&EPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington DC 20460
EPA/625/7-91/012
October 1991
Guides to Pollution
Prevention
The Photoprocessing Industry
-------
EPA/625/7-91/012
October 1991
Guides to Pollution Prevention
The Photoprocessing Industry
Risk Reduction Engineering Laboratory
and
Center for Environmental Research Information
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268
Printed on Recycled Paper
-------
Notice
This guide has been subjected to the U.S. Environmental Protection Agency's peer and
administrative review and approved for publication. Mendon of trade names or commercial
products does not constitute endorsement or recommendation for use.
This document is intended as advisory guidance only to photoprocessors in developing
approaches for pollution prevention. Compliance with environmental and occupational
safety and health laws is the responsibility of each individual business and is not the focus
of this document
Worksheets are provided for conducting waste minimization assessments
of photoprocessing operations. Users are encouraged to duplicate portions of this publication
as needed to implement a waste minimization program.
-------
Foreword
Photoprocessing laboratories primarily generate aqueous wastes from process opera-
tions. The most significant contaminant is silver, which may be present as silver thiosulfate
complex. Some aqueous wastes also contain other chemicals. Technology exists to recover
silver, as well as certain other chemicals. Solid wastes are primarily paper and fabricated
items such as film cassettes, spools, and cartridges.
Reducing these wastes at the source, or recycling usable materials, will benefit
photoprocessors by reducing raw material costs, waste disposal costs, and potential liabilities
associated with hazardous wastes. This guide provides an overview of photoprocessing
processes and operations that generate waste and presents options for minimizing waste
generation through source reduction and recycling. It also includes worksheets to assist
photoprocessors in performing waste minimization self-assessment.
-------
-------
Contents
Foreword iii
Acknowledgments vi
1. Introduction 1
Overview of Waste Minimization 1
Waste Minimization Opportunity Assessment 1
References 3
2. Photoprocessing Industry Profile 5
Industry Description 5
Process Descriptions 6
Waste Streams 10
References 10
3. Waste Minimization Options for Photoprocessors 13
Source Reduction 13
Recycling and Resource Recovery 14
References 10
4. Waste Minimization Assessment Worksheets 21
Appendix A 37
Photoprocessing Laboratory Assessments: Case Studies of Shops A, B, C, and D
Appendix B 55
Where to Get Help: Further Information on Pollution Prevention
-------
Acknowledgments
This guide is based on a waste audit study for the photoprocessing industry performed
by Arthur D. Little, Inc., for the California Department of Health Services, under the direction
o* Benjamin Fries of the Alternative Technology Division, Toxic Substances Control
Program. Teresa Harten of the U.S. Environmental Protection Agency, Office of Research
and Development, Risk Reduction Engineering Laboratory, was the project officer respon-
sible for the preparation of this manual, which was edited and produced by Jacobs
Engineering Group, Inc.
We would like to thank the following people, whose review of this guide contributed
substantially to its development:
William F. Wescott - Arthur D. Little, Inc.
John Ennis - Arthur D. Little, Inc.
Thomas J. Dufficy - National Association of Photographic Manufacturers, Inc.
Thomas Dagon - Eastman Kodak
Nancy Neely - Fuji Photo Film USA
Tammy Nelson - Konica USA
Harry Fatkin - Polaroid Corporation
Mike Galliano - Polaroid Corporation
Much of the information in this guide that provides a national perspective on the issues
of waste generation and minimization was provided originally to the U.S. Environmental
Protection Agency by Versar, Inc. and Jacobs Engineering Group, Inc. in Waste Minimiza-
tion-Issues and Options. Volume II, Report No. PB87-114 369 (1986).
vi
-------
Section 1
Introduction
This guide is designed to provide photoprocessors with
waste minimization options appropriate for this industry. It
also provides worksheets designed to be used for a waste
minimization assessment of a photo lab, to be used in devel-
oping an understanding of the waste generating processes and
to suggest ways to reduce the waste. The guide should be used
by photoprocessing companies, particularly their operators
and environmental engineers. Others who may find this docu-
ment useful are regulatory agency representatives, industry
suppliers, and consultants.
In the following sections of this manual you will find:
•A profile of the photoprocessing industry and the pro-
cesses used by the industry (Section 2);
•Waste minimization options for photoprocessing firms
(Section 3);
•Waste minimization assessment guidelines and
worksheets (Section 4);
•Appendices, containing:
- Case studies of waste generation and waste minimiza-
tion practices of photoprocessors;
- Where to get help: additional sources of information.
The worksheets and die list of waste minimization op-
tions were developed through assessments of three
photoprocessing firms, commissioned by the California De-
partment of Health Services (Calif. DHS 1989). The opera-
tions, manufacturing processes, and waste generation and
management practices were surveyed, and their existing and
potential waste minimization options were characterized.
Overview of Waste Minimization
Waste minimization is a policy specifically mandated by
the U.S. Congress in the 1984 Hazardous and Solid Wastes
Amendments to the Resource Conservation and Recover' Act
(RCRA). As the federal agency responsible for writing regu-
lations under RCRA, the U.S. Environmental Protection
Agency (EPA) has an interest in ensuring that new methods
and approaches are developed for minimizing hazardous waste
and that such information is made available to the industries
concerned This guide is one of the approaches EPA is using
to provide industry-specific information about hazardous waste
minimization. The options and procedures outlined can also
be used in efforts to minimize other wastes generated in a
business.
In the working definition used by EPA, waste minimiza-
tion consists of source reduction and recycling. Of the two
approaches, source reduction is considered environmentally
preferable to recycling. While a few states consider treatment
of hazardous waste an approach to waste minimization, EPA
does not, and thus treatment is not addressed in this guide.
Waste Minimization Opportunity Assessment
EPA has developed a general manual for waste minimi-
zation in industry. The Waste Minimization Opportunity As-
sessment Manual (USEPA 1988) tells how to conduct a waste
minimization assessment and develop options for reducing
hazardous waste generation. It explains the management strat-
egies needed to incorporate waste minimization into company
policies and structure, how to establish a company-wide waste
minimization program, conduct assessments, implement op-
tions, and make the program an on-going one.
A Waste Minimization Opportunity Assessment
(WMOA), is a systematic procedure for identifying ways to
reduce or eliminate waste. The four phases of a waste minimi-
zation opportunity assessment are: planning and organization,
assessment, feasibility analysis, and implementation. The steps
involved are shown in Figure 1 and are presented in more
detail on page 3. Briefly, the assessment consists of a careful
review of a plant's operations and waste streams and the
selection of specific areas to assess. After a particular waste
stream or area is established as the WMOA focus, a number of
options with the potential to minimize waste are developed
and screened.
The technical and economic feasibility of the selected
options are then evaluated. Finally, the most promising op-
tions are selected for implementation.
Planning and Organization Phase
Essential elements of planning and organization for a
waste minimization program are: getting management com-
mitment for the program; setting waste minimization goals;
and organizing an assessment program task force.
1
-------
The Recognized Need to Minimize Waste
I
PLANNING AND ORGANIZA TtON PHASE
• Gel management commitment
• Set overall assessment program goals
• Organize assessment program task force
I
Assessment Organization A
Commitment to Proceed
ASSESSMENT PHASE
Collect process and site data
Prioritize and select assessment targets
Select people for assessment teams
Review data and inspect site
Generate options
Screen and select options for further study
Assessment Report of
Selected Options
Select New Assessment
Targets and Reevaluate
Previous Options
FEASIBILITY ANALYSIS PHASE
' Technical evaluation
1 Economic evaluation
• Selected options for implementation
Final Report, Including
Recommended Options
IMPLEMENTATION PHASE
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
Repeat the Process
Successfully Implemented
Waste Minimization Projects
Figure 1. The Waste Minimization Assessment Procedure.
-------
Assessment Phase
The assessment phase involves a number of steps:
• Collect process and site data
• Prioritize and select assessment targets
• Select assessment team
• Review data and inspect site
• Generate options
• Screen and select options for feasibility study
Collect process and site data. The waste streams at a
facility should be identified and characterized. Information
about waste streams may be available from hazardous waste
manifests. National Pollutant Discharge Elimination System
(NPDES) reports, routine sampling programs, and other
sources.
Developing a basic understanding of the processes that
generate waste at a site is essential to the WMOA process.
Flow diagrams should be prepared to identify the quantity,
types, and rates of waste generating processes. Also, prepar-
ing material balances for various processes can be useful in
tracking various process components and identifying losses or
emissions that may have been unaccounted for previously.
Prioritize and select assessment targets. Ideally, all waste
streams in a business should be evaluated for potential waste
minimization opportunities. With limited resources, however,
the owner or manager may need to concentrate waste minimi-
zation efforts in a specific area. Such considerations as quan-
tity of waste, hazardous properties of the waste, regulations,
safety of employees, economics, and other characteristics
need to be evaluated in selecting the target streams.
Select assessment team. The team should include people
with direct responsibility and knowledge of the particular
waste stream or area of the facility being assessed. Operators
of equipment and the person who sweeps the floor should be
included, for example.
Review data and inspect site. The assessment team evalu-
ates process data in advance of the inspection. The inspection
should follow the target process from the point where raw
materials enter to the points where products and wastes leave.
The team should identify the suspected sources of waste. This
may include the production process; maintenance operations;
and storage areas for raw materials, finished product, and
work in progress. The inspection may result in the formation
of preliminary conclusions about waste minimization oppor-
tunities. Full confirmation of these conclusions may require
additional data collection, analysis, and/or site visits.
Generate options. The objective of this step is to generate
a comprehensive set of waste minimization options for further
consideration. Since technical and economic concerns will be
considered in the later feasibility step, no options are ruled out
at this time. Information from the site inspection, as well as
trade associations, government agencies, technical and trade
reports, equipment vendors, consultants, and plant engineers
and operators may serve as sources of ideas for waste minimi-
zation options.
Both source reduction and recycling options should be
considered. Source reduction may be accomplished through
good operating practices, technology changes, input material
changes, and product changes. Recycling includes use and
reuse of waste, and reclamation.
Screen and select options for further study. This screen-
ing process is intended to select the most promising options
for full technical and economic feasibility study. Through
either an informal review or a quantitative decision-making
process, options that appear marginal, impractical or inferior
are eliminated from further consideration.
Feasibility Analysis Phase
An option must be shown to be technically and economi-
cally feasible in order to merit serious consideration for
adoption at a business. A technical evaluation determines
whether a proposed option will work in a specific application.
Both process and equipment changes need to be assessed for
their overall effects on waste quantity and product quality. An
economic evaluation is carried out using standard measures of
profitability, such as payback period, return on investment,
and net present value. As in any other project, the cost
elements of a waste minimization project can be broken down
into capital and operating costs. Savings and changes in
revenue also need to be considered.
Implementation Phase
An option that passes both technical and economic feasi-
bility reviews should be implemented. It is then up to the
WMOA team, with management support, to continue the
process of tracking wastes and identifying opportunities for
waste minimization by periodic reassessments. Such ongoing
reassessments and the initial investigation of waste minimiza-
tion opportunities can be conducted using this manual.
References
California DHS. April 1989. Waste audit study:
Photoprocessing industry. Report prepared by Arthur D.
Little, Inc. for the Alternative Technology Section, Toxic
Substances Control Division, California Dept. of Health
Services.
USEPA. 1988. Waste minimization opportunity assessment
manual. Hazardous Waste Engineering Research Labora-
tory, Cincinnati, Ohio, EPA/625/7-88/003.
-------
-------
Section 2
Photoprocessing Industry Profile
Industry Description
The photoprocessing industry consists of businesses which
develop and finish photographic film. This industry is in-
cluded in Standard Industrial Classification (SIC) code 7382.
In 1988, U.S. consumers spent $4.86 billion on photo finish-
ing compared to $4.4 billion in 1987 (U.S. Dept of Com-
merce 1988). The rate of revenue growth for finishing has far
outstripped that for film, cameras, and other photo equipment
for at least the last decade. The industry is diversified both
geographically and in terms of unit size. Figure 2 illustrates
the market share for various types of processors, based on
number of film rolls processed in 1987. The largest share
belongs to mini-labs, which are on-site photoprocessors. This
segment has grown from 5,200 labs in 1984 to 14,700 in 1987
(end-of-year figures).
Figure 3 illustrates the market share by film type. The
most popular type is 35 mm film. Instant film is not processed
and is outside the scope of this study. Disc film use is
declining. Eastman Kodak, a major supplier, has withdrawn
from this part of the camera market. Cartridge film use is
strong because this type of camera is frequently offered by
retailers as a promotion.
Nearly all of the consumer-oriented films are based on
silver as the photo-active chemical. Other types of films are
diazo, vesicular photopolymer, and electrostatic (Calif. DHS
1989b), which are not covered by this guide. These have
specific commercial markets and are likely to be processed
only by specialized (often in-house) labs.
Kiosk/Other
Camera Stores ->«/
7% **
Mailorder
9%
Mini-Lab
29%
Supermarkets
13%
Discount Stores
17%
Drugstore
23%
Cartridge
15%
35-mm Rolls
55%
Reference: Standard & Poor's. 1990 Industry Surveys.
Flgun 2. Share of Photofinishing Market.
Based on number of rolls (1987).
Reference: Standard & Poor's. 1990 Industry Surveys.
Flgun 3. Types of Film Processed.
Based on number of roHs (1987)
-------
Process Descriptions
The processing of photographic film and paper requires
the use of a number of chemicals to develop and produce
finished photographic goods. The waste streams generated
vary widely according to the type and volume of processing.
Photoprocessing is dominated by color print film, prints, and
slides, with only about 10 percent of the market involving
black-and-white processing. Because color processing usually
represents a greater production volume of the operations at a
given location, it usually generates a larger waste stream
volume. An increasing portion of the color market is being
taken by mini-labs, which are automated machines that oc-
cupy little space. These machines are the ones used by the
popular one-hour developing centers. The waste stream vol-
ume from most one-hour developing centers has been greatly
reduced, because most centers have converted to "washless"
or "plumbingtess" processing, which does not use a conven-
tional wash cycle.
Color Processing
Film and paper used for color photography consist of
three separate layers of photosensitive emulsion with interme-
diate layers. Each layer is coated on clear film base or on
paper. Each emulsion layer is sensitive to either red, green or
blue light due to the presence of selective dyes in the emul-
sion. Intermediate layers filter out other wavelengths, so that
the silver halide salts in each photosensitive layer are exposed
only by light of the specific color. A colorless dye-forming
coupler is present along with the silver halide crystals in each
emulsion layer. When processed in a color-developing solu-
tion, an image of "developed silver" is farmed in each layer.
The exposed silver halide crystals are reduced to metallic
silver, while simultaneously producing oxidized developer
molecules. The oxidized developer reacts with the dye-form-
ing coupler to produce a dye which is complementary in color
to the light to which the emulsion layer is sensitive. The
intensity of the dye formed in a particular portion of the image
is dependent on the quantity of oxidized developer, which is
in turn proportional to the extent of exposure in that area.
A bleach bath renders the color image visible by remov-
ing the black metallic silver image, converting the metallic
silver back to a silver halide. All of the silver on the film,
whether exposed or not, can then be dissolved and removed in
the fixer bath. The dye is retained in each layer of the film so
that a negative (complementary) color image remains. Some
processes combine the bleach and fix processes in a single
solution, termed bleach-fix or "blix." It is a common practice
to introduce the film into a stabilizer bath after the fixer
solution to equilibrate the emulsion and increase the stability
of the dye image to light A schematic diagram of the color
negative film process is shown in Figure 4.
Positive color prints can be made from the film negative
recorded by the camera by exposing color paper or other
suitable print medium to light through the developed film. The
print medium, which contains the same combination of color-
sensitive emulsion layers as does the film, is then processed
through a similar sequence of solutions to obtain the final
print, as illustrated by Figure 5.
For color slides, a positive color image is produced
directly on the film by reversal processing. The exposed color
film is first subjected to black-and-white processing to pro-
duce a negative image consisting only of metallic silver. After
washing, the film is immersed in a reversal bath that renders
the remaining silver salts developable. The film is then pro-
cessed in a color developer that reduces the remaining silver
salts and produces a positive dye image. Then a sequence of
bleach, fixer, and wash steps produces the final color transpar-
ency.
Color prints can be made from slides by a similar reversal
process. Alternately, prints can be prepared by first producing
a film negative from the slide, and then printing from this
negative in the usual fashion. Figure 6 is a schematic diagram
depicting both slide and reversal print operations.
Cinemagraphic film processing is similar to processing of
color print or slide film. In commercial operations, a large
number of copies are made from one film. A print or "nega-
tive image" film is used for the original exposure and then
used to make film copies (much as print film is used to make
prints). Amateur film processing, which usually results in
only one copy of the film, uses film much like slide film that
is exposed and processed, producing the positive image on the
originally-exposed film.
Black-and-White Processing
The photosensitive medium used for black-and-white
processing is an emulsion composed of a dispersion of fine
silver halide crystals in a matrix of gelatin. This emulsion is
applied in a layer approximately 1/1000 of an inch thick on a
supporting material, either paper or clear plastic film. Brief
exposure to small quantities of light produces a chemical
change in the silver halide crystals, which allows the silver
ions in the exposed crystals to be converted to metallic silver
at a faster rate than in unexposed crystals. By focusing the
light through the camera lens, the pattern of exposed crystals
corresponds to the image from which light is reflected. At this
point, the exposed silver halide crystals are termed "develop-
able." When the film is subsequently immersed in the devel-
oping solution, an alkaline solution of organic reducing agents,
the exposed silver halide crystals are reduced to metallic
silver. The silver is dark in color and produces a negative
image. The most commonly used developing agents are metol
(p-methylaminophenol sulfate) and hydroquinone (p-
dihydroxybenzene) or 1,4-dihydroxybenzene.
The chemistry of development is extremely complex. For
example, hydroquinone in ordinary sulfite-containing devel-
opers (sodium sulfite is added to most developers as a preser-
vative) is oxidized to a semi-quinone free radical, and then
reacts with sulfite to form mono- and di-sulfonates. These
reaction products may be isolated along with quinone, sodium
sulfate (NajSO,), and many other compounds associated with
the other ingredients, e.g., metol, sodium carbonate, and po-
tassium bromide. For additional information on
photoprocessing chemistry, various references are available
(e.g. Henn, Locker, Umberger).
-------
Film—^
Replenish
i
Color
Develop
Waste
1 1
Replenish
i 1
Bleach
*" (Ferric EDTA) H
Rinse Water
J '
»• Wash -H
Spent Rinsewater
\ <
! Bleach i
{Regeneration;
T! —
'Waste
i
Replenish
---» 1
»• Fix _£
Rinse Water
1
. Wash
Spent Rinsewater
i
\<
! Silver
I Recovery
TT~~
j Waste
Silver
Recovery
Replenish Water Vapor
1 t
^ Ctthili-rn
Waste
f
• Product
Reference: California OHS 1989a
Flgun 4. Process: Color Negative Film.
Film
Replenish Rinse Water
i 1
Col
Oevc
or Bleach-Fix
ilop * hemcEDTA *• """" »•
\
(NR)" 1
i Spent Rinsewater
| Bleach-Fix j
*| Regeneration j
1 J
1 v 8ft
* Hece
Dry _^. Product
«r Waste
>very J~*" Water
•No Regeneration with NR Bleach Fix
"Silver Recovery from Wash Used in EP-2 Process with NR Bleach Rx
Reference: California DHS 1989a
Flgun 5. Process: Color Negative Paper.
-------
Replenish
Rim — ». Dew
Hop
I
Batch
Overflow
Replenish
1
Bleach-fix
* FemcEota
i
j Bead
j Regent
I
p
h-Rx
ration
j
Replenish
J
»• Stop
1
Batch
Overflow
Water
1
«. Wash
Spent Rinsewater
Water
1
>. Wash
1
Spent Rinsewater
Replenish
1
••» Stabilize
Batch
Overflow
Replenish
^ Color
Develop
1
Batch
Overflow
Water
i
Spray
Wash
1
Spent Rinsewater
Water
fc. Wpeh
1
Spent Rinsewater
Water Vapor
t
• •Jfj — *
\
Product
r
Waste
Reference: Caffomia OHS 1989a
Flgunt. Procets: Color traversal Paper.
If kept in the developer bath, even the unexposed silver
halide crystals can be converted to metallic silver by the
developer solution. To prevent mis, the action of the devel-
oper is arrested by transferring the film to a stop bath. The
stop bath is a weakly acidic solution (usually acetic acid)
which neutralizes any of the alkaline developer carried over
on the surface of the film or in the wetted gelatin layer.
Following the stop bath, the film is immersed in a fixer
solution that solubilizes and removes the remaining unreacted
silver salts, rendering the image on the film permanent Fixer
solution adhering to the film most be removed in a final rinse
step.
The film now contains a negative image of the scene
which the camera recorded A positive print is prepared by
exposing a photosensitive sheet of paper to a light source
passing through the negative film image. The paper is then
processed through a similar set of operations (i.e. developer,
stop bath, fixer, and rinse). A diagram for black-and-white
processing that applies to both film and paper is shown in
Figure?.
As more film is processed, the concentration of various
reaction products gradually builds up in the developer solu-
tion. Silver and bromide ions removed from the developed
film accumulate in the fixer solution, and the stop bath is
gradually neutralized as the quantity of developer carried over
increases. At some point, these solutions become unusable
and must be discarded.. The final rinse is usually conducted in
a continuous flow of fresh running water. As a result, only
small amounts of silver and other fixer compounds can be
detected in the spent rinse water waste stream.
Black-and-white reversal film processing requires two
development steps with an intermediate bleach step. Bleach
solution for black-and-white processing contains sodium di-
chromate. Spent bleach is a hazardous waste because of its
chrome content
Manual and Automated Systems
Manual Systems
Manual systems include tray and tank processing. These
are often used for low volume production such as black and
white processing, enlargements, or other services that do not
require, or are not amenable to, cost-effective automation.
While manual processing wastes can be significantly reduced,
this represents such a small volume for most businesses that
the overall waste reduction impact may not be significant
8
-------
Developer
Solution
Stop Bath
Solution
Fixer
Solution
Rinse
Water
Undeveloped
Film/Paper
Developer
Bath
Overflow
Stop Bath
Overflow
I
I
Reference: California DHS 1989a
Figure 7. Black and White Development Process.
Finished
- Rim or
Print
Wastewater
Recovered
Silver
The tray method allows processing small quantities of
film and papers with minimum chemical consumption. Sheets
of film or paper are placed on the bottom of the shallow tray
containing solution. The tray is then rocked back and forth
manually to ensure that adequate fresh solution contacts the
emulsion surfaces. The sheets are removed, drained, and
transferred to the next processing bath. The duration of each
step in the process is timed according to a prescribed sched-
ule. Once the processing is completed, the-solutions are
returned to storage containers for reuse. With proper storage,
solutions can be reused until chemically exhausted, as indi-
cated by test strips.
Tanks are used for processing large quantities of film and
paper sheets. This method is usually limited to sheets no
larger than 8 inches by 10 inches. The sheets are suspended
vertically in the tank from hangers which maintain a lateral
separation. The solution level in each tank covers the entire
sheet. The solution is agitated by gentle vertical movement of
the hangers. When not in use, the tanks should be covered to
keep foreign materials out of the processing solutions and to
minimize evaporation and oxidation. Oxidation of the devel-
oper solution can be further reduced by using a tight-fitting
"floating lid" of buoyant plastic and limiting the amount of
time the solution is in use.
In addition, strips of camera film are often processed in
tanks. The flexible film strip is inserted in a spiral slot in a reel
which fits into a cylindrical tank. Inserting the film into the
reel and loading the reel into the tank must be carried out in
the dark. Then, in a lighted area, the solutions are added, one
at a time, through a light-tight port in the cap. Following a
prescribed schedule, the tank is drained and refilled with the
subsequent solutions. During the final wash step, the cap can
be removed to permit easier washing of the reels in the stream
of water.
Automated Systems
Automated systems differ primarily by the means used to
transfer the film through the sequence of solutions. The major
types of transport systems are discussed in the following
Dip and Dunk. The films, in the form of sheets, strips, or
short looped lengths, are clipped to hangers supported on a
rack. The rack is removed from the processing machine to
simplify loading. Once replaced in the processor, the rack
holding the film is advanced by a gear chain mechanism. As
the rack moves into position, it is lowered into the solution
tanks so that the film is completely immersed. Agitation is
provided by vertical movement of the rack to ensure continu-
ous contact of the emulsion surface with fresh solution. As the
rack continues its advance, it is automatically raised from one
bath, allowed to drain, and lowered into the subsequent solu-
tion or wash tank. Finally the rack moves the film through a
forced-air drying unit
Nip Rollers. A series of small cylindrical wringers trans-
ports film or paper through the sequence of processing solu-
tions. These rollers provide for both vertical and horizontal
movement, and this method is suitable for either strips or
sheets. Initially a leader strip or sheet is threaded and pulled
-------
sheets. Initially a leader strip or sheet is threaded and pulled
through to a rewind station situated after the final dryer unit.
Once the processing is started, movement of the film or paper
through the solutions is continuous.
Belt Systems. The film or paper to be processed is sup-
ported on a belt which is conveyed through the sequence of
solutions using guides and rollers. Where desirable, the mate-
rial being processed can be transferred from one belt to
another to allow for a greater variety of strips. Initially a
leader strip or sheet is treated and pulled through to a rewind
station situated after the final dryer unit Once the processing
is started, movement of the film or paper through the solutions
is continuous.
High-Speed Roller. Long strips of film are mounted on a
flexible support which is attached to a series of racks. A
system of guides and immersed rollers conveys the film
through the solutions to wash tanks. Before starting up the
processor, a leader is threaded through the racks. Generally,
the leader is attached to the end of the film and is always left
in place between processing cycles to simplify start-up. Lengths
of film to be processed, or tailing leaders, can be attached with
tape or staples. High linear speeds are possible, resulting in
greater throughput than can be obtained with other types of
processors.
Waste Streams
Wastes generated by photoprocessors are primarily aque-
ous effluents. These may be categorized as: process bath
wastes, color developer wastes, and bleach/fix/bleach-fix
wastes (Freeman 1990). Spent rinse water is also an aqueous
waste, although not specified separately in Freeman's book.
They are typically combined as a single stream either to an on-
site biological treatment system or via sewer to a publicly-
owned treatment works (POTW). All the aqueous effluents
contain silver, although in different forms and different con-
centrations, and some of the streams are contaminated with a
variety of other chemicals. Table 1 lists waste solutions, their
constituents and the associated environmental concerns.
The free silver ion is an effective bactericide, which can
seriously impair biological systems. On July 1,1976, interim
federal guidelines were issued for point source discharges in
the photoprocessing industry (40 CFR 459). These apply to
photolabs which discharge waste waters directly into a surface
water such as a stream or lake. These guidelines established
limits of 0.03 pounds of silver per day per 1000 square feet of
film or paper processed, and a 30 consecutive-day average of
0.015 pounds/day per 1000 square feet However, most
photolabs discharge into municipal sewer systems. Approxi-
mately half of the municipal sewer codes in the nation contain
limits on silver discharge. Most of these limits range from
0.05 to 5.0 mg/L (ppm). Some municipalities have prohibited
the discharge of photoprocessing effluents to their sewage
systems.
The impact of silver in photoprocessing wastes is contro-
versial. One published study indicates that there is no real
threat to aquatic systems (Bard et al. 1976). Although de-
listing of silver is being studied by some federal authorities,
some local authorities regard it as a hazardous waste. In those
locations, silver-containing materials must be manifested and
shipped as a hazardous waste if they contain more than 5 mg/
L of silver as measured by the EPA-specific leaching test,
increasing the cost for offsite reclamation.
Table 1. Aqueous Waste* from Photoprocessing
Solution Constituents
Environmental
Concern
Prehardeners, hardeners Organic chemicals
Chromium compounds
andprebaths
Developers
Stop baths
Ferricyanide bleaches
Dichromate bleaches
Clearing baths
Fixing baths
Neutralizes
Stabilizers
Sound-track fixer or
redevelopor
Organic chemicals
Organic chemicals
Ferricyanide
Organic chemicals
Chromium compounds
Organic chemicals
Organic chemicals
Silver
Thiocyanate
Ammonium compounds
Sulfur compounds
Organic chemicals
Phosphate
Oxygen demand
Toxic metals
Oxygen demand
Oxygen demand
Toxic chemical
Oxygen demand
Toxic Metals
Oxygen demand
Oxygen demand
Toxic metals
Toxic chemicals
Ammonia
Possible H2S
generation
Oxygen demand
Bio-nutrients
Organic chemical Oxygen demand
Ammonium compounds Ammonia
10
Monobaths Organic chemicals Oxygen demand
In addition, photoprocessing solutions may be acidic or alkaline.
Waste streams from cinemagraphic film processing are
similar to those described above with one major exception.
For some cinemagraphic films, a bleach containing ferricya-
nide is used, and could result in appreciable concentrations of
ferri- and ferrocyanide in the waste streams. Most
cinemagraphic processors recover up to 99% of the ferricya-
nide for reuse. If not recovered, ferrocyanide can eventually
be converted to free cyanide by sunlight in the presence of
oxygen over a period of several weeks, and is therefore a
waste constituent of concern.
Silver-bearing solid wastes include scrap film and photo-
graphic paper. Other solid wastes are film cartridges, cassettes
and canisters, as well as containers for photographic chemi-
cals.
References
Bard, C.C., JJ. Murphy, Dl. Stone, and C J. Terhaar. Febru-
ary 1976. Silver in photoprocessing effluents. Journal of
Water Pollution Control Federation. Vol. 48, No. 2.
Calif. DHS. 1989a. Waste audit study: photoprocessing in-
dustry. Report to California Department of Health Ser-
vices, Alternative Technology Section, Toxic Substances
Control Division. Prepared by Arthur D. Little, Inc.
-------
Calif. DHS. IWb Reducing California's metal-bearing waste
streams. Report to California Department of Health Ser-
vices, Alternative Technology Section, Toxic Substances
Control Division. Prepared by Jacobs Engineering Group
Freeman, H.M. 1990. Hazardous waste minimization.
McGraw-Hill Publishing Co.
Henn, R. W. 1977. Development and after process. In:
Neblette's handbook of photography and reprography. 7
Edition, pp. 113-126 VanNostrand.
Locker, D. J. 1972. Photography In: Kirk-Othmer encyclope-
dia of chemical technology, 3rd Ed. 1972. Vol. 17. pp.
61 1-656. John Wiley and Sons.
Standard ^ Poor> im ,d s ,
J } vv
Umberger) L Q 1973 photographic chemistry ta: SPSE
Handbook of photographic science and engineering, pp.
501-591. John Wiley and Sons.
U s Department of Commerce. 1989. U.S. industrial outlook.
PP- 33~2 to 33"3'
u
11
-------
-------
Section 3
Waste Minimization Options for Photoprocessors
This section discusses recommended waste minimization
methods for photoprocessing operations. These methods come
from both open literature and industry contacts. Waste mini-
mization options can be classified as source reduction and
recycling or resource recovery. In addition to the specific
recommendations provided below, rapidly advancing technol-
ogy makes it important that companies continually educate
themselves about improvements that are waste reducing and
pollution preventing. Information sources to help inform com-
panies about such technology include trade associations and
journals, chemical and equipment suppliers, equipment expo-
sitions, conferences, and industry newsletters. By keeping
abreast of changes and implementing applicable technology
improvements, companies can often take advantage of the
dual benefits of reduced waste generation and a more cost
efficient operation.
Table 2 summarizes the principal wastes and methods for
minimizing them.
Tabto 2. WHI* Minimization Methods for PhotoprocMdng
Waste Stream
Waste Minimization Methods
Aqueous Waste Use squeegees to minimize chemical cany over
Recover silver from effluent
Reuse fixer
Regenerate developer
Regenerate bleach
Use counter current rinsing
Use pkjmbingless minilabs
Expired or Off- Control inventory carefully
Spec Chemicals Store away from heat and light
Other Solid Waste
Store paper at cool temperature
Recover silver from off-spec paper and from
excess Mm
Recycle cartridges, cassettes and spools to film
manufacturer
Air Emissions Use floating coven on solution tanks
Source Reduction
•
The following management practices are applicable to all
sizes of photoprocessing operations to minimize waste gen-
eration. They require almost no investment and have proven
effective in many businesses:
• Control inventories of processing chemicals so they are
used before their expiration dates.
• Make up processing solutions only in quantities needed to
meet realistic processing volumes.
• Use floating lids or balls on developer solution tanks to
prevent loss of potency through oxidation or evaporation.
• Improve quality control for all processes to prevent unnec-
essary discharges.
Squeegees can be used in all manual and some automated
processing systems to wipe excess liquid from the film and
paper, reducing chemical carryover from one process bath to
the next by 75 percent or more (Eastman Kodak 1990).
Several types are available, including wiper blades, air squee-
gees, vacuum squeegees, wringersling squeegees, and rotary-
buffer squeegees. Belt turnarounds with soft-core rollers can
be used for slow speed transport of wide films, but squeegees
cannot be used on rack-and tank, basket, or drum processors
(Eastman Kodak 1990). Minimizing chemical contamination
of process baths increases recyclability, enhances the life of
the process baths, and reduces the amount of replenisher
chemicals required. Some types of squeegees may damage the
film image, if it has not fully hardened.
Accurately adding and monitoring chemical replenish-
ment of the process baths will cut down chemical waste.
Process baths may be protected from oxidation by reducing
exposure to air. Some smaller photo developers store chemi-
cals in closed plastic containers. Glass marbles are added to
bring the liquid level to the brim each time liquid is used. This
limits the volume of air in the container, thereby extending the
chemical's useful life.
Proper storage conditions are necessary to maximize the
life of paper for color prints. One writer recommends storing
paper in a refrigerator, if it will not be used for a few days, and
in a freezer for longer storage periods. He states that he has
used the same box of paper for years by freezing it (Sribnick
1986).
The photoprocessor usually receives films in rolls, cas-
settes, cartridges, or canisters. These are often recyclable.
Eastman Kodak, for example, has collected these from some
processors on a test basis, and is reportedly expanding the
program. A distributor of microfilmed catalogs reuses the
plastic housings returned by its customers six or seven times,
before they become too worn for continued use.
13
-------
Material substitution involves replacing a processing
chemical with an alternate material that reduces the quantity
of waste generated or the degree of hazard associated with the
waste. Opportunities for this type of waste reduction in
photoprocessing are limited. Alternate materials may be un-
available, more expensive, or have undesirable effects on
product quality.
The "black box" nature of photoprocessing chemistry
generally requires an individual operator to use established
chemical packages with few options for substituting alternate
materials. Photochemical manufacturers and suppliers can aid
photoprocessors, however, by developing new processes which
result in lower volume and lower toxicity wastes. For ex-
ample, ferricyanide bleach has been replaced by ferric EDTA
(ethylenediaminetetraacetic acid) complex, resulting in a less
toxic waste stream (Calif. DHS 1989a).
Businesses which operate in-house labs have more flex-
ibility for material substitution, such as using non-silver film.
A company that supplies microfilms of catalogs and standards
to industrial users has switched to diazo and vesicular films.
However, it should be noted that these films are not consid-
ered "archival" and may not be acceptable for permanent
document storage.
Recycling and Resource Recovery
Silver Recovery
Metallic silver trades as a commodity in units of Troy
ounces (one Troy ounce equals 31.10 grams). In recent years
the price range has typically been $4 to $6 per Troy ounce,
although during the speculative fever of 1980, the price reached
$50 per Troy ounce, before the market collapsed. Thus, if the
market price were $6.00 per ounce, and an effluent contained
31 mg/L silver, the potential recovery value of silver would be
0.6 cents per liter or nearly 2.4 cents per gallon of effluent.
Since silver recovered from photoprocessing requires further
processing, reclaimers will offer somewhat less than market
price for the recovered silver.
Table 3 lists the silver content in Troy ounces per square
foot for several types of film, and Table 4 shows the surface
area for film rolls. The quantity of silver entering the facility
can be estimated based on die number of rolls processed.
However, as modifications are made to films the silver level
could change significantly. Film manufacturers should be
consulted for up-to-date values.
Major sources of recoverable silver are: photoprocessing
solutions, spent rinse water, scrap film, and scrap printing
paper. The silver in these materials may exist as insoluble
silver halide, soluble silver thiosulfate complex, silver ion, or
elemental silver, depending on the type of process and the
stage in the process where the silver is being recovered.
As much as 80 percent of the total silver processed for
black-and-white positives and almost 100 percent of the silver
processed in color work will end up in the fixer or bleach-fix
solution. Silver is also present in the rinse water following the
fixer or bleach-fix due to carry-over. The amount of silver in
Table 3. Silver Content of Films
Film Type
Silver Content
Troy ounces per sq. ft.
BlackWnita Film
Photofinishing
Low Speed - ISO 32
Medium Speed - ISO 125
High Speed - ISO 320-4OO
Ultra-fast-ISO 1250
Black/White Prints
Color Film
Negative Process C-41
Kodacolorll
Vericolor II
Kodacolor400
Kodacolor HP Disc Film
Kodacolor VR Disc Film
Kodacolor VR2OO, 400, 1000
Kodacolor VR 100
Vericolor III
Vericolor Slide/Print
Reversal Process K-14
Reversal Process E-6
Low Speed
Medium Speed
Highspeed
Duplicating
Duratrans Display 4022
Motion Picture Film
Ektachrome
Kodachrome
Negative Film
Print
Intermediate
Intemegative
Reversal Films
Kodachrome
Ektachrome
Print
Intermediate
0.0105
0.0073
0.0104
0.0156
0.0264
0.0024
0.0169
0.0208
0.0278
0.0288
0.0263
0.0268
0.0187
0.0244
0.0088
0.0152
0.0122
0.0121
0.0149
0.0121
0.0020
O.OO95
0.0142
0.0210
0.0050
0.0081
0.0096
0.0137
0.0162
0.0098
0.0133
NOTE: These figures can be used to estimate the silver content.
Contact the fHm manufacturer for information or brands not
on this table or for updates on the above information.
Reference: Calif. DHS 1989a.
rinse water is only a small fraction of that in the fixer or
bleach-fix solutions, but can be economically recovered when
high volumes of rinse water are used. A variety of equipment
types and sizes are available for silver recovery. Table 5
compares silver recovery methods. More detailed descriptions
are given below.
Silver Recovery from Fixer Solution
The most common methods of silver recovery from the
fixer and bleach fix processing solutions are metal replace-
ment, electrolytic recovery, and chemical precipitation. Ion
exchange and reverse osmosis are other methods that can be
used. However, these are suitable only for dilute silver solu-
tions such as wash water from a primary silver recovery unit
14
-------
Tabto 4. Standard Film Roll Areas
Film Size
110 12-exposurerot
1 10 20-exposure mi
1 10 24-exposure rot
126 12-exposure rot
126 20-exposure rot
126 24-axpoeure roll
127 roll
13S 12-exposure rot
135 20-exposure rot
135 24-exposuro rot
135 36-exposure rot
120roK(blacUwhite)
120 roll (color)
620 rot (UacUwhile)
620 roll (color)
220 roll
828 roll
Area
sq. ft
0.078
0.113
0.131
0.177
0.272
0.319
0.305
0.268
0.382
0.440
0.619
0.538
0.547
0.522
0.530
1.090
0.163
Reference: Calif. DHS 1989a.
which has been mixed with wash waters. Some facilities use a
primary silver recovery unit, which removes the bulk of
silver, in combination with a "tailing" unit to treat the rela-
tively low silver concentration effluents from a primary silver
recovery system. Color developer effluent does not flow
through a silver recovery unit because the silver content is
very low and the high pH developer if mixed with other silver-
bearing solutions, could reduce the efficiency of silver recov-
ery and could result in ammonia generation.
A silver recovery system can be devoted to a single
process line or can be used to remove silver from the com-
bined fixer from several process lines in a plant. Multiple-
stream systems are more typical in large facilities. Sometimes
a separate fixer system is used for specialty processing to
reduce the possibility of inter-process contamination, which
can occur when desilvered fixer is recycled to the photo
process.
Metallic Replacement
Metallic replacement occurs when an active solid metal,
such as iron, contacts a solution containing dissolved ions of a
less active metal, such as silver. The more active metal goes
into solution as an ion, being replaced by an atom of the less
active metal in the solid matrix. The dissolved silver, which is
present in the form of a thiosulfate complex, reacts with solid
metal.
Silver ions will displace many of the common metals
from their solid state. Because of its economy and conve-
nience, iron in the form of steel wool is used most often.
Hypothetically, zinc and aluminum can also serve as replace-
ment metals; however, both have drawbacks. Zinc is not used
because of its relative toxicity and greater cost. Aluminum is
not used because it simultaneously generates hydrogen gas,
which can be an explosion and fire hazard if improperly
handled.
T«bl«5. Comparison of Silver Recovery Method*
Method
Advantages
Disadvantages
Metatic Replacement
Electrolytic Recovery
Precipitation
Reverse Osmosis
Ion Exchange
Evaporation
Low investment
Low operating cost
Simplest operation
Recovers silver as pure metal
High silver recovery
Can attain 0 1 mg Ag-/L
Low investment
Also recovers other chemicals
Purified water is recyclable
Can attain 0.1 -2.0 mg Ag*/L
Good for very low Ag limits
Minimum aqueous effluent
Water conservation
High iron content of effluent
Silver recovered as sludge
High silver concentration in
effluent unless two units are
in series
Potential for sulfide formation
High silver concentration in effluent
Complex operation
Silver recovered as sludge
Treated solution cannot be reused
Potential H£ release
Concentrate requires further processing
High investment
High operating cost
Only for dilute influent
Complex operation
High investment
High energy requirement
Silver recovered as a sludge
Organic contaminant buildup
Potential air emissions
15
-------
Commercially-available units consist of a steel wool-
filled plastic canister with appropriate connections. Typical
practice is to feed waste fixer to a train of two canisters in
series. The first canister removes the bulk of the silver, and the
second polishes the effluent of the first. It also is a safety
factor if the first unit is overloaded When the first is ex-
hausted, the second becomes the first, and fresh unit replaces
the second. One supplier recommends changing when the
silver in the effluent of the first cartridge reaches 25 percent of
the influent concentration (Eastman Kodak 1980). Silver con-
centration in the effluent from a single canister averages 40 to
100 mg/L over the life of the system, versus a range of 0.1 to
50 mg/L when two canisters are used in series. Fixer desilvered
by this process cannot be recycled, because of excessive iron
concentration in the effluent (averaging 4,000 mg/L).
For the most effective operation, the pH of the solution
passing through the metallic replacement unit should be be-
tween 4 and 6.5. The optimum is between 5 and 5.5. Below
pH 4, the dissolution of the steel wool is too rapid. Above pH
6.5, the replacement reactions may be so slow that silver
removal is incomplete. Thus, proper pH control is important
to high silver recovery. A metal replacement canister should
recover about 85 percent of the recoverable silver in the form
of a sludge, which must be further processed to produce pure
metallic silver (Calif. DHS 1989a).
Electrolytic Recovery
An electrolytic unit can be used for a primary or a tailing
waste stream, and can be either batch or continuous. This
silver recovery method applies a direct current across two
electrodes in a silver-bearing solution. Metallic silver deposits
on the cathode. Sulfite and thiosulfate are oxidized at the
anode:
HjO + SO,'2 —> SO4-2 + 2e- + 2H+ (Anode)
$03-2 + S2O3-2 —> SsOe-2 + 2e- (Anode)
Ag+ + e* —> Ag° (Cathode)
Approximately 1 gram of sodium sulfite is oxidized for
each gram of silver deposited. Considerable agitation and
large plating surface areas can achieve good plating efficiency
and silver up to 90-98 percent pure. Lower silver purity levels
usually result from tailing unit applications because of the
lower silver concentration in the influent solution. The cath-
odes are removed periodically, and the silver metal is stripped
off. An electrolytic system should recover about 90 percent of
the recoverable silver.
Care must be taken to control the current density in the
cell because high density can cause "sulfiding." Sulfiding is
the decomposition of thiosulfate into sulfide at the cathode,
which contaminates the deposited silver and reduces recovery
efficiency. The higher the silver concentration, the higher the
current density can be without sulfiding. Therefore, as the
silver is plated out of solution, the current density must be
reduced.
Batch Electrolytic Recovery
In batch recovery, overflow fixer from one or more
process lines is collected in a tank. When sufficient volume is
reached, the waste fixer is pumped to an electrolytic cell for
silver removal. The desilvered fixer can be discharged to a
sewer, disposed of as solid waste, or reused. If reused, it is
transferred to a mix tank where sodium thiosulfate is added to
replenish its strength.
Primary batch system cells are usually designed to desilver
the fixing batch at initial silver concentrations of about 5,000
mg/L. The silver concentration in the effluent is typically 200-
500 mg/L. Effluent of 20-50 mg/L is possible with additional
treatment time and careful current density control. An electro-
lytic tailing cell typically achieves the lower range because
the process can be optimized for low initial silver concentra-
tions.
Continuous Electrolytic Recovery
The volume of a continuous electrolytic unit must be
large enough relative to the incoming flow volume to ensure
adequate residence time of the fixer, so two or more units can
be placed in series to achieve this. The continuous flow of
incoming fixer supplies a constant quantity of silver for
electrolytic recovery. As a result, the units can be operated at
a relatively stable current density. Such systems can be auto-
matic. Some units can sense silver concentration in solution
and adjust current densities. Usually, continuous flow units
discharge desilvered fixer directly to the sewer.
Recalculating Electrolytic Recovery
Silver can also be removed from an in-use fixer solution
at approximately the same rate it is added by film processing,
using a continuously recirculating system. The recovery cell
is connected "in-line" as pan of the recirculation system. This
continuous removal technique has the particular advantage of
maintaining a relatively low silver concentration in the fixer
processing solution, which minimizes the amount of silver
carried out into the wash tank. The silver concentration in the
fixer can be maintained in the range of 500 to 1,000 mg/L
without forming sulfide.
A recirculating silver recovery unit receives a small con-
tinuous stream of fixer from an in-use process tank, removes
the silver, then returns the desilvered fixer to the
photoprocessor. Each photoprocessor requires a separate unit.
Systems are available for treating all types of non-bleach
fixers that have circulation pumps. Once installed, the unit is
fully automatic, turning itself on by sensing the flow of fixer
through the electrolytic cells. The cells themselves contain no
moving parts, and the silver is harvested every two to three
months.
Desilvered fixer solution can be reused, whether from an
"in-line" continuous system or from batch. This requires
adequate monitoring and process control to maintain compo-
sition and protect quality. Some manufacturers have special
electrolytic fixers for this application. Parameters (pH, silver,
and sulfate concentrations) should be monitored to maintain
16
-------
the physical and chemical properties of the fixer solution,
usually through the addition of make-up chemicals.
Chemical Precipitation
Chemical precipitation is the oldest and cheapest method
for recovery of silver. It is widely used by manufacturers of
photographic supplies but usually not by photoprocessors.
The two primary disadvantages are that extremely toxic hy-
drogen sulfide gas (H,S) can be evolved, and that the resulting
sludge may have to be managed as a hazardous waste. A third
disadvantage is that recovery of silver from the sludge is more
difficult than with other methods.
Sodium sulfide causes silver sulfide to precipitate readily
from waste fixer solutions.
— >Ag2S
Silver sulfide has a solubility product of 1050, making it
one of the most insoluble substances known. Precipitation
must be carried out in alkaline media to avoid the generation
of HjS. Silver sulfide tends to form colloidal suspensions. Its
very small particle size makes filtration difficult, and the filter
cake generated is extremely dense. However, diatomaceous
earth filter aid can be used to improve filtration. About three
grams filter aid are required for each gram of silver, if a
conventional plate-and-frame filter press is used (Calif. DHS
1989a).
Sodium borohydride (NaBH^ is also an effective precipi-
tant for silver
NaBH4 — > Na+ +
BH4~ + 2H2O + 8Ag+ — > 8Ag° + 8H+ + BC>2~
The borohydride method requires significantly more than
the stoichiometric quantity to complete the reaction, while
sodium sulfide precipitation requires use of very little excess
chemicals. Borohydride also reduces many other metals such
as cadmium, lead, and mercury (Cook and Lander 1979). The
major difference between the two processes is the resulting
silver quality. Sodium borohydride produces elemental silver
of 96 to 98 percent purity. Either method can reduce silver
concentrations to 0. 1 mg/L in the fixer waste water.
The process mixes die precipitation agent with the silver-
bearing waste water in a batch reaction tank equipped with
automatic pH control. When sodium sulfide is used, the pH
must be maintained above 7 to avoid releasing H^S. The
optimum pH range for sodium borohydride precipitation is
5.5 to 6.5 (Cook and Lander 1979). Solid particles having a
size of 1 to 2 microns are formed, and are allowed to settle
before filtering. Usually solutions reacted with either sodium
sulfide or sodium borohydride are not reused in the photo-
graphic process
Silver Recovery From Rinse Water
Even with an efficient fixer solution silver recovery sys-
tem and an effective squeegee on the fixer tank, up to 10
percent of the recoverable silver is lost by cany-over into the
rinse tank. The silver concentration in the spent rinse water is
typically in the range of 1 to 50 mg/L, too low for economical
recovery with electrolytic or metallic replacement methods. In
addition, the iron by-product from metallic replacement pre-
cludes reuse of the rinse water, although some photoprocessors
use metallic replacement to meet municipal sewer effluent
limits. Precipitation is uneconomical for rinse water (Calif.
DHS 1989a).
Two methods are currently being used for effective re-
covery of silver from rinse water resin ion exchange and
reverse osmosis (RO). A third method, called "low flow
prewash," has been used in a few locations in the United
States.
70» Exchange
Ion exchange is the reversible exchange of ions between a
solid resin and a liquid. A variety of weak and strong anionic
resins are effective in silver recovery. Using chloride as the
mobile ion, the following represents the reaction:
(Resin) -Cl + AgS2(>3~—> (Resin)-AgS2C>3 + Cl-
(in solution) (in solution)
The silver-thiosulfate complex has a high affinity for the
resin, making it difficult to reclaim the silver and regenerate
the resin. Other problems include plugging of the resin by
suspended matter, such as gelatin, but these have also been
solved by improved equipment design and operational proce-
dures. Some ion exchange units produce effluents with silver
concentrations as low as 0.1 ppm, recovering as much as 98
percent of the silver (Eastman Kodak 1990). High-capacity
units can process as much as 500 gallons per hour (Calif. DHS
1989b).
Reverse Osmosis
In reverse osmosis (RO) techniques, the waste water
stream flows under pressure over the surface of a selectively
permeable membrane. Water molecules pass through the mem-
brane and other constituents are left behind. The extent of
separation is determined by membrane surface chemistry and
pore size, fluid pressure, and waste water characteristics. The
RO unit has one inlet to receive the waste stream, and two
discharge outlets. Purified water (permeate) exits from one
outlet, and concentrated waste water exits from the other. This
process reportedly can recover 90 percent of the silver thiosul-
fate (Eastman Kodak 1990). Silver can be recovered from the
resulting concentrate by conventional silver recovery meth-
ods. The waste water must be pumped to a high pressure
(about 600 psig) before feeding the RO unit, which may incur
high energy and maintenance costs. Operating problems in-
clude fouling of the membrane and biological growth. Proper
maintenance and control can alleviate these problems. One
plant reported membrane fouling, which required frequent
membrane replacement at high cost The problem was solved
by installing a sandbed filter upstream of the RO unit (Calif.
DHS 1989a). RO requires more capital investment than most
other silver recovery methods, discouraging its use in
photoprocessing (Eastman Kodak 1990).
17
-------
Low Flow Prewash
Low flow prewash involves segmenting the after-fix wash
tank to perform the washing in two stages, with separate rinse
water make-up and overflow. It does the after-fix washing in
two stages. Most of the silver carry-over is washed off in the
low volume, after-fix prewash tank. The system lessens dilu-
tion of the silver carry-over, but means that concentrations of
fixer, silver, and other chemicals reach high levels in the
prewash tank under steady-state conditions. One problem is
that the work being processed may receive additional fix time
and exposure to concentrated contaminants while immersed
in the prewash. Some investigators fear that this may harm the
quality of the processed material. Dye stability tests on color
paper processed using the prewash system showed an increase
in yellow stain six months after processing. Another problem
is increased maintenance of the wash tank because of biologi-
cal growth, although this can be controlled with biocides
(Calif. DHS 1989a).
Stiver Recovery from Scrap
Scrap film and paper result from trimmings, test strips,
and leaders. The silver may be present in the form of silver
salts or elemental silver from fogged or developed material.
The processing of solid materials is more cumbersome than
for solutions, but there are a number of silver recovery compa-
nies in business that will buy solid scrap. If necessary, the
silver in scrap film and paper can be removed in the photo lab
by treating the material with a sodium hypochlorite solution to
oxidize elemental silver, assuring that all silver is in the form
of salts that can be removed by fixing. Some photo labs
collect fixer overflow in a container and add unprocessed
scrap film or paper as it is generated. Once dissolved in the
fixer, the silver can be recovered through the same silver
recovery processes used by the lab for the fixer solutions from
the photoprocessors. This approach can increase the amount
of silver recovered on site, but can also be a bit messy.
Digested film or paper can be difficult to handle and may even
go sour, if left in the container long enough to be attacked by
bacteria (Calif. DHS 1989a).
Processed or unprocessed film can be soaked in an agi-
tated, hot solution of sodium hydroxide to remove the emul-
sion. The silver can then be separated from the solution by
settling, centrifuging or filtering (Eastman Kodak 1980b).
Some film base can be sold as scrap polymer after the silver-
bearing emulsion has been removed, so segregating film by
type of base is recommended.
Color Developer Reuse
Color developers which can be regenerated are available,
allowing the photoprocessor to reduce replenisher purchases
about 50 percent One regeneration process requires the addi-
tion of an ion-exchange unit to remove the excess develop-
ment by-products from the developer overflow. Another
process accomplishes the same objective without ion ex-
change, Using a different developer solution (Eastman Kodak
1989b).
Ferricyanide Recovery
Ferricyanide bleaches reduce to ferrocyanide during the
bleach process. The spent ferrocyanide can be regenerated
either electrolytically or chemically. Chemical methods em-
ploy either ozone or persulfate. Regenerated ferricyanide can
be re-used in photoprocessing.
Electrolytic Regeneration
Spent bleach is fed to an electrolytic cell, where the
following reactions occur (Eastman Kodak 1990):
Anode:
Primary: 2Fe(CN)6-4 —> 2Fe(CN)6'3 + 2e'
Secondary: 4OH~ —> O2 + H2 + 2OH" +2e~
Cathode:
Primary: 2H2O + 2e' —> H2 + 2OH-
Secondary: Fe(CN)g-3 + e" —> Fe(CN)6'4
The evolution of hydrogen gas presents a potential safety
hazard.
Persulfate Regeneration
This method is relatively inexpensive and safe, since it
does not liberate any hazardous gases. The reaction is:
-2 — > 2Fe(CN)6-3 + 2SO4-2
2Fe(CN)6-4
The major disadvantage is that gradual accumulation of
sulfate salt reduces bleaching efficiency (Eastman Kodak 1990).
Ozone Regeneration
Ozone reacts with ferrocyanide to form ferricyanide as
follows:
»2Fe(CN)6"3+2OH'+O2
Hydrobromic acid is also added to control pH and to
supply the bromide ion needed for the bleach process. The
major advantage of this process is that there is no salt buildup.
Disadvantages include high initial cost for the ozone genera-
tor and potential safety problems, since ozone is corrosive,
unstable, and high reactive. Because of these disadvantages,
this process is likely to be used only by large labs (Eastman
Kodak 1990).
Ion Exchange
Bleach water containing dilute concentrations of
hexacyanoferrates (either ferricyanide or ferrocyanide) can be
passed through a column containing a weak base anion ex-
change resin, which removes the hexacyanoferrate. The resins
then regenerated with sodium hydroxide, and the recovered
hexacyanoferrate reacted with ozone or persulfate to recover
ferricyanide as shown above. Treated effluent from this pro-
cess can contain as little as 0.07S mg/L (75 parts per billion)
hexacyanoferrate (Eastman Kodak 1990).
18
-------
Reverse Osmosis
Reverse osmosis can remove up to 95 percent of the salts
from fixer solutions, including nearly all of the
hexacyanoferrates. The capital investment is relatively high,
which has limited applicability of this process in
photoprocessing (Eastman Kodak 1990).
Precipitation
Fixer overflow can be treated with ferrous sulfate and a
flocculant to produce ferrous ferrocyanide. Then either so-
dium or potassium hydroxide is added to make the ferrocya-
nide, which can be reoxidized with one of the bleach
regeneration techniques. The resulting ferricyanide can be
reused as bleach replenisher.
Another method uses calcium chloride to precipitate the
salt Ca(NH4)2Fe(CN)6- This method can reduce ferrocyanide
concentration of some color-reversal fixers to less than 1 g/L
(Eastman Kodak 1990).
Water Conservation
Water conservation is especially important in certain
parts of the United States where either (a) fresh water is in
short supply or (b) local regulations severely limit or prohibit
discharge of photoprocessing effluents to the sewer system.
Some operators simply shut off the rinse water except when
film is moving through the processor. However, certain pro-
cessors require a continuous water flow to maintain tempera-
ture control. Many locales have established concentration-based
limits on aqueous effluents. Photoprocessors must check the
local requirements to be sure that reducing water without
proportionately reducing all other contaminants will not vio-
late the concentration limit
Rinse Water Recycling
To maintain product quality, many photoprocessing op-
erations use continuous rinse water flows. The result is rinse
water waste streams usually are the highest volumes of waste
from photoprocessors. This effluent consists primarily of wa-
ter with tow concentrations of chemicals from the carry-over
of the processing solutions. Commercial rinse water recycling
systems are available for photoprocessing operations. Spent
rinse water can be treated to restore purity and recycled for
rinsing. A small portion of incoming clean water is added to
the recycled water stream, and an equivalent overflow goes to
the sewer drain after the fixer wash. A single recycling system
can serve several photoprocessor units.
Countercurrent Rinsing
Continuous photoprocessing trains may employ a series
of rinse steps, designed so that water flows countercurrent to
the process. Thus, fresh water is fed to the final stage. Over-
flow water then goes to the next stage upstream. Of course,
the rinse water becomes more contaminated in each succeed-
ing stage. Thus, it may be economical to use squeegees to
minimize carryover of contaminants into each rinse stage, and
a squeegee between the processing solution and the first wash
stage is recommended. Otherwise, efficiency will be impaired
and product quality will degrade.
19
Plumbingless Minttabs
Plumbingless minilabs use a proprietary chemical stabi-
lizer in place of wash water. While conventional minilabs
discharge 20 to 25 gallons of effluent per roll of film pro-
cessed, this type of lab discharges less than 0.1 gallon of
effluent per roll. Although the volume of effluent is greatly
reduced, the concentrations of contaminants are much higher
than for conventional minilabs. Wherever there are concentra-
tion limits on sewer discharges, potential users should review
this point with local authorities if silver can be recovered from
this effluent using either the metallic replacement or electro-
lytic processes described above (Eastman Kodak 1986).
Evaporation
Another option in managing waste photographic solu-
tions is evaporation, in which the waste waters are collected
and heated to evaporate all liquids. This is often done under
vacuum to reduce the boiling temperature. The resulting sludge
is collected in filter bags, which can be sent to a silver
reclaimer for recovery. Evaporation can accommodate opera-
tions that do not have access to sewer connections or waste
water discharge. If the water vapor is condensed and recycled,
instead of being vented to the atmosphere, then this can be
considered a source reduction technique.
One manufacturer has an automatic recirculating system
in which aqueous effluent is continuously introduced into the
evaporation chamber. The water is vaporized, then condensed
and recycled to a rinse water holding tank. As the water
evaporates, the solids are collected in one of two S-micron
filter bags. When the unit senses that the filter bag is full, it
switches the flow to the other filter bag, and alerts the operator
to remove the filled bag.
The advantage of this approach is it achieves "zero"
water discharge. Virtually all of the silver in the waste solu-
tions is captured with the solids. There are several disadvan-
tages, however. One is that volatile organics in the waste
solution may be evaporated as well, creating an air pollution
problem. One evaporation unit has a charcoal air filter to
capture these organics. A second disadvantage is that any
organics which condense with the water will be recycled also,
causing a potential buildup of their concentrations in the
process. Finally, the. cost of energy to evaporate water is likely
to be high (Calif. DHS 1989a).
References
Bard, C.C., JJ. Murphy, DL. Stone, and C J. Terhaar. Febru-
ary 1976. Silver in photoprocessing effluents. Journal
Water Pollution Control Federation, Vol. 48, No.2,
Calif. DHS. 1989a. Waste audit study: photoprocessing in-
dustry. Report to California Department of Health Ser-
vices, Alternative Technology Section, Toxic Substances
Control Division. Prepared by Arthur D. Little, Inc.
Calif. DHS. 1989b. Reducing California's metal-bearing waste
streams. Report to California Department of Health Ser-
vices, Alternative Technology Section, Toxic Substances
Control Division. Prepared by Jacobs Engineering Group
Inc.
-------
Calif. DHS. 1988. Waste audit study: commercial printing in-
dustry. Report to California Department of Health Ser-
vices, Alternative Technology Section, Toxic Substances
Control Division. Prepared by Jacobs Engineering Group,
Inc.
Cook, M.M. and J.A. Lander. 1979. Use of sodium borohy-
dride to control heavy metal discharge in the photographic
industry. Journal of Applied Photographic Engineering.
Vol. 5, No. 3, pp 144-147.
Cooley, A. C., T. J. Dagon, P. W. Jenkins, and K. A. Robillard.
1987. Silver and the environment. Presented at the Sympo-
sium on Environmental Issues in Photofinishing, Los An-
geles, CA. September 15 -17.
Eastman Kodak Company. 1990. Disposal and treatment of
photographic effluent. In support of clean water. Publica-
tion J-55.
Eastman Kodak Company. 1989a. Choices - choosing the
right chemicals for processing Kodak professional color
negative films. Publication J-30.
Eastman Kodak Company. 1989b. Choices - choosing the
right chemicals for photofinishing labs. Publication J-35.
Eastman Kodak Company. 1989c. Choices - choosing the
right silver-recovery method for your needs. Publication J-
21.
Eastman Kodak Company. 1989d. Disposing ofminilab efflu-
ent. Publication J-20.
Eastman Kodak Company. 1989e. Potential silver yield from
Kodak photographic products. Publication J-10A.
Eastman Kodak Company. 1987. The use of water in photo-
graphic processing. Publication J-S3.
Eastman Kodak Company. 1983. Silver recovery with the
Kodak chemical recovery cartridge. Type 3. Publication J-
9.
Eastman Kodak Company. 1980a. Analysis, treatment and
disposal of ferricyanide in photographic effluents - A
Compendium. Publication J-54.
Eastman Kodak Company. 1980b. Recovering silver from
photographic materials. Publication J-10.
England, R. 1987. Market focus is on photo minilabs. Insight.
April 13.
Freeman, H. M. 1990. Hazardous Waste Minimization.
McGraw-Hill Publishing Co. Locker, D. J. 1972. Photog-
raphy In: Kirk-Othmer Encyclopedia of Chemical Tech-
nology, 3rd Ed. Vol. 17. pp. 611 - 656.
Quinones, P.R. 1985. Optimizing silver recovery in
photofinishing operations. Journal of Imaging Technol-
ogy, Vol. 11, No. 2, April.
Sribnick, L. 1986. The color darkroom- How to tell when your
color chemicals and printing papers go bad, and how to
make them last longer. Popular Photography. April, p.18.
20
-------
Section 4
Waste Minimization Assessment Worksheets
The worksheets provided in this section are intended to
assist photoprocessors in systematically evaluating waste gen-
erating processes and in identifying waste minimization op-
portunities. These worksheets include only the waste
minimization assessment phase of the procedure described in
the Waste Minimization Opportunity Assessments Manual. A
comprehensive waste minimization assessment includes a
planning and organizational step, an assessment step that
includes gathering background data and information, a feasi-
bility study on specific waste minimization options, and an
implementation phase. For a full description of waste minimi-
zation assessment procedures, please refer to the manual.
Table 6 lists the worksheets included in this section. After
completing the worksheets, the assessment team should evalu-
ate the applicable waste minimization options and develop an
implementation plan.
Table 6. List of Waste Minimization Assessment WorkahMts
Number Tide
1. Waste Minimization Status
2a. Waste Minimization: Photoprooessor Operations
2b. Waste Minimization: Photoprocessor Operations
3. Option Generation: Photoprocessor Operations
4. Waste Minimization: Silver Recovery
5. Waste Minimization: Silver Recovery
6. Waste Minimization: Black and White Prints
7. Waste Minimization: Color Prints
8. Waste Miminization: Potentially Recoverable Silver
9. Waste Sources
10. Waste Minimization: Material Handling
11. Waste Minimization: Material Handling
12. Waste Minimization: Material Handling
13. Option Generation: Material Handing
Description
Questionnaire on current status of waste minimization
Questionnaire on operating procedures. Part I
Questionnaire on operating procedures, Part II
Questionnaire on silver recovery
Questionnaire on recovery methods
Calculation form
Calculation form
Calculation form
Relative importance of sources
Questionnaire on material handling
Questionnaire on procedures for drums, containers and
packages
Questionnaire on procedures for bulk liquids
Waste minimization options for material handling operations
21
-------
Irm
lite
Date
Waste Minimization Assessment
Proj. No..
Prepared By
Checked By
Sheet of Page of
WORKSHEET
WASTE MINIMIZATION:
Waste Minimization Status
Does this photoprocess laboratory have a formal waste minimization program?
If yes, who is responsible for overseeing the program?.
Q Yes Q No
Describe goals of the program and results:.
Has a waste minimization assessment been performed previously at this laboratory? If so, describe results:
Have waste minimization techniques and options been discussed with:
Chemical suppliers?
Equipment vendors?
Regulatory agencies?
If so, describe results:.
Q Yes Q No
a Yes Q No
a Yes a No
Does this laboratory have emission or waste disposal problems now?
Aqueous effluent
Air emissions
Solid waste
If the answer Is YES, describe the probtem(s):.
Q Yes Q No
Q Yes Q No
Q Yes Q No
Do you perform material balances routinely?
photowt1.pm3
Q Yes 0 No
22
-------
Firm
Slta ,
Data
Waata Minimization Aaaaaamant
Proj. No..
Preparad By
Chackad By
Shaat of Paga '. of
WORKSHEET
2a
WASTE MINIMIZATION:
PrtotoprocMsor Operations
Ara formallzad oparating procadurea usad to control your photoprocasslng
operations?
Yes Q No
If your answar Is YES,
Ara thasa procaduraa In writing?
Ara thasa procedures available at each photoprocasslng work area?
Do tha procaduraa Induda replenishment rates, wash water flow rates,
and the uaa of teat strips?
Do the procedures Include operation and maintenance of silver recovery
equipment?
Are your photoprocessors Inspected regularly?
Q Yes O No
a Yes Q No
Q Yes Q No
Q Yes Q No
Q Yes Q No
If your answer Is YES, do the inspections Include:
Equipment leaks? a Yes Q No
Replenishment ratee and waeh water flow settings? Q Yes Q No
Chemical and waahwater flows shut off when processor is not being used? Q Yes Q No
Coven on photoprocasslng chemicals containers when not In use? Q Yes Q No
Have you Installed squaegeaa to minimize carryover of one chemical solution to
another and from the fixer solution Into the wash water?
Yes Q No
photom2.pm3
23
-------
:irm
Site
Date
Waste Minimization Assessment
Proj. No..
Prepared By
Checked By
Sheet of Page of
WORKSHEET
2b
WASTE MINIMIZATION:
Photoprocessor Operations
How are chemical replenishment rates set?
Use test strips* a
Photoprocessor instructions Q
Chemical supplier recommendations Q
When are batch chemical solutions discarded?
When product quality degrades Q
When production run is finished Q
Other O
How are rinse water rates set?
Use test strips* Q
Photoprocessor instructions Q
Chemical supplier recommendations Q
How is rinse water used?
Once-through Q
Countercurrent Q
Recycled through dean-up system a
Are any chemicals recovered and reused?.
Operator experience
Other
After a pre-set time
(e.g. weekly)
Operator experience
Other
Still rinse
Flowing rinse
Q
Q
Q
Q
Q
a
If so, describe which ones and how..
•Using test strips will minimize unnecessary additions and consequent discharges.
24
-------
Firm Waata yinlmteattan A*M»
Stta
Data Pro). No.
•maul PraoaradBv
ChackadBv
WOHKSHEET OPTION GENERATION:
O ,'••./ ".>...•.•.•••.••-. .,••,:-:-;•.::•.,. • ..-.:• :, ;: ,; , .
O Pfiotoproetssor Operation*
Maatlng format (a.g., bralnstormlng, nominal group tt
Maating Coordinator
ichnioua)
Maatlng Partldpanta
ouggaataa waata Minimization optwna
Incraasa Slza of Production Run
Parform Malarial Balanoa
Kaap Racords of Wasta Souroas A Disposition
Wasta/Matarials Documantatlon
Provlda Oparating Manuals/Instructions
Employaa Training
InerMMd SuoMvtalan
incivBivu oupvrvwon
Provlda Employaa Incantlvaa
Encouraga Dry Claanup
Incraasa Rant Sanitation
Establish Wasta Minimization Policy
Sat Qoals for Souroa RaductJon
Sat Goals for Raductton
Sat Qoals for Racydng
Conduct Annujsl Assaaamanta
Uaa Tast Strips
nacovar svvar irom Lmuams
Raganarata Blaach or BlaactvFIx
Currantty
DenaY/N?
Rational/ftomarka on Option
25
-------
Firm
Site
Date
Waste Minimization Aaseaament
Proj. No.
Prepared By.
Checked By .
Sheet of Page of
WORKSHEET
WASTE MINIMIZATION:
Silver Recovery
Has the quantity of silver processed been determined?
If no, estimate the amount based on film processed using worksheets 6,7, and 8.
Enter quantity processed
Is silver now recovered from:
Developer solutions
Fixer solutions
Bleach or bleach-fix solutions
Rlnsewater
Combined aqueous effluents
Silver-bearing solids (e.g. paper, flm)
Quantity of silver recovered
Quantity of silver potenttaly recoverable
Which silver recovery processes are used? On which streams?
Metal replacement (one cartridge)
Metal replacement (series cartridge)
Electrolytic
Redrculatingetectror/tte
Batch electrolyte
Predpftatkxi
ton exchange
Hybrid (two or more procesiei)
Q Yes Q No
Troy ozJmo.
Q Yes Q No
Q Yes Q No
0 Yes Q No
Q Yes Q No
Q Yes Q No
Q Yes Q No
Troy or/mo.
Trey ozJmo.
26
-------
Rrm
Stta ,
Data
Waata Minimization Aaaaaamanl
ProJ.No..
PraparadBy
ChacfcadBy
Sheet of Paga .of.
WORKSHEET
WASTE MINIMIZATION:
Slrvtr R»covt)ry
METALLIC REPLACEMENT
Do you UM tHvar tact stripa on tha dlacharge watar to maka aura that tha canieter
la oparatlng efficiently?
Do you changa tha canlatar immediately whanavar tha taat atrip ahowa allvar
In tha dlacharga?
Do you Impact tha eanlatar ayatam ragularty for tha following:
Laaka from tha hoM oonnactton?
Plugging and channeling?
Do you maka aura that your caniatar haa • conatant flow of aolutlon running
through It (rathar than Intermittent dripping during operation)?
Q YM Q No
Q YM Q No
a YM a NO
a YM a NO
a YM a NO
ELECTROLYTIC RECOVERY
Do you check the current on the electrolytic unK(a) regularly (at least daly)to
enaure II la within tha range apadflad by tha manufacturer?
i (the cathode or
Do you check the unk(a) to enaure that agitation la
anode la rotating, the aolutlon pumpa are working)?
la a filter uaed to remove dW and other partfclM from the fixer aolutlon before
I ontara the electrolyte unt?
Do you UM elver taat atrlpa on the dbcharge water dally to make aura that the
electrolytic unlt(a) la operating efficiently?
Q YM Q No
Q YM Q No
Q YM Q No
Q YM Q No
phoMm&emS
27
-------
Firm
Site
Date
WORKSHEET
6
Waste Minimization Assessment Prepared By
Checked By
Proi-No. sh,^ of Paae of
WASTE MINIMIZATION:
Black & White Prints
BLACK A WHITE PRINTS
Use this worksheet to estimate the area processed each month.
Size f Prints Sq.FL 8q.Pt
In Inch** Per Month Par Print Perl/tenth
21/4x3 1/4
21/2x31/2
31/4x4 1/4
31/2x31/2
31/2x41/2
31/2x5
4x5
41/2x10
41/2x17
5x7 |
7x17
8x10
10x12
11x14
14x17
16x20
18X24
20x24
30x40
34x44
SUBTOTAL
NOTE:
Standard sizes are note<
x 0 050ft •
_. Y n oeofl •
v 0 OQ5O _
v o oaso •
Xn inoj —
X 0.833 •
X 3330 •
v 1O40 •
j by boxes, Le., 31/2x5
28
-------
Firm
Sit.
Data
WORKSHEET
7
Waste Minimization Assessment Prepared Bv
Checked Bv
Prol. No. stiMt of Page of
WASTE MINIMIZATION:
Color Prints
COLOR PRINTS
Use this worksheet to estimate the area processed each month.
Sin f Prints 8q.Ft Sq.Pl.
In Inehaa Parllonth Per Print Par Month
21/9 v 1 1/9
31/4 * A 1/4 —
31/9 v 1 1/9
I/4
18 X 24 —
20x24
30 Yin
3el Vetai
SUBTOTAL
NOTE:
Standard sizes are noted b
X 00059 • — - •
v n nfiso •
x 0.833 •
1 t-330 •* - --
y boxes, Le., 31/2x5
29
-------
:irm.
Stta .
Data
Waata Minimization Aaaaaamant
Proj.No..
Prepared By
ChackadBy
Shaat of
of P*Q«_of
WORKSHEET
8
WASTE MINIMIZATION:
Recoverable Silver
Sourea
Black & Whtta Film
Color Rim
Black & Whtta Print*
Color Prints
Motion Picture Film
Othar
TOTAL SILVER
Sq. FL1
par mo.
TroyOx2
Trov ozJma.
Potentially
Raeovarabla
Trov
x
X
X
X
X
X
X
X
X
X
X
X
0.8
1.0
0.5
1.0
Notas:
1Saa Workahaata 6 and 7 for film roll araa calculation.
*Saa TaWa 3 or consul your tuppHar for allvar contant
30
-------
Firm Wacte Minimization A****»m»nt
Site
Date Proi. No.
Pre
CTM
Sh<
WORKSHEET
Q WASTE SOURCES
Waste Source: Material Handling
Off-spec materials
Obsolete materials
Spills & leaks (liquids)
Spills (powders)
Empty container cleaning
Container disposal (metal)
Container disposal (paper)
Container disposal (plastic)
Pipeline/tank drainage
Evaporative tosses
Other
Tank cleaning
Container cleaning
Process effluent
Spent rtnaewaJer
Rim reels, canisters, spools
Other
pared
Kkedl
•t
Bv
3v
of Pan* rrf
Significance at Plant
Low
Medium
High
*
31
-------
Firm,
Site .
Date
Waste Minimization Aeeeeament
ProJ.No..
Prepared By
Checked By
Sheet of Page of
WORKSHEET
10
WASTE MINIMIZATION:
Material Handling
GENERAL HANDLING TECHMQUE8
Are all Input materials tested for quality before being accepted from suppliers? Q Yes Q No
Describe safeguards to prevent the use of materials that may generate off-spec product:
Is obsolete material returned to the supplier?
Is Inventory used In flrst-in, first-out order?
Is the Inventory system computerized?
Does the current Inventory control system adequately prevent waste generation?
What Information does the system track?
Q Yes Q No
Q Yes Q No
Q Yes Q No
Q Yes a No
Is there a formal personnel training program on material handling, spill prevention,
proper storage techniques, and waste handling procedures?
Does the program Include Information on the safe handling of the types of drums,
containers, and packages received?
Are written procedures avaBaWe and easUy accesabie?
How often Is training given and by whom?
Q Yes Q No
Q Yes Q No
Q Yes Q No
What spin containment methods are used?
photowt10.pm3
32
-------
Firm
Sfta .
Oat*
Waata Minimization Aaaaaamant
PTOJ.NO..
PraparadBy
ChackadBy
Shaat of Paga .of
WORKSHEET
11
WASTE MINIMIZATION:
Material Handling
B
DRUMS, CONTAINERS, AND PACKAGES
Ara drums, packagas, and containars Inspactad for damaga before being accaptad?
Ara amployaas trainad In ways to safaly handla tha typas of drums & packagas racalvad?
Ara thay proparly trainad In handttng of spilled raw materials?
Ara stored Harris protected from damaga, contamination or axposura to heat, Ight
and air?
Q Yas Q No
Q Yas Q No
Q Yas Q No
Q Yas Q No
Dascriba handling procaduras for damagad Harm:
Ooas tha layout of tha facility rasul In haavy traffic through tha raw matarlal storaga area? Q Yas Q No
(Haavy traffic Increasas tha potential for contaminating raw materials with oTrt or
dust and for causing spilled materials to bacoma dlsparsad throughout tha facility.)
Can traffic through tha storaga area ba reducad? Q Yas Q No
To reduca tha generation of ampty containars and liquid wastes dua ta their daanlng,
has tha facility attempted to:
Purchasa pra-mtxad solutions to minimize maasuring, mixing, and handing? Q Yas O No
Purchasa solutions In recydabla containars? Q Yas Q No
Othar approaches (Daacrtba ) Q Yas Q No
Discuss tha results of these attempts:
Ara all ampty baga. packagas, and containars that contained hazardous materials segregated from those that
containadnon-hazardouawaataa? Describe method currently used to dkpose of hazardous waste:
photowsH .pniS
33
-------
Firm ,
Site .
Date
Waete Minimization Assessment
Prol. No.
Prepared By _
Checked By .
Sheet of Page .of
WORKSHEET
12
WASTE MINIMIZATION:
Material Handling
C. BULK LIQUIDS HANDUNQ
What safeguards are in place to prevent spills and avoid ground contamination during the filling of storage tanks?
High level shutdown/alarms Q Secondary containment Q
Flow totalizers with cutoff Q Other Q
Are air emissions from buk chemical storage tanks controlled by means of:
Conservation vents Q Absorber/Condenser Q
Nitrogen blanketing Q Other vapor loss control system Q
Adsorber Q
Are all storage tanks routinely monitored for leaks? If yes, describe procedure and monitoring frequency for
aboveground/vautted tanks:
Underground tanks:
How are the-Hqulds In these tanks dispensed to the users? (I.e., * *"»" containers or hard piped)
Are pipes cleaned regularly?
dtae
MS the way pipes are cleaned and how the resulting waste Is handled:
When a spill of liquid occurs what cleanup methods are employed (e^., wet ordry)? Also discuss the way In
which the resulting wastes are handled: ,
pnotow»12.pm3
34
-------
Firm Waeta Minimization A**A*»m«nt Prtoartd BY
Site
Data Pro). No.
Checked Bv
Sh«*t of PKM of
WORKSHEET WASTE MINIMIZATION:
13 Material Handling
Meeting Format (e.g., brainstorming, nominal group tec
Meetlnq Coordinator
Unique)
Meeting Participants
Suggested Waste Minimization Options
A. GENERAL HANDUNO TECHMOUE8
Quality Control Check
Return Obsolete Material to Supplier
Minimize Inventory
Computerize Inventory
Formal Training
Recycle Rim Reels, Canisters, and Spools
B. DRUMS, CONTAINERS, AND PACKAGES
Raw Material Inspection
Proper Storage/Handtag
Pre-mbced Solutions
^* nnnlaiil« ^Jkfl^*b»A«M
necydaow woransfs
BukDelvsry
C. BULK LIQUDS HANDUNO
rtgh Level Shmdown/Atarm
Flow Totatzeis «Mi Cutoff
Secondary Containment
Air Emissions Control
LeakMonlorlna
Spiled Material Reuoo
Cleanup Methods to Promote Recydng
Currently
DeneY/N
Rationale/Remarks on Option
35
-------
-------
Appendix A
Photoprocessing Laboratory Assessments
Case Studies of Photoprocessors A, B, C and D
Case Studies of Photoprocessing Laboratories
In 1989, the California Department of Health Services
(DHS) commissioned a waste minimization study of
Photoprocessing laboratories. The objectives of the waste
minimization assessments were to:
• Gather site-specific information concerning the generation,
handling, storage, treatment, and disposal of hazardous waste;
• Evaluate existing waste reduction practices;
• Develop recommendations for waste reduction through source
control, treatment, and recycling techniques; and
• Assess costs and benefits of existing and recommended
waste reduction techniques.
In addition, the results of the waste assessments were
used to prepare waste minimization assessment worksheets to
be completed by other photoprocessors in a self-assessment
process.
The first step in conducting the assessments was selecting
and contacting the photoprocessors to solicit voluntary par-
ticipation in the study. Selection emphasized small busi-
nesses, which generally lack the financial and/or internal
technical resources to perform a waste reduction assessment
This Appendix presents both the results of the assess-
ments of three photoprocessing labs (here identified as A, B,
and Q and the potentially useful waste minimization options
identified through the assessments. Also included are the
practices already in use at the plants that have successfully
reduced waste generation from past levels. The original as-
sessments may be obtained from:
Mr. Benjamin Fries
California Department of Health Services
Alternative Technology Division
Toxic Substances Control Program
714/744 P Street
Sacramento, CA 94234-7320
(916) 324-1807
A fourth photoprocessor performed a self-assessment
using the worksheets presented in Section 4 (Case D). This
case was not part of the DHS study.
37
-------
Photoprocessor A Assessment
Facility Description
Photoprocessor A operates 12 hours a day, five days a
week. The staff consists of 25 people. Monthly photoprocessing
volumes are listed below:
Black & White Film
Black & White Prints
Color Negatives
Color Prints
Color Slides
Color Prints from Slides
Intemegatives (Color)
Intemegatives (B&W)
500 rolls
347.5 sq.ft.
2,400 rolls
25,135 sq.ft.
1,000 rolls
4,232 sq.ft.
139 sq.ft.
278 sq.ft.
Inventory Management
The company uses a first-in/first-out policy to prevent
chemicals from deteriorating in storage. It also has a comput-
erized inventory tracking system which it uses to maintain a
one-month inventory. As a result, waste from off-specifica-
tion material which has exceeded its shelf life rarely occurs.
The storage areas are checked daily on an informal basis
for spills or leaks. There is an informal training program to
ensure proper storage and handling.
Waste Generation, Handling and Disposal
All aqueous waste discharges to a public sewer which
carries the discharges to a Publicly-Owned Treatment Works
(POTW). The laboratory has an electrolytic silver recovery
unit to treat fixer solutions, followed by a canister-type silver
recovery unit These recovery units are serviced by an outside
contractor. The photoprocessor relies on the contractor to
check and maintain these units. Wash water streams do not
flow through the silver recovery units. Fixer is not recycled.
Silver Recovery
Based on the monthly photoprocessing volumes listed
above, Photoprocessor A estimates it handles the following
quantities of silver
Source azjmd
Black/White Film Processing 2.0
Black/White Print 0.9
Color Film Processing 33.2
Color Print Processing 75.4
Total Silver 111.5
Photoprocessor A estimates it presently recovers % ounces
of silver per month or about 86 percent of the total. Umecovered
silver, 15.5 ounces per month, is assumed to be lost in wash
water, which is not treated. Based on a silver price of $6.00
per Troy ounce, this loss amounts to $93 per month or $1,116
per year.
Aqueous Waste Minimization
This lab does not recycle either fixer or rinse water.
Sewer charges average $58 per month and water bills average
$118 per month. The assessment team estimated that a rinse
water recycling system could save $106 per month.
Other Waste Minimization Practices
Photoprocessor A has not installed squeegees to mini-
mize carryover of solutions, except where these were supplied
as part of the original equipment Management believes that
additional squeegees may be impractical, since the facility
uses a roller transport system. Both bulk and in-use chemical
solutions are kept covered whenever possible. Chemical re-
plenishment and wash water rates are determined by using test
strips for continuous photoprocessing, and at the end of a
production run for batch processing.
Recommendations
Photoprocessor A should take the following actions to
minimize waste:
• Use test strips on its batch chemical solutions to deter-
mine when these should be discarded. Although the
company did not provide cost data for photoprocessing
chemicals, this is a low cost-option which the WMOA
team believes could result in savings.
• Monitor its own silver recovery units to assure they are
performing as efficiently as possible.
• Include replenishment rates, water flow rates, and test
strips in its written operating procedures.
• Evaluate recycling rinse water, including recovering sil-
ver.
• Evaluate recycling fixer.
38
-------
Photoprocessor B Assessment
Facility Description
Photoprocessor B has three employees and operates 8
hours a day, six days a week. Photoprocessing is almost
entirely color negatives and color prints, since the company
sends black-and-white film and color slides off-site for pro-
cessing.
Estimated monthly production volumes are:
Color Negatives
Color Prints
Duplicate Slides
20 rolls
5,500 sq.ft.
10 rolls
Inventory Management
This company does not have a formal inventory manage-
ment system, but waste from off-specification material which
has exceeded its shelf life occurs infrequently. Inventory is
used on a first-in, first-out basis. Stored material is checked
daily for leaks or spills. There is no formal procedure for
training.
Waste Generation, Handling, and Disposal
Waste bleach/fix solution is treated with an electrolytic
silver recovery unit. The desilvered solution is then drummed
and sent off-site to a commercial reclaimer. This waste amounts
to about 1450 gallons per year, or about two drums a month,
and costs $2,175 per year in disposal fees. Other aqueous
wastes discharge to the public sewer, which carries the dis-
charge to a Publicly-Owned Treatment Works (POTW).
Silver Recovery
This lab estimates that it handles 28 ounces of recover-
able silver per month. At a price of $6.00 per Troy ounce, this
quantity is worth $168 per month or $2016 per year. Although
there is an electrolytic recovery unit for the bleach/fix solu-
tion, the lab does not record the amount or value of silver
recovered.
Aqueous Waste Minimization
Neither fixer solution nor rinse water is recycled. Water
and sewer costs are included in the building lease, so there is
no estimate of potential savings for reducing water use.
Other Waste Minimization Practices
Photoprocessor B relies upon operator experience to set
chemical replenishment rates and wash water flow rates to the
continuous process. Batch chemical solutions are discarded at
the end of a production run. No squeegees have been installed,
and floating lids are used on chemical solutions.
Recommendations
The assessment team recommended that Photoprocessor
B take the following actions:
• Use test strips to set chemical replenishment and wash
water, flow rates on continuous processors and to deter-
mine when to discard batch chemical solutions.
• Establish procedures to routinely maintain and monitor
performance of the electrolytic silver recovery unit
• Evaluate installing a metallic replacement unit to recover
silver from spent wash water.
39
-------
Photoprocessor C Assessment
Facility Description
Photoprocessor C operates from 7:30 A.M. to 1 A.M.
seven days a week. There are 45 production employees and 25
persons in sales and administration. Monthly processing vol-
umes are estimated as:
Black & White Film
Black & White Prints
Color Negative
Color Prints
Color Prints from Slides
1,000 rolls
3,000 sq. ft
4,000 rolls
50,000 sq. ft
10,000 rolls
Inventory Management
The company performs an inventory twice a year, and
tries to maintain a one-month stock of materials. Material
usage depends largely on accessibility. There is no first-in/
first-out usage policy, so material occasionally becomes waste
because it has exceeded its shelf life.
Storage areas are checked daily for spills and leaks. The
chemical storage area is diked, and absorbent pillows are
available to contain spills. However, the company does not
have a program to train personnel in handling and storing
materials, nor are personnel trained in spill response proce-
dures.
Waste Generation, Handling and Disposal
All aqueous wastes go to a public sewer and then to a
Publicly-Owned Treatment Works (POTW). Approximately
9,200 gallons a year of spent bleach/fix solution is given to a
contractor, who recovers the silver and disposes of the rest of
the solution. The contractor handles all reports and manifests
for hazardous waste handling and disposal. The company
pays nothing for this service, but receives no credit for recov-
ered silver.
Silver Recovery
Photoprocessor C estimates it handles the following quan-
tities of silver
Source
ozTmo
Black/White Film Processing 4.0
Black/White Prints Color 12
Film & Slides 472
Color Prints Processing 150.0
Total Silver 208.4
The company does not recover any silver on site. There is
no estimate of the amount of silver discharged to the sewer. At
a price of $6.00 per Troy ounce, quantity is worth $1,250 per
month or $25,000 per year.
Aqueous Waste Minimization
Photoprocessor C does not recycle either fixer or rinse
water. Sewer charges average $200 per month and the water
bill averages $250 monthly. In addition, the company spends
about $50 per month to treat its make-up water. The assess-
ment team estimated that water recycling could potentially
save $280 per month.
Other Waste Minimization Practices
Photoprocessor C sets chemical replenishment rates and
wash water flow rates according to the manufacturer's operat-
ing instructions for continuous processing. Batch chemical
solutions are discarded after a pre-determined time (e.g., daily
or weekly). Fixed lids are used on chemical solution contain-
ers. Squeegees have not been installed, unless they were
provided with the original equipment
Recommendations
Photoprocessor C should take the following actions to
minimize waste:
• Implement a first-in/first-out inventory procedure. This
may require reorganizing the storage area to improve
accessibility by the operators.
• Train operators in proper storage and handling proce
dures and in spill response/cleanup procedures.
• Use test strips to set chemical replenishment and wash
water flow rates on continuous processors and to deter-
mine when to discard batch chemical solutions.
• Evaluate installing bom silver recovery and bleach/fix
reuse.
• Evaluate installing a rinse water recycling system.
40
-------
Photoprocessor D Assessment
Facility Description
The size of staff and number of hours per week were not
identified for this establishment, whose primary activity is
producing over 35,000 square feet of color prints per month.
The lab is owned by a large corporation which has a policy of
minimizing waste in its operations.
Inventory Management
The company uses a first-in/first-out policy and has a
computerized inventory management system, which tracks
the total amounts of materials used and the amount per order.
There is a formal personnel training program given bi-annu-
ally by the Safety Committee and the Lead Technician which
covers material handling, spill prevention, proper storage
techniques, and waste handling procedures. Written proce-
dures are available and accessible to all personnel.
Incoming materials are not tested for quality before the
photoprocessor accepts them. However, damaged containers
are not accepted, but are immediately returned to the supplier.
All chemicals are liquids. Containers are rinsed with water,
and the water is subsequently reused in the process. The
containers are then cut, so they cannot be misused later.
Silver Recovery
The company uses both electrolytic and metallic replace-
ment methods to recover silver from waste water. It estimated
that it handles an average of 357.5 Troy ounces of silver per
month but did not report the amount of silver recovered.
Silver is not recovered from either developer solutions or
solid wastes.
Aqueous Waste Minimization
Low-flow wash is used, and wash water flows are shut off
when the processing system is not in use. Water used to rinse
empty chemical containers is reused in the process.
Other Waste Minimization Practices
The company has installed wet floor sensors with an
audible alarm, so that corrective action can be taken promptly
in case of a leak or spill. Small spills are cleaned up with
either sand, a mop, or a wet vacuum. Large spills are con-
tained with dikes and cleaned up with a wet vacuum. Spilled
chemicals are not reused because of potential contamination
but are diluted with water and discharged to the sewer.
A chemical spill kit is located in the area where chemicals
are mixed and stored. This includes personal protective gear
(gloves, goggles, boots, and respirator) as well as dikes, sand,
mops, and floor squeegees.
Squeegees have been installed to reduce carry over of
process solutions.
Chemical replenishment and rinse water rates are set
based on the use of test strips. Batch chemical solutions are
discarded when product quality degrades.
Recommendations
The company plans to investigate using recyclable chemi-
cal containers.
41
-------
Firm ____^__
ite ____
Dttt 6/22/90
WMU MlaialatUoa
Proj. No.
Prepared By .__
Checked By __
Sheet _of__ Page of
WORKSHEET
WASTE MINIMIZATION:
Wiste Minimization Status
Does this facility have a formal wiste minimization program?
Yes
No
Who is responsible for overseeing the program?
Operations Manager
Has a waste minimization assessment been performed previously at this facility? If so,
describe results: NO
Have waste minimization techniques and options been discussed with:
Chemical suppliers?
Equipment vendors?
Regulatory agencies?
Yes
Yes
Yes
XX
No
No
No
If so, describe results: C-PAC suggestions on double tailing of electrolysised
chenicals to raduc* amount of silver in water being discharged into the
sevar. Fuji/Hunt on bleach regeneration techniques.
Does the facility have emission or waste disposal problems now?
Aqueous effluent
Air emissions
Solid waste
If the answer is YES, describe the problem(s):
Yes
Yes
Yes
xx
XX
MBH
XX
No
No
No
42
-------
Finn
Site _
Date 6/22/90
Wast* Minimization Assessment
Proj. No.,
Prepared By
Checked By ._
Sheet of Page of
WORKSHEET
WASTE MINIMIZATIONS
Photoprocessor Operations
Are formalized operating procedures used to control your photoprocessing operations?
HYes n No
If your answer is YES,
Are these procedures in writing? El Yes Q No
Are these procedures available at each photoprocessing work area?
EYes D No
Do the procedures include replenishment rates, wash water flow rates, and the use
of test strips?
EYes G No
Do the procedures include operation and maintenance of silver recovery
equipment?
QNo
Are your photoprocessors inspected regularly?
If your answer is YES, do the inspections include:
Equipment leaks?
Replenishment rates and wash water flow settings?
Chemical and washwater flows shut off when
processor is not being used?
Coven on photoprocessing chemicals containers
vhen not in use?
EYes
QYes
EYes
EYes
D No
D No
DNo
QNo
Have you installed squeegees to minimize carryover of one chemical solution to another
and from the fixer solution into the wash water? IvlYes n No
43
-------
Firm
he
n... 6/22/90
WMU MloininUoa AucMmtot
Proj. No.,
Prepared By • _ ^_
Cheeked By _
Sheet ___ of.__ Page __ of mm_
WORKSHEET
3
WASTE MINIMIZATION:
>r Operations
How are chemical replenishment rates set?
Use test strips'
Photoprocessor instructions
Chemical supplier recommendations
When are batch chemical solutions discarded?
When product quality degrades [
When production run is finished [
Other [
How are rinse water rates set?
Use test strips' u
Photoprocessor instructions U
Chemical supplier recommendations
How is rinse water used?
Once-through
Countercurrent
Recycled through clean-up system
Operator experience CH
Other
After a pre-set time Q
(e.g. weekly)
Other experience
Other
Still rinse
Flowing rinse
Are any chemicals recovered and reused? No
If so, describe which ones and how:
'Using test strips will minimize unnecessary additions and consequent discharges.
44
-------
Firm ^ Wtsu Minimization Assessment P
Sit* - C
n,,. 6/22/90 Proi. No. 5
WORKSHEET WASTE MINIMIZATION;
4 SHverRecowry
repared Bv
Sleeked Bv
beet of Pace of
Has the quantity of silver processed been determined? Q Yes SO No
If no, estimate the amount based on film processed using worksheets 6, 7, and 8.
Enter quantity processed TV™ n» /m*
Is silver now recovered from:
Developer solutions
Fixer solutions
Bleach or bleach-fix solutions
Rinsewater
Combined aqueous effluents
Silver-bearing solids (e.g. paper, film)
Quantity of silver recovered
D Yes Q No
Q Yes Q] No
(jg Yes Q No
Q Yes n No
Oil Yts D No
D Yes D3 No
Troy 02. /mo.
Trnv rvr /mn
Which silver recovery processes are used? On which streams?
Metal replacement (series cartridge) x
Electrolytic X
Rcrimiliting elertmtyrig
Batch electrolytic
Preopititmn
Ton exchange
Hybrid (two or more processes) X All JU,fiae±
i. Fix. Tfjtf pin W»«^|
45
-------
Firm
Ue
6/22/90
Wute MlaimixaUoa AiMumcot
Proj. No.,
Prepved By.
Cheeked By .
Sheet of
WORKSHEET
5
WASTE MINIMIZATION:
SfiYW Recowiy
METALLIC REPLACEMENT
Do you use silver test strips on the discharge water to make sure that the canister is
operating efficiently? (3 Yei n No
Do YOU change the canister immediately whenever the test strip shows silver in the
discharge? (gjYes
Do you inspect the canister system regularly for the following:
Leaks from the hose connection SI Yes
Plugging and channeling ££] yes
CD N
Do you make sure that your canister has a constant flow of solution running through
it (rather than intermittent dripping during operation)? 651 Yes Q No
ELECTROLYTIC RECOVERY
Do you check the current on the electrolytic unit(s) regularly (at least daily) to
ensure it is within the range specified by the manufacturer? CT Yes I I No
Do you check the unit(s) to ensure that agitation is adequate (the cathode or anode
is rotating, the solution pumps are working)? (££) Yea | | No
Is a filter used to remove dirt and other panicles from the fixer solution before it
enters the electrolytic unit? CT Yes I I No
Do you use silver test strips on the discharge water daily to make sure that the
electrolytic unit(s) is operating efficiently? ggj Yes I I No
46
-------
Finn .
Site - - -
n.,. 6/22/90
• Waste Minimization Assessment
Proj. No.
Prepared By _
Cheeked By
Sheet of Page _of
WORKSHEET
WASTE MINIMIZATION:
Black & White Prints
BLACK & WHITE PRINTS
Use this worksheet to estimate the amount of silver processed each month.
Size
in inches
21/4x3 1/4
21/2x3 1/2
31/4x4 1/4
31/2x31/2
3.1/2x41/2
# Prints
Per Month
Not Applicable
7x17
10x12
Sq. PL
Per Print
&}. ft
Per Month
Not Applicable
NOTE:
TOTAL
Standard sizes are noted by boxes, i.en 31/2x5
47
-------
Firm
pttr 6/22/90
Wuu MlolmiaUoa AjMumcat
Proj No
Prepared By'.
By.
Sheet of PǤe__of
WORKSHEET
WASTE MIMMIZATION:
COLOR PRINTS
Use this woricsheet to estimate me amount of silver processed each month.
Site * Prints Sq.FL
21/4x31/4
21/2x31/2
31/4x41/4
31/2x31/2
3.1/2x4
7x17
10x12
* Prints
Per Month
Sq.Ft
Per Month
iA9.nnr>
21,600
_moo_
x
X
X
X
X
X
X
X
X
X
X
X
X
0.0508
0.0959
0.0850
0.1094
0.1
0.531
0243
0.826
0.556
0.833
1.070
U
x 3.000
x
X
x 10.40
TOTAL
NOTE:
Standard sizes are noted by boxes, i.e.
3 1/2 « S
77
5,249
35,273
48
-------
Firm
Site
Date
.11 Waste Minimization Awssmeat
Proj. No..
Prepared By
Checked By ___________
Sheet of Page ;of
WORKSHEET
8
WASTE MINIMIZATION:
Recoverable Sliver
Source
Black & White Film
Color Film
Black & White Prints
Color Prints
VIotion Picture Film
Other
TOTAL
Processed
N/A
N/A
350
Recovery
Factor
0.8
1.0
0.5
1.0
N/A
49
-------
Firm WtiU Mlointatioa AiMSsaeat
*'• - -
Pirr V22/90 prpi Nfl
Prepared B
Checked Bj
Sheet o
WORKSHEET i •;, ', \VASTE SOURCES
9 •": . ,jr
1I/A««« O...._^.». lifa«*_l»1 U>_ Jll_^ _
waste source: Material Handling r
Ofrspec materials
Obsolete materials
Spills it leaks (liquids)
Spills (powders)
Empty container cleaning
Container disposal (metal)
Container disposal (paper)
Container disposal (plastic)
Pipeline/tank drainage
Evaporative losses
Other
Waste Source; Process Operations
Tank clcaniaf
Container clesaini
Process effloeat
Spent rtnscwattr
Filling equipment cleaning
Film reels, canisters, spools
Other
i
r
r Fife of
Significance at Plant
Low
XX
XX
XX
XX
XX
XX
XX
XX
XX
Medium
XX
High
XX
XX
XX
XX
XX
XX
50
-------
Finn Waste Minimization Assessment Prepared By
Sire Checked By
Date 6/22/90 _ Proj. No. Sheet of Ptge ^
WORKSHEET WASTE MINIMIZATION:
10 Material Handling
A. GENERAL HANDLING TECHNIQUES
Are all input materials tested for quality before being accepted from suppliers? Q Yes
Describe safeguards to prevent the use of materials that may generate off-spec produa:
S No
Is obsolete material returned to the supplier? £ Yes
Is inventory used in first-la, first-out order? £T yM
Is the inventory system computerized? r^ v
Does the current inventory control system adequately prevent waste generation? $& :,**
jDClYes
What information does the system track?
DNO
^No
Total amount used; Amount Per Order
Is there a format personnel training program on material *»•«"<'!"£. spill prevention, proper storage tech-
niques, and waste handling procedures? )£lYes F~ Vo
Does the program include information oo the safe handling of the types of drums, containers, aad packages
received? jGcTv** flNo
Are writteq procedures available and easily accessibk? ASJYcj f~~]No
How often is training given and by whom? Bi-Annual by Safety Coranittee Chairman
(' •' ~-~*) and Safety Committee member and load technician (
What spill containment methods an used? * chemical spill kit stands ready
chemicals are mixed and stored. This Kit include* Drot*rtiw» »r
(gloves, goggles, boots, respirator) Ditoes, Sand, Floor Scueeaies
where
51
-------
Firm __
S!f.
n... 6/22/90
WORKSHEET
11
E. DRUMS, CONTAINERS
Are drums, packages, aad contaii
Are employees trained in ways to
Are they properly trained in hand
Are stored items protected from
Describe h«n«Hmg procedures for
by our receiving pi
, , Waste Minimization Assessment Prepared By
Checked By
. p«*No Sheet of Page
of
; WASTE MINIMIZATION:
;, AND PACKAGES
ten impeded for damage before being accepted? &D Yes
safely handle the types of drums & packages received? BY«
ling of spilled raw materials? Fl Yes
damage, contamination, or exposure to heat, light and air? &L Ye*
damaged items: Damaged containers are not accep
J No
J No
No
J No
>ted
irsonnel. These containers are sent back to the
vendor via the delivery service.
Does the layout of the facility reaukia heavy traffic through the raw material storage area? Ovae
spilled materials to become dlspe
Caa traffic through the storage ai
To reduce the generation of empt
tempted to:
Purchase pre*mixed sdu
Plir^ttM* auihttiAtM MI mf
ned throughout the facility.) i— L,
ea be reduced? LJY*
[y containers aad liquid wastes due to their cleaning, has the facilii
tioas to minimize measu'i'ig, ^"'^"f. tp4 handling'' dYu
rurauuc ionuKMU IB rtc/^we* WMMMMM.I i| Ta
Other approaches (Diacribt ) nv«
Ditcuu the results of these tftea
no:
2 Ne
jaf
SNO
yu-
)2No
3 £ Ne
TjNe
An til taicfY btsBL MckiML aw
r/iMtmlA**! Sim hsjVSlfftfllMlfl WMtStfll
AT T rhamlrBla U^MJ ara
1 Describe method currently used to dispose of hazardous waste:
limiid. TTiasa confflin*1"* sr» fehornimhlv rina*<
hose that
i
vith water that is added to the mix. The containers are then cut to
prevent them being reused by others not aware of the contents.
52
-------
Firm
Site
n... 6/27/90
W»iste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of Page of ___
WORKSHEET
12
WASTE MINIMIZATION:
Material Handling
BULK LIQUIDS HANDLING
What safeguards are in place to prevent .spills and avoid ground contamination during the Tilling of storage
aaks?
High level shutdown/alarm* Q Secondary containment D
Flow totalizers with cutoff Q Other DC
describe the system:
Wet floor sensors vith audible alarm for spills or leaks as soon as
they occur.
Are air emissions from bulk chemical Morugv tanks controlled by means of:
Conservation vents r] Absorber/Condenser
Nitrogen blanketing Q Other vaptor lou control system
Describe the tviam:
Absorber D
Each 500 gallon tank has a tight fighting lid.
Are all storage tanks routinely monitored for leaks? If yes, describe procedure and monitoring frequency for
aboveground/vaulied tanks:
Yes. Each day chemical levels are checked and tanics are
12 inches to maka leak* obvious.
Jnderground tanks:
How are the liquids in these tanks dispensed to the users? (Le., in small containers or hard piped.)
All chaaic».l« are hardpiped directly to the processors.
Afe EF!* dea"cd ftfularty? Al*» discuss the way pipes arc cleaned and how the resulting waste is handled:
"pressure created bv gravity feed. Pip»a ara not
When a spill of liquid occurs in the facility, what cleanup methods are employed (e^ wet or dry)? Also
discuss the way in which the resulting wastes are handled: If a spill is snail; sand, a mop,
or vet vacum is used for pick-up. If spin is large; dikes are used to
contain spill, wet vacum is used to pick-up. All liquids are then diluted
10.1 •ilh aam aiul dlsuiidiyyd. • — :
53
-------
Firm
Site
Date 6/27/9°
Wiutlc Minimiivtioa A*M»mcBt
Pn«. Unit/Oner. _^__________
Proj. No.,
Prepared By _
Checked By
Sheet of Page of
WORKSHEET
13
OPTION GENERATION:
Material Handling
Meeting Format (e.g.. brainstorming. nominal group technique) Stall group discussions
Meeting Coordinator ^_______^_i__
Meeting Participants
Plant Manager
Currently
Suggested Waste Mlnlmltatlon Options | Done Y/N
Ratloaalt/Remarki on Option
General Handling Technique*
Quality Control Check
Return obsolete Material to Supplier
Minimi/c Inventory
Computerize Inventory
Formal Training
Recycle Film Reels. Canisters, and Spools
B.
Drums. Containers, and Packages
N
Will investigate options in futire.
Raw Material Inspection
N
Is not feasible at this tine.
Proper Storage/Handling
Pre-mixed Solutions
N
NA
Recycable Containers
N
Will contact vendor for inform
on.
Bulk Delivery
Waste Segregation
C.
Bulk Liquids Htndling
Hifh Level Shutdown/Alarm
Flow TotaltTCrs with Cutirif
Secondary
N
necessary in our set-up.
Air Emissions Comrttl
Leak Monuorine
Spilled Material Reuse
N
ive never tried. Contamination
Cleanup Methods to Promote Recycling
N
54
-------
Appendix B
Where to Get Help
Further Information on Pollution Prevention
Additional information on source reduction, reuse and
recycling approaches to pollution prevention is available in
EPA reports listed in this section, and through state programs
and regional EPA offices (listed below) that offer technical
and/or financial assistance in the areas of pollution prevention
and treatment
Waste exchanges have been established in some areas of
the U.S. to put waste generators in contact with potential users
of the waste. Twenty-four exchanges operating in the U.S. and
Canada are listed.
U.S. EPA Reports on Waste Minimization
Waste Minimization Opportunity Assessment Manual. EPA/
625/7-8«/003.***
Waste Minimization Audit Report: Case Studies of Corrosive
and Heavy Metal Waste Minimization Audit at a Specialty
Steel Manufacturing Complex. Executive Summary. NTIS
No. PB88 -107180*
Waste Minimization Audit Report: Case Studies of Minimiza-
tion of Solvent Waste for Parts Cleaning and from Electronic
Capacitor Manufacturing Operation. Executive Summary.
NTIS No. PB87 - 227013*
Waste Minimization Audit Report: Case Studies of Minimiza-
tion of Cyanide Wastes from Electroplating Operations. Ex-
ecutive Summary. NTIS No. PB87 -229662.*
Report to Congress: Was* Minimization, Vols. landE. EPA/530-
SW-86033 and -034 (Washington, D.C:US.EPA,1986)**.
Waste Minimization - Issues and Options, Vols. l-lll EPA/
530-SW-86-041 through -043. (Washington, D.C.:
U.S.EPA.1986**.
•Executive Smnnuiy available from EPA, WMDDRD, RREL. 26 W. Martin
Luther King Dr.. Ondntnti, OH 45268; fuO report available from the
National Technical Information Service (NTIS), US. Department of
Commerce. Springfield, VA 22161.
* •Available from the National Technical Information Service as a five-volume
set, NTIS no. PB87 -114 328.
*** Available from EPA ORD Pubucationf. CERL 26 W. Martin Luther King
Drive. Cincinnati, OH 45268; (513-569-7562).
The Guides to Pollution Prevention manuals*** describe
waste minimization options for specific industries. This is a
continuing series which currently includes the following tides:.
Guides to Pollution Prevention: Paint Manufacturing Indus-
try. EPA/625/7-90/005
Guides to Pollution Prevention: The Pesticide Formulating
Industry. EPA/625/7-90/004
Guides to Pollution Prevention: The Commercial Printing
Industry. EPA/625/7-90/008
Guides to Pollution Prevention: The Fabricated Metal Indus-
try. EPA/625/7-90/006
Guides to Pollution Prevention For Selected Hospital Waste
Streams. EPA/625/7-90/009
Guides to Pollution Prevention: Research and Educational
Institutions. EPA/625^7-90/010
Guides to Pollution Prevention: The Printed Circuit Board
Manufacturing Industry. EPA/625/7-90/007
Guides to Pollution Prevention: The Pharmaceutical Indus-
try. EPA/625/7-91/017
Guides to Pollution Prevention: The Fiberglass Reinforced
and Composite Plastic Industry. EPA/625/7-91/014
Guides to Pollution Prevention: The Automotive Repair In-
dustry. EPA/625/7-91/013
Guides to Pollution Prevention: The Automotive Refinishing
Industry. EPA/625/7-91/D16
Guides to Pollution Prevention: The Marine Repair Industry
EPA/625/7-91/015
U.S. EPA Pollution Prevention Information Clearing House
(PPIQ: Electronic Information Exchange System (EIES) -
User Guide, Version 1.1. EPA/600/9-89/086
55
-------
Waste Reduction Technical /Financial/
Assistance Programs
The EPA Pollution Prevention Information Clearinghouse
(PPIQ was established to help reduce industrial pollutants
through technology transfer, education, and public awareness.
PPIC collects and disseminates technical and other informa-
tion on pollution prevention through a telephone hotline and
an electronic information exchange network. Indexed bibliog-
raphies and abstracts of reports, publications, and case studies
about pollution prevention are available. PPIC also lists a
calendar of pertinent conferences and seminars; information
about activities abroad and a directory of waste exchanges. Its
Pollution Prevention Information Exchange System (PIES)
can be accessed electronically 24 hours a day without fees.
For more information contact:
PIES Technical Assistance
Science Applications International Corp.
8400 Westpark Drive
McLean, VA 22102
(703) 821-4800
or
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, D. C. 20460
Myles E. Morse
Office of Environmental Engineering
and Technology Demonstration
(202) 475-7161
Priscilla Flattery
Pollution Prevention Office
(202) 245-3557
The EPA's Office of Solid Waste and Emergency Re-
sponse has a telephone call-in service to answer questions
regarding RCRA and Superfund (CERCLA). The telephone
numbers are:
(800) 424-9346 (outside the District of Columbia)
(202) 382-3000 Cm the District of Columbia)
The following programs offer technical and/or financial
assistance for waste minimization and treatment.
Alabama
Hazardous Material Management and
Resources Recovery Program
University of Alabama
P.O. Box 6373
Tuscaloosa, AL 35487-6373
(205) 348-8401
Alaska
Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101
Anchorage, AK 99501
(907) 276-2864
Arkansas
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501) 371-1370
California
Alternative Technology Division
Toxic Substances Control Program
California State Department of Health Services
714/744 P Street
Sacramento, CA 94234-7320
(916) 324-1807
Connecticut
Connecticut Hazardous Waste Management Service
Suite 360
900 Asylum Avenue
Hartford, CT 06105
(203) 244-2007
Florida
Waste Reduction Assistance Program
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 488-0300
Georgia
Hazardous Waste Technical Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404) 894-3806
Environmental Protection Division
Georgia Department of Natural Resources
Floyd Towers East, Suite 1154
205 Butler Street
Atlanta, GA 30334
(404) 656-2833
Guam
Solid and Hazardous Waste Management Program
Guam Environmental Protection Agency
ITCE E. Harmon Plaza, Complex Unit D-107
130 Rojas Street
Harmon, Guam 96911
(671) 646-8863
56
-------
Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy and Natural Resources
1 East Hazdwood Dr.
Champaign, IL 61820
(217) 333-8940
Illinois Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Alumni Building, Room 102
Illinois Institute of Technology
3200 South Federal Street
Chicago, IL 60616
(313)567-3535
Indiana
Environmental Management and Education Program
Young Graduate House, Room 120
Purdue University
West Lafayette, IN 47907
(317)494-5036
Indiana Department of Environmental Management
Office of Technical Assistance P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317) 232-8172
Iowa
Center for Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames, IA 50011
(515) 294-3420
Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 50319-0034
(515) 281-8690
Kansas
Bureau of Waste Management
Department of Health and Environment
Forbesfield. Building 730
Topeka, KS 66620
(913) 269-1607
Kentucky
Division of Waste Management
Natural Resources and Environmental Protection Cabinet
18 Reilly Road
Frankfort, KY 40601
(502) 564-6716
Louisiana
Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804
(504) 342-1354
Maryland
Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200 A
Annapolis, MD 21401
(301) 974-3432
Maryland Environmental Service
2020 Industrial Drive
Annapolis, MD 21401
(301) 269-3291
(800) 492-9188 (in Maryland)
Massachusetts
Office of Technical Assistance
Executive Office of Environmental Affairs
100 Cambridge Street, Room 1094
Boston, MA 02202
(617) 727-3260
Source Reduction Program
Massachusetts Department of Environmental Protection
1 Winter Street
Boston, MA 02108
(617) 292-5982
Michigan
Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517) 373-0540
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612) 296-6300
Minnesota Technical Assistance Program
1313 5th Street S. E., Suite 207
Minneapolis, MN 55414
(612) 627-4555
(800) 247-0015 (in Minnesota)
Missouri
State Environmental Improvement and Energy
Resources Agency
P.O. Box 744
Jefferson City, MO 65102
(314) 751-4919
57
-------
New Hampshire
New Hampshire Department of Environmental Sciences
Waste Management Division
6HazenDrive
Concord, NH 03301-6509
(603) 271-2901
New Jersey
New Jersey Hazardous Waste Facilities
Siting Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609) 292-1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 292-8341
Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 984-6070)
New York
New York State Environmental Facilities Corporation
50 Wolf Road
Albany, NY 12205
(518) 457-3273
North Carolina
Pollution Prevention Pays Program
Department of Natural Resources and
Community Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919) 733-7015
Governor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020
Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Raleigh, NC 27602
(919) 733-2178
Ohio
Division of Solid and Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 WaterMark Drive
Columbus, OH 43266-1049
(614) 481-7200
Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus, OH 43266-0330
(614) 466-4286
Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
(503) 229-5913
Pennsylvania
Pennsylvania Technical Assistance Program
501 F. Orvis Keller Building
University Park, PA 16802
(814) 865-0427
Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
Bureau of Waste Management
Pennsylvania Department of Environmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust Streets
Hanisburg, PA 17120
(717) 787-6239
Rhode Island
Office of Environmental Coordination
Department of Environmental Management
83 Park Street
Providence, RI02903
(401) 277-3434
(800) 253-2674 (in Rhode Island only)
Ocean State Cleanup and Recycling Program
Rhode Island Department of Environmental Management
9 Hayes Street
Providence, RI 02908-5003
(401) 277-3434
(800) 253-2674 (in Rhode Island)
58
-------
Center for Environmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, RI02912
(401) 863-3449
Tennessee
Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxville,TN 37996
(615) 974-2456
Virginia
Office of Policy and Planning
Virginia Department of Waste Management
11th Floor, Monroe Building
101 North 14th Street
Richmond, VA 23219
(804) 225-2667
Washington
Hazardous Waste Section
Mail Stop PV-11
Washington Department of Ecology
Olympia, WA 98504-8711
(206) 459-6322
Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI53707
(608) 267-3763
Wyoming
Solid Waste Management Program
Wyoming Department of Environmental Quality
Herchler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
Wastes Exchanges
Alberta Waste Materials Exchange
Mr. William C. Kay
Alberta Research Council
Post Office Box 8330
Postal Station F
Edmonton, Alberta
CANADA T6H 5X2
(403)450-5408
British Columbia Waste Exchange
Ms. Judy Toth
2150 Maple Street
Vancouver, B.C.
CANADA V6J 3T3
(604) 731-7222
California Waste Exchange
Mr. Robert McCormick
Department of Health Services
Toxic Substances Control Program
Alternative Technology Division
Post Office Box 942732
Sacramento, CA 94234-7320
(916) 324-1807
Canadian Chemical Exchange*
Mr. Philippe LaRoche
P.O. Box 1135
Ste-Adele, Quebec
CANADA JORILO
(514)229-6511
Canadian Waste Materials Exchange
ORTECH International
Dr. Robert Laughlin
2395 Speakman Drive
Mississauga, Ontario
CANADA L5KIB3
(416) 822-4111 (Ext. 265)
FAX: (416) 823-1446
Enstar Corporation*
Mr. J.T. Engster
P.O. Box 189
Latham, NY 12110
(518) 785-0470
Great Lakes Regional Waste Exchange
400 Ann Street, N.W., Suite 201A
Grand Rapids, MI 49505
(616) 363-3262
Indiana Waste Exchange
Dr. Lynn A. Corson
Purdue University
School of Civil Engineering
Civil Engineering Building
West Lafayette, IN 47907
(317) 494-5036
Industrial Materials Exchange
Mr. Jerry Henderson
172 20th Avenue
Seattle, WA 98122
(206) 296-4633
FAX: (206) 296-0188
Industrial Materials Exchange Service
Ms. Diane Shockey
Post Office Box 19276
Springfield, IL 62794-9276
(217) 782-0450
FAX: (217) 524^193
•For Profit Wute Infotmttion Exchange.
59
-------
Industrial Waste Information Exchange
Mr. William E. Payne
New Jersey Chamber of Commerce
5 Commerce Street
Newark. NJ 07102
(201) 623-7070
Manitoba Waste Exchange
Mr. James Ferguson
c/b Biomass Energy Institute, Inc.
1329 Niakwa Road
Winnipeg, Manitoba
CANADA R2J 3T4
(204) 257-3891
Montana Industrial Waste Exchange
Mr. Don Ingles
Montana Chamber of Commerce
P.O. Box 1730
Helena, MT 59624
(406) 442-2405
New Hampshire Waste Exchange
Mr. Gary J. Olson
c/oNHRRA
P.O. Box 721
Concord, NH 03301
(603) 224-69%
Northeast Industrial Waste Exchange, Inc.
Mr. Lewis Cutler
90 Presidential Plaza, Suite 122
Syracuse, NY 13202
(315) 422-6572
FAX: (315) 422-9051
Ontario Waste Exchange
ORTECH International
Ms. Linda Varangu
2395 Speakman Drive
Mississauga, Ontario
CANADA L5K 1B3
(416) 822-4111 (ExL 512)
FAX: (416) 823-1446
Pacific Materials Exchange
Mr. BobSmee
South 3707 Godfrey Blvd.
Spokane, WA 99204
(509) 623-4244
Peel Regional Waste Exchange
Mr. Glen Milbury
Regional Municipality of Peel
10 Peel Center Drive
Brampton, Ontario
CANADA L6T4B9
(416) 791-9400
RENEW
Ms. Hope Castillo
Texas Water Commission
Post Office Box 13087
Austin, TX 78711-3087
(512) 463-7773
FAX: (512) 463-8317
San Francisco Waste Exchange
Ms. Portia Sinnott
2524 Benvenue #35
Berkeley, CA 94704
(415) 548-6659
Southeast Waste Exchange
Ms. Maxie L. May
Urban Institute
UNCC Station
Charlotte, NC 28223
(704) 547-2307
Southern Waste Information Exchange
Mr. Eugene B. Jones
Post Office Box 960
Tallahassee, FL 32302
(800) 441-SWK (7949)
(904) 644-5516
FAX: (904) 574-6704
Tennessee Waste Exchange
Ms. Patti Christian
226 Capital Blvd., Suite 800
Nashville, TN 37202
(615) 256-5141
FAX: (615) 256-6726
Wastelink, Division of Tencon, Inc.
Ms. Mary E. Matotke
140 Wooster Pike
Milford, OH 45150
(513) 248-0012
FAX: (513) 248-1094
U.S. EPA Regional Offices
Region 1 (VT, NH, ME, MA, CT, RI)
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3715
Region 2 (NY, NJ)
26 Federal Plaza
New York, NY 10278
(212) 264-2525
Region 3 (PA, DE, MD, WV, VA)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
60
-------
Region 4 (KY, TN, NC, SC, GA, FL, AL, MS)
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
Region 5 (WI, MN. MI. IL, IN, OH)
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
Region 6 (NM, OK. AR, LA, TX)
144S Ross Avenue
Dallas, TX 75202
(214) 655-6444
Region 7 (NE, KS, MO, IA)
756 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2800
Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303) 293-1603
Region 9 (CA, NV. AZ, HI)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305
Region 10 (AK, WA, OR. ID)
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5810
Industrial & Trade Associations
National Association of Photographic
Manufacturers, Inc.
550 Mamaroneck Avenue
Harrison, NY 10528
(914) 698-7603
61
. GOVERNMENT PRINTING OFFICE: 1997 - 650-001/80158
-------
-------
-------
United States
Environmental Protection Agency
Center for Environmental Research Information
Cincinnati, OH 45268
Please make all necessary changes on the below label,
detach or copy, and return to the address in the upper
left-hand corner.
If you do not wish to receive these reports CHECK HERE D;
detach, or copy this cover, and return to the address in the
upper left-hand corner.
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT No. G-35
Official Business
Penalty for Private Use
$300
EPA/625/7-91/012
------- |