the unit, 80 to 100
percent of the water is removed leaving a
silver-rich slurry or solid to be managed
off-site as a hazardous waste.
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Appendix F
Ion Exchange
Ion exchange technology can be used to
recover silver from dilute processing
solutions and wash waters. Keep silver
levels as low as possible in wash water by
preventive maintenance of the equipment
and monitoring replenishment rates.
Ion Exchange Column
low silver
solution in
Ion exchange is recommended for use
only to remove silver from some low-silver
solutions (<1 percent ) such as wash
water. It is not generally recommended for
use with fix solutions.
outlet
desilvered
solution
to drain
G.1 How it Works
Ion exchange is a reversible exchange of
ions between a solid (resin) and a liquid
(water containing ionized salts). When ion
exchange is used with low-silver solutions,
the silver thiosulfate in solution is adsorbed
to the resin in the column. Periodically,
under a service contract, the column is
removed and the resin is rinsed with a
dilute sulfuric acid solution to decompose
the silver thiosulfate to silver sulfide, which
remains in the ion exchange column. The
resin is reused for many cycles and is then
incinerated to recover the silver
accumulated in it.
Ion exchange should not be used for
recovering silver directly from silver-rich
fix solution.
These concentrated thiosulfate solutions
will strip silver from the resin, and can
actually result in more silver being
discharged from the resin column than is
present in the feed solution. Ion exchange,
therefore, lends itself only to the recovery
of silver from wash waters and dilute
processing solutions. Typically, more than
90 percent of the silver from wash waters
can be removed in a single-column
system. Two-columns used in series can
provide 99 percent silver removal
efficiency.
G.2 Proper Operation
Converting equipment to incorporate in
line silver recovery greatly reduces the
silver content of the final wash water. Ion
exchange technology is most effective
when used in conjunction with an in-line
silver recovery unit for the preceding fixer
solution.
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Factors affecting the efficiency of ion
exchange include:
• thiosulfate concentration,
• flow rate, and
• biological growth control.
b. Flow rate
The low-silver solutions must be metered
through the ion exchange columns at a
prescribed rate in order to allow for the
exchange between the silver and the resin
to occur. Generally, this should never
exceed 1 bed volume of resin/minute.
a. Thiosulfate concentration
The capacity of the resin to retain silver is
very dependent on the concentration of
thiosulfate in the influent. The higher the
thiosulfate, the lower the capacity. That’s
why ion exchange is not recommended for
recovering silver from fix. These solutions
are high in thiosulfate.
If you operate under such severe discharge
restrictions that you must use ion exchange
to recover silver from silver-rich solutions,
two steps are required:
1. desilver the silver-rich solutions
through an electrolytic unit, and
c. Biological growth control
Algae, bacteria and fungi grow quite
readily in ion exchange columns and feed
on the dilute photographic processing
chemicals. This growth causes two
problems: 1) it forms a film on the resin
beads, thereby blocking the silver
exchange reaction, and 2) it obstructs the
flow of solution through the column.
To eliminate the problem of biological
growth, the ion exchange column(s) must
be flushed routinely with biocide.
2. meter the desilvered solutions into the
collected wash water overflow at a rate
not exceeding their replenishment rate.
These procedures will reduce the silver
concentration prior to ion exchange and
ensure the thiosulfate levels are controlled.
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Appendix G
Testing for Silver
You must routinely monitor your silver
recovery system to make sure it’s
operating correctly. There are two different
testing methods required: approximations
utilizing test papers are performed
frequently and exact analytical testing is
performed every three months, six months
or annually, depending on the size of the
commercial imaging facility.
H.1 Silver Estimating Test Papers
Silver estimating test papers are used to
provide only an approximation of how
much silver is in a solution. The test strips
are coated with yellow cadmium sulfide
that forms brownish-black silver sulfide
when it comes into contact with silver
ions. The higher the concentration of
silver in solution, the greater amount of
brownish-black silver sulfide will be
formed. The color formed on the test strip
after it has been in solution, therefore,
reflects the amount of silver contained in
that solution.
3. After about 15 seconds, compare the
color on the moist test strip with the
color key provided with the test strips.
Find the color that most closely
matches. That is approximately the
concentration of silver in solution.
4. When evaluating a solution that has
color, such as seasoned fixer, rinse the
test strip briefly under running water
toward the end of the 15-second
waiting period. Take the color of the
solution into consideration when
you’re making the comparison with
the color key.
A typical color key scale is shown below.
As you can see from the scale of numbers
ranging from 0 to 10 g/L* (0 - 10,000
mg/L), the silver readings are only
approximations of the actual silver in
solution. Note that the lowest detection
point is .5g/L or 500mg/L (500 ppm).
Generally, the procedure for using the test
strips is as follows:
1. Dip the test strip in the sample
solution for two (2) seconds so that the
strip is properly wetted.
2. Remove the test strip from solution,
shake off any excess liquid, and place
the strip on a white card.
The test strips are helpful in estimating the
amount of silver in the solution exiting the
silver recovery system. Once the solution
has gone through primary silver recovery,
*
Silver estimating papers are generally scaled in grams per
liter (g/L) rather than parts per million (ppm). Remember:
mg/L and ppm are the same measurement.
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the concentration of silver should be
below the 500 mg/L (ppm) mark. Since the
lowest range on the silver estimating test
papers is 500 ppm, you should see no
color change on the paper. These papers
are only useful for finding major
problems with the silver recovery system.
For example, if you are using chemical
recovery cartridges, you are required to
test the cartridge effluent using test strips
to determine the presence of silver. The
effluent should be below 500 ppm and
therefore, not change the color of the test
strip. The only thing you’ve learned from
testing the effluent with a test strip is that
there are no major problems with the
chemical recovery cartridges. A more
exacting measurement must be taken
periodically to verify the system is actually
recovering the percentage of silver
required.
H.2 Analytical Testing
An exact analytical measurement is
required to verify whether the silver
recovery system is achieving a specific
percentage recovery. Use an outside
analytical laboratory to analyze the
solution samples.
Obtain a sample bottle from the analytical
laboratory, fill the bottle with a sample of
the solution to be analyzed and bring the
bottle to the laboratory. When they have
finished the procedure, the analytical
laboratory will provide the results of the
analysis.
Your best source of information
concerning your sampling procedures and
techniques is the analytical lab that’s
doing your work. Work with them closely
to get your best results. Here are some
general considerations for sampling:
a. Sample containers
• Obtain plastic containers from the
analytical laboratory. Don’t use glass
because silver precipitates more easily on
the wall of a glass container.
• Make sure the laboratory knows that
you are specifically testing for silver so
they provide you with the correct size and
type of container.
b. Sample preservation
• Tell the analytical laboratory NOT to
use a nitric acid preservative with the
sample. Nitric acid precipitates the silver
out of solution, thereby providing an
artificially low silver reading.
• Return the sample to the analytical
laboratory as quickly as possible to avoid
any change in the make-up of the sample.
c. Sampling methodology
• Rinse the sample bottle with the
sample once or twice before filling it for
analysis.
• Make sure that none of the equipment
you are using to collect the sample has
been contaminated with another solution
or material.
d. Analytical test methods
There are two methods the analytical
laboratory can use to detect silver in the
sample:
1. Inductively coupled plasma
spectroscopy (ICP)
2. Atomic absorption (AA)
Either test will provide the same result.
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Appendix H
Forms
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SPILL CONTINGENCY PLAN
Spill Response Personnel
Name
pager/phone
Name
pager/phone
Name
pager/phone
Environmental
Emergency
Phone
(999) 999-9999
24 hours a day
7 days a week
EQUIPMENT REQUIRED
• Gloves
• Apron
• Goggles
• Bucket
• Mop
• Sponge
•
•
Absorbent Materials
Neutralizing Materials
SPILL RESPONSE PROCEDURES
1. Put on gloves, goggles and an apron.
2. Contain the spill with a mop or absorbent materials available.
3. Check the appropriate material safety data sheet (MSDS) for special
handling, ventilation, personal protection or other pertinent data.
4. Clean up the spill, as directed, using generous amounts of water.
5. Use the mop and sponge to clean the area thoroughly.
6. Package and label all contaminated absorbent materials for off-site
disposal.
7. Notify the supervisor or manager that a spill has occurred.
8. (If required) Notify appropriate government agency that a spill has
occurred.
* This plan will not meet the requirements in all states, including California.
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Worksheet for Screening Options
Date
Option:
1. What is the potential for reducing waste and providing other environmental benefits?
2. What is it going to cost in time and materials?
3. How much money will it save in time and materials?
4. How difficult is it to implement?
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Pollution Prevention Plan Worksheet
Date
Option or activity:
Implementation date:
Responsibility:
Record:
Pollution Prevention Plan Worksheet
Date
Option or activity:
Implementation date:
Responsibility:
Record:
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Worksheet for Evaluating P2
Date
Option:
1. Waste reduction results
2. Costs
3. Savings
Worksheet for Evaluating P2
Date
Option:
1. Waste reduction results
2. Costs
3. Savings
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Processor Log Form
Processor Name (location)
Fixer Volume
Category
% Silver Efficiency
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