REDUCING IS$$
HAZARDOUS
WASTE!
Waste Reduction Guidebook
for the
Photofinishing Industry
with a summary of Washington
Dangerous Waste Regulations
Sponsored By:
II ! II II ( II I Illl I
3 ( f I I I f I I OF
ECOLOGY
Presented By:
Bellevue, WA
Program Funded by a U.S. EPA RTTTA Grant
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REDUCING $$
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
ECOLOGY
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
Techniques
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
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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
wastes.
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
version.
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
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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
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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.
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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.
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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
wastes.
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.
Containers
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.
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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
they:
- 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
landfill).
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-
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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.
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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.
BACKGROUND
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
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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
plants.
POTENTIAL HAZARDOUS WASTES PRODUCED
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.
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Slow Biodegradatian - developing agents, citric acid, ammonium
salts, glycols, hydroxylamine sulfate, formalin, formic acid.
No Btodegradation - phosphate, bromide, ferrocyanide, borate,
nitrate.
Sludges
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.
Containers
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
papers.
WASTE REDUCTION TECHNIQUES
Introduction
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
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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.
Recycling
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.
SOURCE REDUCTION AND RECYCLING-GENERAL PRACTICES
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
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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
benefits.
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
production.
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
spills;
Label all containers with contents and use information;
Conduct regular waste audits;
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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,
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Including any contaminated soil or water. Therefore, spill and leak
prevention are important ways of reducing your hazardous waste
generation.
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
system;
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
contamination;
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
oxidation;
Squeegee chemicals from films to minimize cross
contamination;
Renew photoprocessing chemicals by use of replenisher
concentrates and regenerators.
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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
mixer)
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
feedstock.
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
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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.
WASTE REDUCTION OPPORTUNITIES
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
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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
processors.
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.
2-10
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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
levels.
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
2-11
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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
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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
2-13
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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
2-14
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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
methods.
Sodium sulfide and sodium borohydride are effective precipitants of
silver; the sodium borohydride method, however, requires
significantly more excess chemicals to complete the reaction.
2-15
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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
2-16
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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
tank.
7«
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)
2-17
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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.
2-18
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Electrolysis
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
bleach.
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.
2-19
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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
2-20
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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
2-21
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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
operations.
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.
2-22
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KEY REFERENCES
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.
2-23
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SUMMARY OP WASHINGTON DANGEROUS WASTE
GENERATOR REQUIREMENTS
Washington
pppitaHi»B
Inventory
Notification
Accumulation
Fully Regulated Generators
22.200 tbsl
220 - 2.200 Ibs. Generators
>220lbGbut<22001bsDW
Small Quantity Generator*
<220lhsDW.<:
Satellite
Accumulation
Labeling
Inspections
Transport
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
except:
- 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
except:
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
Washington
Fully Regulated Geneiatom
220 - 2,200 DM. Generators
>220tosbut<2.2O01bGDW
Small Quantity Generator!
<22OlbsHD. <2.2lbsAHW*
Waste
Minimization
Training
Emergency
Response
Reporting
Recordkeeplng
Certify on each manifest that you
have a waste minimization program
in-place
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
procedures
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
KEY TO ABREVIATIONS / ACRONYMS
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.
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WASHINGTON - PHOTOFINtSHING INDUSTRY REFERENCES AND INFORMATION SOURCES
COMPANY
Waste Reduction
WA Dept of Ecology
General
Washington Department of Ecology Regional Office
Washington Department of Ecology Regional Office
Washington Department of Ecology Regional Office
Washington Department of Ecology Regional Office
RefnlBtmv
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
AGCOMetatex
Case Equipment Sales
Chem Security
Chemical Processors. Inc.
Chemical Processors* Inc.
Chempro, Inc.
CMX
Ctowtey Environmental Services
ECOVA Corporation
Envirotech Systems. Inc.
Envlrotech Systems. Inc.
Hallmark Metals
LMD Silver Resources
M2 Refining
Northwest Envlro Service
Pacific X-Ray
Saiety-Kleen
Sol Clean
Van Waters & Rogers. Inc.
Van Waters & Rogers. Inc.
Van Waters & Rogers. Inc.
Venus Products. Inc.
Washington Chemical Co.
Western Equipment
niwsioM
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
BobSmee
Tracy Erb
ADDRESS
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
cny
Jackson
Seattle
Spokane
Lynnwood
Ridgefleld
Bellevue
Washougal
Seattle
Seattle
Seattle
Vancouver
Redmond
Seattle
Seattle
Mount Vernon
Puyallup
Woodliwllle
Seattle
Seattle
Spokane
Spokane
Seattle
Kent
Pasco
Kent
Spokane
Lynnwood
STATE
Ml
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
ZIf*
49201
98122
98204
98037
98OO9
98671
98134
98109
98666
98052
98155
98273
98372
98072
98124
98188
99206
992O6
98124
98032
99210
PHONE NUMBER
(206) 867-7000
(206) 753-2353
(509) 575-2490
(509) 456-2926
(2O2) 382-4335
1-800-424-9346
1-800-762-9287
(206) 296-4899
(509) 623-4244
743-7886
263-3186
827-2774
835-8743
223-0500
223-0500
467-7O45
(503) 286-321O
(8OOIUVEBAC
546-8332/762-6977
363-4442
1-800-255-1895
845-5123
483-9199
622-109O
575-O2O2
928-8353
(509) 928-8353
872-5065
872-5OOO
545-8401
854-2660
(509) 489-9176
774-2933
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