Waste Reduction Guidebook
             for the
      Photofinishing Industry

   with a summary of Washington
    Dangerous Waste Regulations
             Sponsored By:
              II ! II II ( II I Illl I
              3 ( f I I I • f I I OF

              Presented By:
              Bellevue, WA
       Program Funded by a U.S. EPA RTTTA Grant

   REDUCING • •     $$
HAZARDOUS I •     $$
         WASTE II   3$$
    Waste Reduction Guidebook
               for the
      Photofinishing Industry

   with a summary of Washington
    Dangerous Waste Regulations
               Sponsored By:
               t1S * I I!!0 I ! 1 IIi
               0 I > I I I • i I t IF

               Presented By:
               BeUevue, WA

        Program Funded by a U.S. EPA RTTTA Grant

                        TABLE OP CONTENTS
Hazardous Waste Regulatory Summaiy                        1-1
Identifying Hazardous Wastes                               1-1
Photofinishing Wastes                                      1-3
Regulatory Status                                          1-6

The Photofinishing Industry and Waste Reduction
Background                                               2-1
Potential Hazardous Wastes Produced                        2-2
Waste Reduction Techniques                               2-3
Source Reduction  and Recycling-General Practices            2-4
Waste Reduction Opportunities                              2-9
     -Process Changes                                     2-9
     -Waste Water Reduction                               2 - 10
     -Silver Recovery                                      2-12
     -Bleach, Bleach-Fix and Fix Reuse                      2-17
     -Developer Reuse                                     2-21

Summary Table of Regulatory Requirements
References and Information Sources

   Summary of Washington Dangerous Waste Regulations
                for the Photofinishing Industry
The entire scope of handling hazardous waste, including generation,
storage, transportation, treatment and disposal, is  governed by state
and federal laws and regulations.

These  regulations provide for  managing, tracking,  regulating and
minimizing wastes.  They also include measures for proper training,
contingency  planning,   operating procedures,   and  protective
equipment to help ensure worker safety.

In Washington, you will be dealing primarily with the Department of
Ecology (Ecology).   Ecology is  responsible for developing the State
Dangerous Waste Regulations (Ch. 173 - 303 WAC). providing technical
assistance  to regulated  persons, conducting  inspections and
enforcement actions, and writing permits for facilities that treat, store
or dispose fTSD) of hazardous wastes.

Ecology must administer  the state program according to minimum
standards and expectations of the U.S.  Environmental Protection
Agency and the Resource Conservation Recovery Act (RCRA).

Complying with the  state  Dangerous Waste regulations  includes
following  Department  of Transportation  (DOT)  regulations  for
hazardous materials.  DOT regulations cover labeling, placarding and
other handling requirements, for the safe transportation of hazardous

Identifying and managing your wastes according to Ecology regulations
can be complex and confusing.  The following discussion is only a
summary of the Washington dangerous waste regulations. Contact your
regional Department of Ecology  office for a complete copy of the State
Dangerous Waste regulations. These regulations are often amended on
a yearly basis, so make sure you are working with the most current
Identifying Hazardous Wastes

Photofinishing businesses generate several different types of wastes.  It
is the responsibility of each  business to determine whether  their
waste is regulated as dangerous.  In general, a dangerous waste is any
discarded material which, if improperly disposed of, may pose a threat
to human health or the environment.  A waste is considered dangerous
by the state if it is specifically listed in the state regulations or

possesses one of the following characteristics that may be determined
by standard test procedures:
       • Ignitability

       • EP Toxicity

       • Corrosivity
       • Reactivity.
                       Liquids, solids or gases that burn or combust
                       at temperatures less than 140°F
                       Heavy metals and/or source pesticides can be
                       leached from the  waste
                       Wastes with high or low pH (>12.5, <2)
                       Wastes that chemically react with exposure to
                       air, water, heat, pressure or other materials.
                       Reactions can cause releases of toxic  gases,
                       explode or spontaneously ignite.

Tests should be  conducted if it is unclear whether or not a waste
meets any of the above characteristics or criteria.  A waste may also be
regulated as a dangerous waste  if it meets  any of the criteria for
designating the waste as toxic, persistent,  or carcinogenic.

Criteria for Identifying Hazardous Wastes

       • Toxic        -  A waste may qualify as "toxic" if exposure can
                       contribute  to  death, injury  or  illness of
                       humans  or  wildlife.   Tests  to  determine
                       toxlclty include  fish toxicity, orally  dosed
                       rats, inhalation by rats and the skin of rabbits.

       •Persistent   -  Persistent wastes include wastes  which
                       persist in the environment or bioaccumulate.
                       The  test  for persistence  applies  only to
                       halogenated  hydrocarbons (including many
                       solvents)  and  certain  polycyclic  aromatic
                       hydrocarbons (including many solvents).

       • Carcinogenic - If a waste contains one  or more substances
                       which are determined to  cause cancer  by the
                       International Agency for  Research on Cancer
                       or in other scientific documents, it may be a
                       carcinogenic waste under these regulations.
                       The waste is subject to the hazardous waste
                       regulations if it  is generated in quantities
                       over 220  pounds per month or batch  and if
                       the  concentration  of  the  carcinogenic
                       substance(s) is greater  than  0.01%  of the
                       waste.  (A waste is designated an Extremely
                       Hazardous Waste if the concentrations of the
                       carcinogenic substance is greater than

The  EP Toxicity  test will be  replaced  by the Toxic Characteristic
Leaching Procedure  (TCLP).  This change in  regulations will affect
small quantity generators beginning March, 1991.

Depending on the level of hazard posed, a waste may be designated as
a Dangerous Waste (DW) or an Extremely Hazardous Waste (EHW). The
latter  wastes are  regulated  more stringently.   Details on the
designation of DW and EHW can be found in the Washington Dangerous
Waste regulations or in the Guide for Hazardous Waste Generators (see
bibliography at the end of this handbook).
Photofinishing Wastes

Wastes produced from photographic processing vary with the type and
amount of film being processed and the type of processing being done.
The  types  of photographic  processing solutions  commonly  used
include activators,  fixers, developers,  various bleaches, hardeners,
monobaths, neutralizers. stabilizers, and stop baths.

Wastes generated from photographic processing Include wash waters
and processing solutions that need to be disposed periodically.  Wash
waters  usually  contain small  amounts of processing  solutions.
Processing solutions that may be disposed of as  waste Include spent
solutions and process tank overflows. Wastewaters may contain  some
of the process chemicals not used up  during processing, and small
amounts of chemicals  leached out of  the film and paper emulsion
during processing, such as silver thiosulfate complex.

The table below  provides information for classifying hazardous wastes
prior to off-site shipment.   The correct designation for a specific
waste should be verified with your transporter or the regional offices
of the federal Department of Transportation prior to completion of the
hazardous waste manifest. ITEMS LISTED ARE EXAMPLES ONLY, and
other DOT descriptions and identification codes may be  applicable in
some circumstances.

Wastes generated as a result of photoprocessing operations include:

     WASTE TYPE                               WASTE CODE

     • Heavy Metal Solutions

           -  photoprocessing wastes containing
             heavy metals
             •  cadium                               D006,
             •  chromium                            D007,
             •  lead                                 D008, or
             •  silver                                DO 11

     • Cyanide bearing solutions                       D003
Generators of waste should be careful not to pour liquid hazardous
waste down the drain which  may lead directly to a waterbody, or
dispose of solid hazardous waste in the dumpster.

Process Wastewaters

The  discharge of photofinishlng wastewater to the sanitary sewer
system is a commonly employed practice and currently acceptable
method of waste disposal.  Such discharges however, are subject to
local restrictions and limitations.   As long as  the  photofinishing
wastewaters are discharged to the sanitary sewer system along with
domestic sewage, the wastewater is not subject to state hazardous
waste regulations, even if the wastewaters  are classified as hazardous
wastes.  This is because of an exemption  for process wastewaters in
the state regulations. However, other hazardous substances may not be
added to the wastewaters, and a permit for such discharges is often
required  from the  local sanitary sewer  municipality.   If process
wastewaters are not discharged along with domestic sewage, then the
domestic sewage exemption does not apply and the wastewaters may
be subject to state regulations.   Photofinishers intending to discharge
process wastewaters to the  sanitary sewer system should consult with
local authorities to determine whether this exemption is applicable to
the specific operations of their  facility.

NOTE:  In  September  1990,  Ecology will propose a new rule to
tighten the  exemption for discharges of dangerous wastes to sewer
systems.  When ado^d, this new  rule will require  dischargers to
eliminate  hazardous  constituents  or treat  wastewaters  to
concentrations below thresholds for designation as dangerous waste.

In general, there may be local discharge limitations established for a
number of wastewater parameters, and  those which apply  to the
photofinishlng Industry include  pH.  temperature, and  heavy  metals.

Wastewaters  that  do  not  meet  discharge limits  may  require
pretreatment  for the  removal of  the problem  constituent(s).
Businesses intending to discharge process wastewaters to the  sanitary
sewer system should check with their local municipality to determine
what  discharge restrictions or  limitations apply and if a discharge
permit is required.

In areas not  serviced by  a  municipal sanitary sewer system and
treatment facility, other wastewater  management alternatives need to
be considered, such as  a contracted waste pick-up and disposal
service.  When using this alternative, photoprocessing businesses
should be  careful  to keep potentially  hazardous wastewaters
segregated from the  non-hazardous wastewaters.  Mixing hazardous
and non-hazardous wastewaters may result in a mixture that is also a
hazardous waste.  Keeping these wastewaters separated will reduce
the total amount of hazardous waste generated and thus minimize the
resources  and  problems associated with the management of hazardous

Process wastewater discharges to a surface water, such as directly to a
lake or stream, or to a storm sewer, are subject to the Federal Clean
Water Act,  and  require an  NPDES  (National Pollution Discharge
Elimination System) discharge permit.   The act places  restrictions
and  limitations  on  specific wastewater parameters that  can  be
discharged. To meet discharge  limitations,  the process wastewaters
must generally be extensively  treated on-site  prior  to discharge.
Wastewaters containing hazardous  wastes cannot be  discharged to
surface waters.


The containers in which photoprocessing chemicals  are kept may be
considered hazardous waste unless they are being recycled, reused or
are  legally empty.    The EPA waste code  and  corresponding
characteristics assigned  containers depends on what has  been in
them.  The definition of "empty" according to regulations is as  follows:

• All  wastes have been removed that practically can be  removed by
  methods of pouring, pumping, etc.. and

• No  more than 1  inch  of residue  remains on  the bottom of a
  container, or

• No  more than 3% by weight of the total container  capacity remains
  in a container equal to or smaller than 110  gallons, or

• No  more than 0.3% by weight of total container capacity remains for
  a container larger than 110 gallons.

  For a container which has held acutely hazardous wastes, must be
  triple rinsed before it is considered legally empty.
Regulatory Status

The more waste produced and/or accumulated by an photofinishing
lab,  the more  regulatory requirements  there  are to meet.  Each
company must  comply with the requirements set for their generator
category.   Hazardous waste generators  are allowed  to temporarily
accumulate hazardous waste  on  site without  a storage permit.
However,  accumulation time and quantity vary depending on the
company's generator status as described below:

Fully Regulated Generators
Generate  or  accumulate 2,200 Ibs.  (approximately  five  55 gallon
drums)  or  more of dangerous waste,  or  2.2 Ibs.  or more  of acutely
hazardous waste per month.

220-2200 Pound Generators
Generates between  220 Ibs. (approximately one 55 gallon drum)  and
2,200 Ibs. of dangerous waste per month and never accumulates more
than 2,200 Ibs. at any time.

Small Quantity Generators
Generates less than 220 Ibs. of dangerous waste and less than 2.2 Ibs.
of acutely hazardous waste  per month and never accumulates more
than 2,200 Ibs. of hazardous waste  .....* 2.2 Ibs. of acutely  hazardous
waste at any time.

Generators under the quantity exclusion  limits must make sure that

   -   know what kinds of wastes they produce (i.e. is it dangerous)
   -   treats or disposes of waste on-site, or,
   -   ships wastes off-site to a permitted TSD. legitimate recycler, or
      a  facility  permitted  to manage solid wastes  (e.g. solid  waste

If any one of these  conditions are not met. then the generator is fully
regulated under dangerous waste regulations

If a non-dangerous substance is mixed with a  listed or characteristic
dangerous waste, it may result in the entire mixture being regulated as
a dangerous waste. Additionally, if two non-dangerous waste streams
are  mixed, the resulting  mixture could demonstrate dangerous
characteristics and therefore be deemed dangerous waste.   The
addition of these mixtures to a generator's dangerous waste stream
could result in the generator losing small quantity generator or 220-

2200 pound generator status, and thus be subject to the requirements
of fully regulated generators.

NOTE:  In September 1990, Ecology will propose a new rule changing
the conditional exemption for sending small quantity wastes to a solid
waste facility.  The proposed rule will require that wastes be managed
according to a locally adopted moderate-risk waste plan.

An  outline of  the Dangerous Waste Generator Requirements of each
generator category is attached.

                 The Photofinishing Industry

This summary will begin with a brief background of the photoflnishlng
industry. Hazardous wastes which may potentially be produced during
the  photofinishing   process will  be discussed.   General waste
reduction and recycling techniques will be described in the next
section.  Beginning with the "Waste  Reduction Opportunities"  section,
specific waste reduction opportunities  will be  presented.   These
include process changes, water conservation, silver recovery, and the
reuse of bleach, bleach-fix, and fix.

The  information presented in this summary was taken in part from
the following documents: Profit from Pollution Prevention and Waste
Audit Study/Photoprocessing Industry. Refer to the references for a
complete bibliography. We extend our thanks to the authors for the
use of their materials.


The  photographic processing industry includes businesses  processing
color print films  and paper, color slide  films,  color movie film and
black  and  white film.   Typically,  only  10% of  a commercial
photoprocessor's business involves black and white processing. While
other users  of photography, such as hospitals processing x-ray films
and  printing plants processing graphic arts films, are not  considered
part of the photofinishing industry, many of the waste reduction
strategies discussed in this guidebook are  applicable for these users.

Processing photographic film and  paper requires the use of a number
of chemicals  and  lab  setups  to  develop  and produce finished
photographic  goods.  Process chemicals may include developers,
bleaches, fixing  agents  (fixer)  and  stabilizers.   Waste streams
generated vary widely according to the type and volume of processing,
but may include ferrocyanide. silver, cadmium, chromium, ammonium
salts, trisodium phosphate, sodium nitrate, and formaldehyde.

In 1962, the price of silver was $.90 per Troy ounce.   In 1967, the
United  States government  removed its price  restraints  on silver,
permitting silver prices to respond to market demand and speculative
buying; one year later, silver prices had doubled and  many of the
photographic processing labs not already reclaiming silver were well
into recovering silver from their  process wastewaters.  Today  silver
prices are averaging  $5 - $6 per ounce but have been as high as $40
per ounce in 1980.

The  escalation in silver  prices did  much to steer the film industry
along a course of pollution prevention.  Along with the knowledge that
silver  recovery brought  higher  profits came the awareness that
recycling process chemicals and washwaters  could heighten  profit

margins even more.  For example, desilvering of spent fix solutions
meant that recovered fix could be reused to replenish process fix.

More  than  a decade  of active research in maximizing waste reuse in
photofinishing has resulted in the availability of a growing selection of
recovery equipment and retrofit design  options.   Commercially
available equipment is capable not only of recovering silver, but also of
regenerating spent fix, bleach, bleach-fix and developer process baths
using individual  closed-loop systems.  However, the use of recycling
technology in   photographic  processing  does  require care  in
monitoring to guarantee consistent product quality.

Refinement  in  reuse  technology   allows  many  of the   dilute
contaminants in waste rinsewaters presently discharged to  sewers to
be recovered economically by medium-sized businesses.  Future
technology developments may see further scaling down of  equipment
to be economically  attractive to even very small photoprocessing

Most small to mid-sized photolabs are located in areas serviced by a
public sewer, and photoprocessing wastes are discharged to the sewer
along  with  sanitary wastes.    Local authorities  regulate  the
concentration of sewered chemicals.   Photolabs usually do  not
generate large quantities of non-sewered hazardous waste.

Film Processing Wastewaters
Several  types of processing chemicals are used in developing films.
These processing chemicals include developers, fixers, stabilizers,  and
activators.   Some film processing solutions may be classified as
corrosive due to pH values, such as dichromate bleaches, which have a
pH less  than 1.0.    Silver,  chromium and  cyanides  (found in
ferrocyanide  and ferricyanide  bleaches)  may also be  found in  film
processing wastewaters.

Wastewaters  may contain small amounts of processing  chemicals not
used up during processing, trace amounts of chemicals  such as silver
thiosulfate complex, leached out of the film and paper emulsion during
processing,  and process  tank overflows.   Many of the  chemicals
present  in  photographic  processing waste streams are readily
biodegradable, however some are  not.   Listed below  are  three
categories of biodegradability and the  process chemicals that fall
within each.

•  Rapid  Biodegradation - acetate, benzyl  alcohol,  hydroquinone,
   sulfite, thiosuifate.

 •  Slow Biodegradatian - developing agents, citric acid, ammonium
   salts, glycols, hydroxylamine sulfate, formalin, formic acid.

 •  No Btodegradation  -  phosphate, bromide,  ferrocyanide, borate,

 Sludges may be produced as a result of the treatment of spent rinse
 waters. Sludges may also result from the supersaturatlon of dissolved
 metals  (silver) and chemicals in  rinse baths which settle out in the
 bottom of tanks.  In  addition to heavy  metals, process  chemical
 residues, sludges contain significant amounts (over 95%)  of water.
 Removing excess water from these sludges will result in a significant
 volume reduction of the material that must be disposed.  Several
 methods are available for accomplishing volume reduction,  including
 the use of centrifuges, vacuum filters, and filter presses.

 Empty product containers and drums may contain residual processing
 chemicals.  Legally empty containers (see definition of "empty" in the
 Regulatory  Summary)  do not constitute  hazardous  waste.   Many
 vendors will accept emptied containers  back for refill and containers
 recycled in this manner are not regulated as hazardous wastes.  If the
 containers have been adequately rinsed, they may be disposed of at a
 licensed sanitary landfill.  You must check with  local authorities for
 specified restrictions.

 Film Negatives and Transfer Papers
These materials may contain significant  amounts of recoverable silver.
 Many of the contract services that pick up reclaimed silver from on-
 site silver recovery systems will also collect film negatives and transfer


Minimizing  the   production   of  hazardous   wastes   in  your
photoprocessing business makes sense because it can help you to:

• reduce operating costs by using less raw materials;

• improve workplace health and safety;

• reduce your regulatory requirem<	„ saving time and money;

• reduce the liabilities associated with the management of hazardous
 waste; and

• reduce potential damage to the environment.

Federal and state regulations require that hazardous waste generators
must manage  their wastes  in accordance  with the  appropriate
hazardous waste  regulations.   Generators  of 220  Ibs/month (or 2.2
Ibs/month of acutely hazardous waste) must certify that they have a
program in place to minimize the volume and/or toxicity of hazardous
wastes.  The EPA defines waste minimization as both source reduction
and recycling.

Source Reduction
Source  reduction includes  good housekeeping techniques,  raw
material  substitution, and changes in processes  which reduce the
amount of hazardous wastes produced at the source of generation. For
example, using film with less or no silver reduces silver content in
process waste streams.

This includes the recovery and reuse of hazardous  wastes such as
spent photoprocessing chemicals.  Photoprocesslng chemicals can be
renewed by using replenishment concentrate and regenerators.  Silver
can also be recovered from photographic wastes.

There are many  ways to reduce the  amount  of hazardous waste
produced  in your photofinishing  business without  buying  new
equipment.   Improved "housekeeping" practices can minimize the
chance of material losses.  They can be  as  simple as keeping good
records of hazardous materials purchased to  avoid overstocking or as
complex as changing management's perspective on the substitution of
raw materials which are less hazardous. However, these changes can
affect the  amount of hazardous waste  leaving your operation which
generally means a cost savings for the business.

Source reduction and recycling practices include:

        1. Management Initiative
        2. Employee Training
        3. Good Housekeeping Practices
        4. Proper Material Handling and Storage
        5. Process and Equipment Modification
        6. Raw Materials Substitution
        7. Waste Stream Segregation
        8. Use of Waste Exchanges

Discussion of each  of  these  practices follow.   For more  detailed
information on  waste reduction techniques, refer to the section
entitled "Waste Reduction Opportunities".

1.   Management Initiative

Management support is critical to any waste reduction program.  If
there is not enough visible support from management, employees will
see little incentive to look for waste reduction opportunities and the
waste  reduction  program will  not be as  effective as  it could be.
Employee incentive  programs such as awards for waste reduction
ideas can help foster awareness of waste reduction policies, goals, and

2.   Employee Training

Employee training is an important part  of your waste reduction
program.  The personnel responsible for operating and monitoring
equipment, loading and unloading hazardous materials and purchasing,
storing and transferring  chemicals should be trained in safe operating
procedures, including the handling of hazardous  wastes and proper
equipment use.

Employees should be made aware of the hazards of the materials they
will work with by reviewing the Material Safety Data Sheet (MSDS)
prepared for each chemical and  through training required under
federal and state occupational safety and  health  regulations.  This
awareness will  help  identify their personal   responsibility in
maintaining safe practices  which help minimize hazardous waste

Employees should be cautioned not to accept a sample product from a
vendor (e.g., a new film  or photoprocessing chemical) because it may
become  a  hazardous waste when  discarded or  may generate  a
hazardous waste if used. Employees should be trained to read the label
and MSDS and understand what is in the product and how to use it.
The selection process should  have worker safety as a top priority.

3.   Good Housekeeping

The following suggestions may be applicable to your shop.

     • Keep lids on containers to reduce  evaporation and chance of

     • Label all containers with contents and use information;

     • Conduct regular waste audits;

     • Monitor content of chemical baths and wastes produced;

     • Monitor amounts of chemicals used to reduce overages;

     • Maintain Material Safety Data Sheets to identify the chemical
       Ingredients of waste  products;

     • Improve water use efficiency.

An important part of good housekeeping is a maintenance program.
Whether preventive,  corrective, or both,  a maintenance program can
help cut costs of repairs, waste disposal resulting from leaks and spills
and reduce business  interruptions.

4.   Proper Material Handling and Storage

Store Materials Properly
Many photoprocessing  chemicals are sensitive  to temperature  and
light. Photosensitive film and paper storage areas should be designed
for economical  and efficient use.  Chemical  containers  list the
recommended storage conditions, and meeting these conditions will
increase shelf life.

Control Inventory
Inventories should be kept using the "first-in, first-out" practice.  This
will reduce the possibility of expired shelf life, but this practice may
not work for specialty materials that are  seldom used.   Use of a
computerized inventory system can help  track the amounts and ages
of raw materials.

Purchase Quantities According to Needs
Raw material order  quantities should be matched to usage.  Small
photoprocessors should order process chemicals  in small containers
according to use.  Large photoprocessors  should order materials in
large containers, which may be returnable, thereby  eliminating or
reducing the need to clean  them.  Ordering materials in returnable
tote bins may maximize these advantages.

Test Expired Material for Usefuln
Materials having expired shelf-life should not automatically be thrown
out. Instead, test such materials for effectiveness.  The material may
be usable, rather than becoming a waste.

Minimize Spills and Leaks
Spilling and leaking of hazardous substances can create  hazardous
wastes which must be properly managed. If the material used in the
clean up,  such as water or absorbent, is contaminated with the
hazardous substance, it must be discarded as a hazardous waste. Quick
response  to a spill  can  minimize the amount of spill  material,

Including any contaminated soil or water.  Therefore,  spill and leak
prevention  are  important ways  of reducing your  hazardous waste

5.   Process and Equipment Modification

Presented here is only a summary list.  Many of these techniques are
discussed in greater detail in the "Waste Reduction Opportunities,
Process Changes" section of this summary.

Modifying or modernizing lab  equipment and making processes
throughout your shop more efficient  can help reduce the amount of
wastes generated and raw materials used.

     • Reduce  wastewater volumes by using a washless processing

     • Use a closed cycle system to enhance silver recovery;

     • Recycle  wastewater:

     • Use non-absorbent "twin check" tabs to reduce  the amount of
       chemicals carried over from one bath to another;

     • Use counter-current  wash  systems  to control  cross

     • Use water demand zone valves to control water use;

     • Use  two chemical recovery cartridges in series to maximize
       silver recovery;

     • Use floating lids on bleach and developer containers to retard

     • Squeegee  chemicals   from  films   to   minimize  cross

     • Renew  photoprocessing chemicals by use  of replenisher
       concentrates  and regenerators.

6.    Material Substitution

One way to reduce waste generation is to use less toxic raw materials
or products  which  reduce waste generated.   There are limited
opportunities for this type of waste reduction in photoprocessing. and
alternate materials may be unavailable,  more expensive,  or  have
undesirable effects on  product quality.  However, there are product
substitutions that have proven successful. For example:

     • Use Jttm with less or no silver (films containing bismuth have
       been used success/ally in applications such as black and white
       graphic arts processes and x-ray JUm); and

     •Replace  Jerricyanide   bleach   with  ferric  EDTA
       (ethylenedtamtnetetraacetic  acid)  complex which is less  toxic.
       (Note:  mixing from scratch can be  hazardous to the chemical

7.    Waste Stream Segregation

It  is important not to mix different waste streams.   Once a  non-
hazardous waste is contaminated with a hazardous waste listed in the
regulations,  the entire waste  stream becomes a "listed"  hazardous
waste and must be managed as such.  Mixing of two  non-hazardous
wastes  could  result in  the formation  of a waste that  exhibits a
hazardous characteristic.  In addition, mixing wastes can increase the
volume of hazardous waste you generate  and potentially increase your
regulatory requirements for the managements of these wastes.

8.    Waste Exchanges

Waste exchanges or materials exchanges  provide another management
alternative.  Materials  exchanges  are organizations that manage or
arrange the transfer of wastes between businesses,  such that one
producer's waste materials or  feedstock  might be another business's

For a copy of the latest catalogues, contact:

     PME      Pacific Materials Exchange
                S. 3707 Godfrey Blvd.
                Spokane, WA 98204
                Bob Smee (509)  623-4244

     IMEX      Industrial Materials Exchange
                172 20th Ave.
                Seattle, WA
                (206)  296-4899

As an example of the value of these exchanges, a major film processing
lab in Seattle was able to use the Industrial Materials Exchange to
recycle both  unused  chemicals and empty containers,  avoiding
expensive disposal fees.

Process Changes

Process modification techniques are designed to use materials more
efficiently, reducing the generation of waste.  However, because much
of the photoprocessing  equipment is integrated, and each process
step is part of an overall unit, it may be difficult for a photolab operator
to modify equipment and improve material use.  Additionally, major
modifications must either originate with the equipment manufacturer
or result from  the strong commitment, and often expertise, of the
owner/operator to invest in a costly retrofit of existing equipment.

Despite such barriers, a number of techniques can be applied to both
manual  and automated  photoprocessing  operations  to  enhance
materials use and minimize waste generation.  These practices may
include process adjustments and  installation  of low  cost,  waste
reduction devices compatible with existing equipment.  Examples are:

•     Reuse Solutions
      When using  a tray method, solutions can be reused until test
      strips indicate they are chemically exhausted.

•     Cover Tanks
      When not in use, tanks  should be kept covered to  reduce
      contamination, evaporation, and oxidation.  Oxidations  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.

•     Use Cylinders
      Additional chemical savings  can be realized by changing the
      shape of the  container.  A cylinder can achieve higher  efficiency
      than a rectangular tank, due to smaller container volume and
      surface area, and the ability to evenly distribute solutions by
      rolling the tube.

•     Replenish Carefully
      Photoflnishers demand  a  high quality product, and there is a
      tendency by  some to over-compensate by using  more chemicals
      in the process than are necessary. This overcompensation often
      results in an Increase in the strength of the waste stream and
      higher chemical  expenditures.   The careful addition and
      monitoring of chemical replenishers  to process baths will save

     money In the long term by reducing total chemical costs.  The
     use of replenishment gauges can help ensure that the chemical
     make-up of process baths is optimum, in addition to minimizing
     unnecessary chemical losses to the sewer.

     Use Squeegees
     Squeegees reduce chemical carry-over on film and paper moving
     from  one  process to  the  next  by removing  excess liquid.
     Squeegees typically reduce chemical carry-over by 50%.   By
     minimizing chemical contamination of process baths, the total
     quantity of replenisher chemicals required is drastically reduced
     and the lifetimes of process baths are increased.  This reduces
     the frequency of process bath dumps and the total quantity of
     wastewater discharge.  It is best to place squeegees at the exit
     points  of each  different process  bath for all continuous

     The earliest form of wiper-blade squeegee was a  rubber blade
     which deteriorated quickly with  chemical  contact.   Regular
     inspection of squeegee equipment should be part of a normal
     maintenance program.   Newer polyurethane blades  are more
     resistant  to chemical  deterioration and may be preferable  to
     traditional rubber.  Other squeegee types are available and should
     be examined as possible improvement to an existing system.  You
     need  to  choose what works best for your  specific  processes.
     Listed below are a few of the squeegee types available.

     •     Air-knife

     •     Venturi

     •     Rotary Buffer

     •     Polyurethane Blade

     •     Belt turn-around  and soft-core roller
Wastewater Reduction

The  costs of wastewater treatment can be significant.   Options for
reducing the need to treat wastewater include water conservation and
counter current rinsing.  The goal here is to  avoid the discharge of
valuable residues and process water. A good place to start looking at
your opportunities  is  with an inventory of  all the  sources  of
wastewater.  Major sources include:

      •   Rinsewater is the major component of the wastewater stream.
         Rinsing is necessary to remove excess process solution.

     •  Spills, drips, leaks and clean-up wastes taken as a composite
        can be significant.

     •  Other  large  scale  accidental  losses  are  not  usually
        accommodated and  can be expensive due to the loss of
        process  chemicals.

1.   Water Conservation
Water consumption can be reduced by shutting off the water when film
is not  being processed.  Also, a solenoid valve can be Installed to
automatically reduce water flow when film processing stops.

It is not uncommon for a photofinishing lab to have a rinse system
which  is overdesigned for some uses.  A close examination of your
specific processes may reveal an opportunity to reduce   the total
volume of washwater used without impairing photo or film quality.

Water   savings   may  be realized  through simple  equipment
readjustments.   For  example,  one company halved  their  water
consumption in  one year by  attending to leaks and running hoses,
cutting stand-by flows to a minimum,  adjusting control valves that
were found  to be over  specification, and encouraging employees in
"water  awareness".  The company also recycled water from the final
wash to supply the stop wash.

Improving water  use efficiency is a low-cost investment that can yield
considerable savings.  Because washing of photographic material is a
principle use of water in the photofinishing industry, more efficient
rinse techniques will greatly  reduce the  total  volume of wastewater
that is treated on-site or discharged to the sewer system.  As water is
reduced, however, the percentage of wastes may Increase to problem

2.   Counter-Current Rinsing
The counter-current  system  is an  important  waste  reduction
technique.  It is preferable because it uses much less water than its
parallel tank counterpart.  Rinsing  (also  referred to as washing) has
two major functions in the photofinishing process:  reduce processing
solution contamination  and ensure long-term  stability of the
photographic image.

In a parallel system, fresh water enters each wash tank and effluent
flows out of each tank.  Counter-current washing utilizes  a system
where  fresh water enters only the  final wash tank near the exiting
film. Each of the wash tanks overflows into the preceding tank, with
effluent leaving only the first tank near the entering film.

Conversion of an existing wash system to a counter-current system,
where  space permits, will pay off because of reduced water use and

costs.  For example, a two-stage counter-current system can be one
hundred times more efficient when compared to washing in a single
deep tank with the same total volume of washwater.
Silver Recovery

There are several sources of recoverable silver from the photofinishing
process:  photoprocessing solutions, spent rinse water, and scraps of
film and printing paper.  The  silver in these materials  can exist as
insoluble silver halide, soluble silver thiosulfate complex,  silver ion, or
silver precipitate depending on the type of process and the stage in
the process from which the silver is being recovered.

The fix stage is the most economical  source for silver recovery.  As
much  as 80%  of  the total silver  processed for black  and white
positives and close to 100% for  color work will end up in the fixer
solution.  Color films yield 3 to 4 times as much recoverable silver in
process baths as do black and white films.

Rinse water following the fixer or bleach-fix will also contain silver due
to carry-over.   Because the silver content  of rinse waters is  fairly
dilute, large amounts of this effluent  may be needed to make  silver
recovery  economical.

Improved recovery processes have given small photo processing labs
the  possibilities of economically recapturing their silver. The five
basic methods  used  for silver recovery are metallic replacement,
electrolytic recovery,  chemical precipitation,  ion exchange  and
reverse osmosis. Ion exchange and reverse osmosis are  most often
used for silver  recovery from rinsewaters.  Which system you choose
depends on the size of your business.

1.   Metallic Replacement
Metallic replacement occurs when a metal such as iron contacts with a
solution containing  dissolved ions of a less active metal such as silver.
The dissolved silver, present as a thiosulfate complex, reacts with  the
iron and settles out as a sludge.

Although silver ions  will displace many of the common metals from
their solid state, iron in the form of steel wool is preferred because of
its  convenience and  economy.   Zinc and aluminum are effective as
replacement metals, however zinc is shunned because of its  relative
toxicity and greater cost; while aluminum is avoided because of  the
simultaneous generation of hydrogen gas, which can be explosive.

The pH of the solution passing through the metallic replacement unit
should be between  4 and 6.5.  The optimum is between 5  and 5.5 for
the most  effective operation  of the  unit.   Below a pH of 4,  the

dissolution  of the  steel wool is too rapid; above a pH  of 6.5, the
replacement reaction may be so slow that silver removal is incomplete.

Commercially available units consist of a steel wool-filled  plastic
canister with needed plumbing.   Waste fixer is  fed to two or  more
canisters in series or series-parallel combinations. For two canisters
used in series, the first canister removes the bulk  of the silver and the
second polishes the effluent of the first.  Silver concentration in the
effluent from a single canister averages 40 to 100 milligrams per liter
(mg/L), over the life of the system. If two canisters are used in series,
the silver concentration drops to a range of 0.1 to 50  mg/L.  The
second canister is also a safety factor if the first unit is overused.  Over
the life of the canister, the average iron concentration in the effluent
is  4,000 mg/L.  Because of this iron contamination, the desilvered
fixer cannot be recycled, until an economical iron  removal process can
be developed.

2.     Electrolytic Recovery
Electrolytic recovery  may be the  most promising  silver recovery
technique for even  small photoflnishing labs.  During the electrolytic
recovery process,  a  controlled  direct  electrical current  is passed
between  two electrodes (a cathode(+) and an anode (-)) which are
suspended  in the  silver-bearing solution.   Silver  deposits on the
cathode in the form of silver plate with a purity of dose to 99%. The
cathode is removed periodically and  the silver stripped  off.  Lower
levels of purity usually result from tailing unit applications due to the
lower concentration of silver in the influent solution.

Care  must  be taken  to  control current  density in the  cell.   High
density can cause  "sulfiding", the decomposition of thiosulfate into
sulfur at  the cathode,  which contaminates the deposited silver and
reduces recovery efficiency.  The higher  the  silver concentration in
the solution, the higher the current  density can  be without the
occurrence  of sulfiding; therefore,  as the  silver is plated  out of
solution, the current density must be reduced.

An electrolytic unit can be used for a primary or tailing waste stream,
and can be batch or continuous.  Batch and continuous applications of
electrolytic recovery  units  are discussed  below.   Recirculating
electrolytic recovery is also discussed below.

•     Batch Electrolytic Recovery

      In batch recovery, overflow fixer from one or more process lines
      are  collected in a tank. When sufficient volume is reached, the
      waste fixer is pumped to  an electrolytic cell for silver removal.
      Once desilvered, the fixer can usually be discharged to the sewer
      system, disposed of as solid waste, or reused. If the fixer is to be
      reused, it is transferred to a mix tank where sodium thiosulfate

and  potassium  chrome  alum are  added  to  bring  it  to
replenishment strength.

Primary batch system cells are usually designed to desilver the
fixing bath with initial silver concentrations of about 5,000 mg/L.
Silver concentration in the effluent is typically 200-500 mg/L.
Effluent  with a silver  concentration of 20-50 mg/L can  be
achieved with additional treatment time and careful current
density control.

Continuous Electrolytic Recovery

Electrolytic  recovery units are  also  capable of treating  the
overflow  fixer stream  continuously.   The  volume of  the
electrolytic unit must be large enough relative to  the  incoming
flow volume  to ensure  adequate treatment  time  for the fixer.
This can be achieved with two or more  units placed in series,
with the  continuous flow of incoming fixer supplying a constant
quantity of silver for recovery.  As  a result, the  units can be
operated at a relatively stable current density and can be  an
automatic system.  Some units are available that can sense silver
concentration in  solution  and  adjust  current  densities
accordingly.  Continuous flow units usually discharge desilvered
fixer directly to the sewer system.

Recirculating Electrolytic Recovery

Silver  can also be  removed  from in-use fixer solution by a
continuously recirculatlng system.  With this system, the silver is
removed at approximately the  same  rate it is added by the
processing of film.   The recovery cell is connected "in-line" as
part of the recirculating system.  This  technique of continual
removal has the 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.
Recirculating  electrolytic  recovery  has  the  capability  of
maintaining silver concentration in the fixer in the range of 500
to 1,000 mg/L, depending upon the flow  rate and hydraulic
capacity of the system.

Once installed, the unit may be fully automatic with little daily
maintenance required. By sensing the flow of fixer through the
electrolytic cells (which  themselves contain no moving parts),
the unit turns itself on.  Solution is circulated by the pumped
flow of fixer.  Silver is usually collected every 2-3 months.

By maintaining low silver concentrations in the fixer processing
solution, the recirculating silver recovery system minimizes the

     silver lost through carry-over into the waste tank, which results
     in two benefits:

     -  More silver is recovered, increasing monetary return.

     -  Because the concentration of silver in the wash water is
        decreased, the photofinishing lab Is less  likely to  exceed
        allowable discharge limits when releasing the wash water to
        the sewer.

     Desilvered fixer solution can be reused, whether from  an "in-
     line" continuous system or from batch.  However, this requires
     adequate  monitoring and process control to protect product
     quality. Parameters such as pH, silver, and sulfate-concentrations
     should be monitored  to  maintain the  physical and chemical
     properties of the fixer solution.  This usually requires the
     addition of make-up  chemicals.

     Not all the fix can be reused.  With some processes, the reuse of
     as little  as 50%  of the  desilvered fix  added  to new  fix has
     resulted in the serious staining  of the sensitized product unless
     proper precautions are taken such as sulfiting the replenisher
     solution.  Because of such problems, some processing labs  avoid
     using  certain recycling techniques, and some  prefer to  use an
     in-line electrolytically desilvered system.

     The in-line system continuously desllvers the fix in the tank and
     allows the use of a reduced replenishment  rate for the fix.
     However, to use this system successfully, it may be necessary to
     modify the replenisher solution by adding sulfite.

     Residual  silver in  the electrolytically  desilvered  fix  can be
     captured using a metallic replacement cartridge as a secondary
     silver recovery step.  This is known  as tailing.

a   Chemical Precipitation
Chemical  precipitation, though the oldest and cheapest  method of
silver recovery,  is rarely used by photoprocessors, but used widely by
manufacturers  of  photographic supplies.   The  two primary
disadvantages of this process is the generation of hydrogen sulfide gas
and the resulting sludge which must be handled as a hazardous waste.
Recovery  of silver from  the sludge is more  difficult  than  other

Sodium sulfide and sodium  borohydride are  effective precipitants of
silver;  the sodium   borohydride  method,  however,  requires
significantly more excess chemicals to complete the reaction.

The  process mixes the precipitating agent  with  the silver-bearing
wastewater  in a batch reaction  tank equipped with automatic pH
control.  When sodium sulfide is used, the pH must be maintained
above seven to avoid  the release  of toxic hydrogen sulfide gas.  The
optimum pH range for sodium borohydride precipitation is 6.5 to 6.8.
Solid particles of 1-2 microns are formed and allowed to settle out
before filtering.

Solutions treated by sodium sulfide or sodium borohydride cannot be
reused in the photographic process.

4.    Ion Exchange
The basis of the ion exchange  system is the ability of certain resins to
act on ion solutions and  selectively replace  some of their own ions
with ions from the solution. The process is essentially cyclic, with the
solution  being treated passing through the resin until its absorption
capacity is  exhausted.  The  resin is then regenerated by  another
chemical that replaces the ions given up by the  exchange process,
converting the resin back to its original composition.

One of the disadvantages  associated with ion exchange is that silver
thiosulfate complex has a high affinity for the resin used, which makes
it difficult to reclaim the silver and regenerate the resin.  The column
is regenerated with 2% H2SO4 which  forces  silver into the bead
matrix as sulfldes.  The acid solution must  be neutralized.  Other
potential problems include  plugging of the resin by suspended matter
such as  gelatin.  However,  changes  in  equipment  design  and
operational procedures have addressed these problems.

5.    Reverse Osmosis
Reverse  osmosis  (RO)  combines  physics with modern membrane
technology, and is based on the principle of natural osmosis.  When a
concentrated salt solution is  separated from  pure water by a semi-
permeable membrane, the  natural tendency  is for the water to flow
into the  concentrated solution until some equilibrium is maintained.
If the natural osmotic pressure is overcome by applying external force
to the concentrated solution, then water can be made  to flow from the
salt solution through the membrane to the dilute solution.

With RO technology, the wastewater stream flows under pressure over
the surface of a selectively permeable membrane.  Water molecules
pass through the membrane, leaving other constituents behind.  The
extent of separation is determined by membrane surface chemistry
and pore size, fluid pressure, and wastewater characteristics.  The RO
unit Itself consists of one inlet to receive wastewaters, and two outlets
to discharge the purified water and the concentrated wastewater.

For removal of  silver  from  photoprocessing wastewaters,  after-fix
rinsewater is flow-equalized,  filtered, and pumped  through the RO

unit, and silver Is recovered from the concentrate.  Problems with this
system  arise from fouling of the  membrane  and biological growth.
Proper maintenance and control can help alleviate such problems; one
company, for example,  solved  its  membrane  fouling  problem  by
installing a sandbed filter preceding the RO unit.

6.   Low Flow Prewash
With a low flow prewash system, the  after-fix wash tank is segmented,
providing a  small prewash tanks  with separate rinsewater make-up
and overflow.  The after-fix washing Is then done in two  stages;  most
of the silver carry-over  is washed  off in the low volume,  after-fix
prewash tank.  This system  lessens the dilution of the  silver carry-
over, which  allows concentrations of fixer, silver, and other chemicals
to reach higher levels in the prewash tank.

There are problems associated with this system.  One is that the  work
being processed may  receive additional fix  time and  exposure  to
concentrated contaminants while immersed in  the prewash. and there
is concern that this may harm the quality of  the processed material.
Also, if you are using a resin bead system, the  build-up of fix can strip
silver from the resin.  Another problem arises from  the  development
of organic matter that increases the need for maintenance of the wash
With evaporation systems, wastewaters  are collected and heated to
evaporate all liquids, with the resulting sludge collected in filter bags.
These  bags  can then be sent to a silver reclaimer for recovery.
Evaporation  systems  can accommodate operations that do not  have
access to sewer connection or wastewater discharge.

The  major advantage to this  approach is it achieves "zero" water
discharge. Virtually all of the silver in the waste solutions Is captured
with the solids.  However, evaporation has drawbacks.  Organics in the
waste  solution  may  also be evaporated,  creating an  air pollution
problem; some evaporation systems are equipped with filters made of
charcoal to capture organics.  Ammonia  releases are also of concern.
In addition, fewer silver  reclaimers are able to handle the sludge for
economical recovery  of silver.  The expense  of filter purchase and
disposal and increased electrical needs  also makes evaporation less
attractive as a management alternative.
Bleach* Bleach-Fix and Fix Reuse

Ferricyanide bleach was once  widely used in color processing to
convert developed metallic silver and bromide to silver bromide that
could be removed by fixer in subsequent process baths.  About 50% of
the ferricyanide changes to ferrocyanide (before the solution is spent)

during the silver conversion, and leaves the process as overflow, which
at one time was discharged untreated into the sewer.

Because of environmental concerns, ferricyanide bleach has been
replaced in  some color processes by a  combined bleach-fix solution
consisting of a ferric  EDTA complex as  the  oxidizing agent and  a
thiosulfate as the fixing agent. The regeneration of bleach-fix solution
can be very economical due to its relatively high cost and high oxygen-
demanding property.

Some color  processes  have been successfully switched to less toxic
iron-complexed  bleaches  and  bleach-fixes,  but these  alternative
bleach-fixes have not  been widely used in processing Kodachrome,
Ektachrome and certain professional motion picture films.  As long as
ferricyanide bleaches remain in use there will exist the incentive to
recover and reuse these chemicals rather than discharge them to the
environment. Ferricyanide, however, is only a small problem overall in
the industry. Two options are recycling bleach  and bleach-fix.

1.    Bleach Recycling
There  are four methods  for the regeneration of  spent ferricyanide
bleach. These are ozone oxidation, electrolysis, use of persulfate salts,
and the use of liquid bromine.

•     Ozone Oxidation
      Regeneration  of spent ferricyanide  bleach depends  on  the
      production  of ozone gas, a relatively  simple operation  that
      requires, however, the purchase of costly ozone generators.

      In a continuous  processor, the film or  paper moves from the
      bleach bath to a wash bath and on to the fix bath.  By keeping the
      ferricyanide concentration in the waste streams as high as the
      process  will  allow, regeneration of  the ferricyanide  can  be
      enhanced.   Counter-current fixes  and washes  can significantly
      reduce the  total  volume of solution while maintaining  process
      quality.  The dilute rinsewater and ferricyanide bleach are  then
      put through  an ion  exchange  column  to  concentrate  the
      ferricyanide to the point that  allows it to be added  to the
      regeneration tank.  Overflow from the ferricyanide bleach tank is
      controlled  and regenerated.  Bleach regeneration through the
      ozone  process   can  reduce   the  effluent  ferricyanide
      concentration  by  about 90%.

      The  investment for  such bleach  recovery  equipment  is
      significant, but return on the investment  can be realized through
      the reduction  of costs for new chemicals.

During the  electrolytic regeneration  of spent  bleach,  an
electrical current is applied to the ferrocyanide overflow.  This
causes the  solution  to  be  converted  from  a  non-active
ferrocyanide  to active  ferricyanide, generating byproducts of
hydroxide and hydrogen gas.  By separating the hydroxide from
the  ferricyanide  solution  and  adding to it a  solution of
hydrobromic acid, the  bromide and water replenishment is
made, completing the requirements for an active regenerated

Use of Persulfate Salts
The  addition of persulfate salts  is the  most common method
used to regenerate  ferricyanide  bleach.   It is an inexpensive
technique and  utilizes relatively safe  chemicals.  It is however,
less  efficient than electrolytic and ozone oxidation methods.
Additional problems can stem  from the saturation  of the
ferricyanide bleach with sulfate after several regenerations with
persulfate. This build-up of sulfate reduces bleaching efficiency,
fouls piping and pumps, and may  require  the elevation of
ferricyanide to  higher concentrations in an attempt to maintain
adequate bleaching.

Use of Liquid Bromine
The  use of liquid  bromine to regenerate ferricyanide is very
efficient and  provides the bromine ions  required for bleaching.
The  major drawback of this method is the potential health and
safety hazard associated with handling  the liquid bromine.

Bleach-Fix Recycle

Electrolytic System
Most of the techniques used to recover silver from fix can also
be applied to bleach-fix solutions.  However, silver recovery from
bleach-fix must be done in batch systems because  closed-loop
recovery is not  possible.   Generally, the use  of  electrolytic
recovery for the desilvering of bleach-fix allows for greater reuse
of the chemicals from the overflow than does the use of metallic
replacement cartridges.

Regeneration  of  the bleach-fix  for  color  paper  processing
Includes three steps because bleach-fix solution containing ferric
EDTA is frequently used in this process.  First, the silver is
recovered; then  the iron  EDTA complex is  oxidized back to
ferric EDTA to  regain bleaching ability.    Finally, certain
chemicals lost  through  carry-over must be added to bring the
solution up to replenisher strength.

There are electrolytic silver recovery systems that automatically
collect, desilver and  aerate the bleach-fix for reuse.  Aeration is
important because it allows the iron in solution to be oxidized
from ferrous EDTA to ferric EDTA.  This not only restores the
properties of the bleach-fix, but also minimizes cyan dye loss
•which could occur when residual ferrous EDTA reduces cyan dye
to leuco dye.

The resulting solution of desilvered bleach-fix should not cause
adverse effects during its reuse as long as a high enough sulflte
concentration  is  maintained.   Failure to ensure that  the
electrolytic recovery  system is operating properly can result in
serious staining.  If sulfite levels are allowed to drop, benzyl
alcohol carried  over from the developer could be oxidized to
benzaldehyde, interact with chemicals in the  color paper and
cause yellow staining.

Oxidized bleach-fix  is regenerated  by adding chemicals and
reused as replenisher.

Ion Exchange
With this system, bleach-fix overflow from the processing tanks
is passed through an ion exchange resin column to eliminate the
silver  complex  in the overflow.   The desilvered overflow is
collected, sent  to the replenisher tank after proper pH and
chemical concentration has  been  achieved,  and  reused  as
replenisher  solution.

Silver  is recovered from  the column  containing the ion-
exchange resin by treating it  with a solution that will  dissolve
the absorbed  silver  out  of  the resin.    The  resin is thus
regenerated  and ready for reuse.

Ion  exchange   resin  technology has  proven  successful  in
prototype development,  but  has met  with little  commercial
success in bleach-fix reuse to date.

Eighty Concentrated Bleach-Fix Replenishment
Use of highly concentrated bleach-fix replenishment offers an
alternative to bleach-fix recycle systems, and a twist:  Instead of
re-using spent bleach-fix, the system strives  to minimize the
generation of spent process chemicals. Known as bleach-fix NR,
the system  uses a more concentrated replenisher solution and
reduces the rate of replenishment by 75%.

Although the bleach-fix NR  is  not regenerated,  the loss of
chemicals to the environment  is  slightly less than with  a
regenerated system.   This system can also be utilized by almost

     any photoflnishing  lab  of  moderate productivity without
     encountering problems of interference with photographic paper.

     By following the bleach-fix MR with a counter-current low-flow
     wash, photofinishers can collect 98% of the total available silver
     in a very small volume of water The bleach-fix MR and low-flow
     wash mixture can then be electrolytically desilvered from a level
     of 3 to 4 grams of silver per litre to as low as 50 mg/L of silver.
     With this complete system, the silver could be recovered in the
     form of electrolytic plate.  Additionally, 3 to 5% more could be
     recovered by  tailing the bleach-fix  NR low-flow  wash mixture
     through  a recovery cartridge.

     Many labs also use a straight bleach recycling method. Overflow
     is collected, concentrate is added, the specific gravity is taken,
     and the pH is adjusted, usually with  acetic acid. This  is done for
     labs using separate bleach and fix in their paper process and for
     C-41 bleach. (Both are ammonium iron EDTA bleaches.)

Developer Reuse

Since  color  developer  has become one  of  the  most  expensive
processing chemistries, recycling technology has come into  wider use.
The technology was actually first developed in the early 1950s, but it
took the recent surge in the price of organic chemicals to make the
application fo the technology economically  feasible.

During film development, silver  halide salts in  the emulsion such as
silver bromide are reduced to  elemental silver.   Bromide Ions are
subsequently released into solution with the corresponding oxidation
of the  developing agent.  Before spent developer can be reused, the
bromide  ions must be removed  and  the  concentration  of  the
developing agent must be increased.

Currently, there are two main systems for the recycling of developer:
ion exchange and electrodialysis.

1.   Ion Exchange System
Ion exchange  developer  recycling systems depend on  strongly basic
anion exchange resins.  By doing batch processing of spent developer,
equipment needs for this system can be simplified.

These  systems work by passing a specific volume of color developer
through the resin and stripping  it of bromide ions.  The ion exchange
bed  Is regenerated using a  double rinse of salt (6%).  and  then
bicarbonate (4%), thus restoring its  capacity for subsequent bromide
removal.  Eventually resin efficiency will drop as the surface becomes
blocked with oxidized byproducts from the spent developer. However,
there are commercial systems in use that after  a year or two  have

shown no reduced efficiency.  The resin lasts longer on developers
without benzyl alcohol.

After the bromide ions are removed, the solution must be analyzed and
the proper new  chemicals  added  to  bring the solution up to
replenishment specifications.  Because carry-over accounts for 17 to
30% of the replenisher volume used, fresh replenisher must be mixed
into the recycled developer to maintain processing volume.

The ion exchange system is most suitable for those labs that use bulk
chemicals  and have analytical  facilities at their disposal.  Some
equipment manufacturers claim  that such analytical facilities are
unnecessary, however,  those labs that  use this  system  claim such
facilities help ensure adequate quality control on developer recycling

2.    Electrodialysis System.
An electrodializer consists of cation-exchange  membranes  layered
alternately with a pair of electrodes at each  end.  By applying a direct
current,  anions and cations  in the developer solution compartments
are attracted toward  the electrode of the opposite charge.  Recycling
of developer with a electrodialysis system  requires only  halide  ions
such  as  bromide to be  accumulated  and removed from the solution,
leaving other ions in the developer.   Not all developers, however, are
compatible with electrodialysis.

This a commercially  available system that  is generally compact and
requires  no analytical work.


Alaska Health Project. Protect Your Business Investment. The Small
     Business Hazardous Materials Management Technical Assistance
     Packet, Waste Reduction tips for Photoflnishers.

Alaska Health Project.  July 15,  1987,  On-Site Consultation  Audit
     Report:  Photofinishing  Shop.  Waste  Reduction Assistance
     Program (WRAP).

California Department of Health Services, Alternative Technology
     Section. Toxic Substances Control Division. April  1989,  Waste
     Audit Study: Photoprocessing Industry. Arthur D. Little, Inc.

Campbell, M. E., W. M. Glenn, and L.  R. Pirn, Profit from Pollution
     Prevention, A Guide to Industrial Waste  Reduction and
     Recycling: Photography. Pollution  Probe Foundation.

Montana Department of Health and Environmental Sciences, June
     1988, The Small Quantity Generator's Handbook for Managing
     RCRA Wastes:  Photofinishing.

                                  SUMMARY OP WASHINGTON DANGEROUS WASTE
                                             GENERATOR REQUIREMENTS



Fully Regulated Generators
22.200 tbsl
220 - 2.200 Ibs. Generators
Small Quantity Generator*

• Identify all dangerous wastes on-site
• Determine pounds per month or batch
  generated/max, amount accumulated at
  any one time

• Notify State Agency to obtain a
  State/EPA ID #

• Up to 90 days
• In containers which are:
  - compatible with dangerous wastes stored
  - closed unless adding/removing waste
 - handled to avoid damage
• Segregation
 • ignltable or reactive waste stored 50ft
   from property line
 - Incompatlbles stored separately

• No more than 55 gallons of DW
  or 1 quart AHW

• RCRA hazardous waste labels
• DOT labels
• Accumulation start date

• Storage area weekly
• Tanks dally
• Facility for potential dangerous waste spills
• Emergency prevention/detection equipment

• Follow DOT regs for packaging, labeling
  marking and placarding
• Use HW manifest
• Use transporters and TSD
  facilities with State/EPA IDft's
• File any necessary exception reports
• Ship wastes within 90 days
• Identify all dangerous wastes on-slte
• Determine pounds per month or batch
  generated/max, amount accumulated at
  at any one time

• Notify State Agency to obtain
 a State/EPA ID #

» Same as other fully regulated generator
  - Up to  180 days. 270 days If TSD Is more
   than 200 miles away (not to exceed
   2.200 Ibs. of waste)
 1 Same as fully regulated generator
• Same as full regulated generator
• Same as fully regulated generator
 Same as fully regulated generator except:
  -Ship wastes within 180 days (270 if TSD
   is located more than 200 miles away)
  Identify all dangerous wa
  Determine pounds per me
  generated/max, amount i
  at any one time

  Notify State Agency to ol
   a State tt>#

  Same as other fully regul
  No time limit if less than
   and 2.2 Ibs of AHW are a<
 Not applicable
• DOT labels (If necessary)
• Accumulation start date
 No Inspections required
 No manifest required
 Use  licensed hazardous:
  facility with prior appro
• For a complete list of substances which are regulated at 2.21bs, see the Dangerous Waste Regulations.

                                 SUMMARY OF WASHINGTON DANGEROUS WASTE
                                            GENERATOR REQUIREMENTS
                 Fully Regulated Geneiatom
220 - 2,200 DM. Generators
Small Quantity Generator!
<22OlbsHD. <2.2lbsAHW*

                 • Certify on each manifest that you
                  have a waste minimization program
                 • Annual reports require documentation
                  of waste minimization efforts

                 • Each employee who handles
                 dangerous waste must be
                  thoroughly trained In
                  -regulatory compliance
                  -emergency response
                  -emergency equipment

                 • Contingency Plan
                 • Preparedness/Prevention requirements
                 • Incident reports to Ecology
                 • Emergency Procedures

                 • Exception Reports
                  (file within 45 days)
                 • Annual Reports

                 • Manifests (3yrs)
                 • Exception reports (3 yrs)
                 • Test results/sample analyses (3 yrs)
                 • Training documentation
                 • Inspection logs
                 • Annual report (3 yrs)
  Same as fully regulated generator
  No requirement
  Employees must be familiar with
  proper waste handling and emergency
• Emergency Procedures
• Preparedness/Prevention requirements
  Same as fully regulated generator
• Manifests (3 yrs)
• Exception reports (3 yrs)
• Test results/sample analysis (3 yrs)
• Inspection logs
  No requirement
  No requirement
• No requirement
 No requirement
DW     Dangerous Waste
AHW    Acutely Hazardous Waste
EPA    Environmental Protection Agency
DOT    Department of Transportation
RCRA   Resource Conservation and Recovery Act
TSD    Treatment Storage and Disposal Facility
                                                         For Additional Information. Call Regional Offices:
                                                         Northwest:   (206) 867-7000
                                                         Southwest:   (206) 753-2353
                                                         Central:     (509) 575-2490
                                                         Eastern:     (509) 456-2926
• For a complete list of substances which are regulated at 2.21bs. see the Dangerous Waste Regulations.


Waste Reduction
WA Dept of Ecology

Washington Department of Ecology Regional Office
Washington Department of Ecology Regional Office
Washington Department of Ecology Regional Office
Washington Department of Ecology Regional Office

EPA's Office of Pollution Prevention
RCRA Hotline

Trade Contact*
Photo Marketing Association International

Waste Exchanges
Industrial Materials Exchange (IMEX)
Pacific Materials Exchange

Waste HandUne/Recvdlntf
Case Equipment Sales
Chem Security
Chemical Processors. Inc.
Chemical Processors* Inc.
Chempro, Inc.
Ctowtey Environmental Services
ECOVA Corporation
Envirotech Systems. Inc.
Envlrotech Systems. Inc.
Hallmark Metals
LMD Silver Resources
M2 Refining
Northwest Envlro Service
Pacific X-Ray
Sol Clean
Van Waters & Rogers. Inc.
Van Waters & Rogers. Inc.
Van Waters & Rogers. Inc.
Venus Products. Inc.
Washington Chemical Co.
Western Equipment

Waste Reduction Program

Northwest Region
Southwest Region
Central Region
Eastern Region

Silver-Bearing Waste

Silver-Bearing Waste

Silver-Bearing Waste
Silver-Bearing Waste
Silver-Bearing Waste

Silver-Bearing Waste

Contact Person


Tracy Erb


3000 Picture Place

172 20th Avenue
S. 37O7 Godfrey Blvd.

37O1 S. Road

P.O. Box 1866
P.O. Box 222
22O3 Airport Way South. Suite 4OO

1317 Republlan
63O5 N.W. Lower River Road
15555 N.E. 33rd Street
19936 Balllnger Way N.E. W

1743 Cedardale Road
5722 1 19th Avenue E,
P.O. Box 1049
P.O. Box 24443
649 Industrial Drive
9516 E. Montgomery. No. 16
Route 10. P.O. Box 255
P.O. Box 3541. Terminal Annex

1862 Ives Avenue
P.O. Box 743




Mount Vernon












(206) 867-7000
(206) 753-2353
(509) 575-2490
(509) 456-2926

(2O2) 382-4335


(206) 296-4899
(509) 623-4244

(503) 286-321O
(509) 928-8353
(509) 489-9176