United States	Office of Water (WH 550G)	EPA 570/9-91-036D
Environmental Protection	January 1992
Agency
&EPA Best Management Practices
For Protecting Ground Water
For Photographic Processing
Establishments Using Shallow
Industrial Waste Disposal Wells
(Class V Well BMP Fact Sheet Number 2B)
EPA recognizes that certain industrial waste disposal practices using drainage mils may pose unacceptable
risks to Underground Sources of Drinking Water. These operations allow the discharge of various wastes to a
drainage system neither designed for rior capable of treating them. Accordingly, BMPs for Industrial Disposal
Wells focus on well closure and alternative disposal methods. We have also included BMPs for waste minimiza-
tion to help facilities reduce waste disposal costs, regardless of the disposal method they use. In addition local,
county, and State regulations may prohibit use of these wells. Note: these practices are recommendations only.
For more information, contact the person named below.
The BMPs listed below apply to photographic processing establishments. Fact
Sheet Number 2 in this series lists BMPs that are applicable to Industrial Disposal
Wells (including those used by photographic processing establishments), particu-
larly for closure and alternative disposal.
Waste Minimization
•	Use as little water as possible (e.g., install water demand valves to control
water use)
•	Use timers to turn off continuous washers when film is not being pro-
cessed to reduce wastewater volume
•	Install a washless processing system
•	Use film with less or no silver; or use silver fixers which allow silver to be
filtered out of developing solutions
•	Replace ferricyanide bleach with ferric EIDTA (ethylenediaminetetraacetic)
complex (Note: mixing EDTA complex from scratch may be dangerous) or
regenerate spent fern-cyanide bleach using ozone oxidation, electrolysis,
persulfate salts, liquid bromine, ion exchange, or highly concentrated
bleach-fix replenishment
•	Use a closed-cycle system to enhance recovery of silver
»Configure chemical recovery cartridges in series to maximize silver
recovery
•	Recover silver by using metallic replacement, electrolytic recovery,
chemical precipitation, ion exchange, reverse osmosis, and/or evapora-
tion

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•	Recycle developer using an ion exchange system or an electrodialysis
system
•	Re-use tray method solutions until test strips indicate they are chemically
exhausted
•	Renew photoprocessing chemicals using replenisher concentrates and
regenerators
•	Use floating lids on bleach and developer to retard oxidation
•	Replace rectangular process tanks with cylindrical ones to maximize
efficiency and to distribute solutions better (by rolling the cylinder)
Note: These BMPs are adapted from a May 1991 EPA report titled, "Class V Well BMP Guidance • Phase I and
Phase II," and have been modified in response to comments by EPA Regions. For a copy of the EPA report,
please contact the Underground Injection Control Branch of the Office of Ground Water and Drinking Water, U.S.
EPA.

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