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Guide forCommercial Imaging

Code of Management Practice Guide for Commerical Imaging 4/1/97

The Silver CouncilThe Silver Council is a national group focussed on the environmentally sound managementof silver derived from the processing of photographic images. The Silver Council issupported by the photographic chemical and equipment manufacturers and representsmore than 360,000 users. The purpose is to encourage communications between theregulatory and regulated communities, to support scientific research, and to share currentscientific, technical and economic information so that the common goals of pollutionprevention, recycling, water conservation, and compliance can be met.

The Silver Council550 Mamaroneck RoadSuite 307Harrison, NY 10528-1612Phone: (914) 698-7603Fax: (914) 698-7609

This document may be reproduced in its entirety without permission for distribution at no charge to commercial imaging facilities.

© 1997 by National Association of Photographic Manufacturers, Inc.


The Commercial Imaging Guide to the Code of Management Practice The Commercial Imaging Guide to the Code of Management Practice is a set ofrecommended operating procedures designed to reduce both the amount of silver and theoverall volume of photographic processing solutions discharged to the drain. This guide hasbeen written for pre-press operations, micrographics and other commercial imagingfacilities.

Limitations of the Commercial Imaging Guide to the Code of ManagementPractice The Commercial Imaging Guide to the Code of Management Practice does not supercedeexisting local regulations. Use this Guide only after the local municipality has adopted theCode of Management Practice for Silver Dischargers (CMP) into regulation. Use of thisGuide where the CMP has not been adopted may cause the commercial imaging facility tobe out of compliance with local regulations. Before using the Guide, each commercialimaging facility should check with the local government agency to determine its regulatoryrequirements. For more information contact The Silver Council.

4/1/97Code of Management Practice Guide for Commerical Imaging

Acknowledgements

Many individuals representing the commercial imaging industry have contributed to theCommercial Imaging Guide to the Code of Management Practice. This Guide is the direct result oftheir participation in the committee process. We gratefully acknowledge all of these contributions.

The participants volunteered their time and expertise, thus ensuring this Guide provides anapproach written by commercial processors. Our thanks to each of these people and theircompanies. Special thanks go to Ms. Susan Borea, Agfa Division, Bayer Corporation, Mr. DanSinto, Anitec and Mr. Thomas Purcell, The Silver Council for their assistance to this publication.This project was funded by The Silver Council.

Association of Graphic Communications

Environmental Conservation Board for the Graphics Communication Industries (ECB)

Envision Compliance Ltd.

Graphic Arts Technical Foundation (GATF)

The Silver Council

Agfa Division, Bayer Corporation

Anitec

Eastman Kodak Company

FUJIFILM America, Incorporated

Ilford Photo

Imation Corporation

Konica Corporation

National Association of Photographic Manufacturers (NAPM)

Photo Marketing Association International (PMAI)


1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11.1 Regulating Silver . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

a. Concentration-based Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . 2b. Performance-based Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What’s the Concern with Silver? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31.2 Implementing the Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

2.0 Determining the Category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.0 Small Commercial Imaging Facility . . . . . . . . . . . . . . . . . . . . . . . . . . . 63.1 Compliance Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63.2 Equipment Configurations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

1. One or Two Chemical Recovery Cartridges . . . . . . . . . . . . . . . 72. Terminal electrolytic Unit Followed by a

Chemical Recovery Cartridge . . . . . . . . . . . . . . . . . . . . . . . . . 83. Off-Site Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

4.0 Medium Commercial Imaging Facility . . . . . . . . . . . . . . . . . . . . . . . . 104.1 Compliance Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104.2 Equipment Configurations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

1. Terminal electrolytic Unit Followed by a Chemical Recovery Cartridge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2. In-line electrolytic Unit Followed by a Chemical Recovery Cartridge 123. Two or More Chemical Recovery Cartridges . . . . . . . . . . . . . . . 134. Off-Site Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5.0 Large Commercial Imaging Facility . . . . . . . . . . . . . . . . . . . . . . . . . . . 155.1 Compliance Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 155.2 Equipment Configurations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

1. Terminal electrolytic Unit Followed by Two or More Chemical Recovery Cartridges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2. In-line electrolytic Unit Followed by a Chemical Recovery Cartridge 173. Off-Site Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Table of Contentsi


ii

6.0 Pollution Prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 196.1 Put a Team Together . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

a. Management Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20b. Staff Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21P2 Team Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

6.2 Review Your Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23a. Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Preventive Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23Process Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23Inventory Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Spill Response Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Good Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Safety and Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25Management Practices Checklist . . . . . . . . . . . . . . . . . . . . . . . 26

b. Equipment Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28Squeegee Rollers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28In-line Silver Recovery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28Stand-by Wash . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28Equipment Modifications Checklist . . . . . . . . . . . . . . . . . . . . . 29

c. Process Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Low Replenishment Chemicals . . . . . . . . . . . . . . . . . . . . . . . . 30Solution Regeneration and Reuse . . . . . . . . . . . . . . . . . . . . . . . 30Water Reuse and Recycling . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Dry Chemicals and Automated Mixing . . . . . . . . . . . . . . . . . . . 30Process Modifications Checklist . . . . . . . . . . . . . . . . . . . . . . . . 31

d. Solid Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32Solid Waste Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

6.3 Develop a P2 Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34Screening Your Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Example Worksheet for Screening Options . . . . . . . . . . . . . . . . 34Point System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35Writing the P2 Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35Example Pollution Prevention Plan Worksheet . . . . . . . . . . . . . 35

6.4 Put the Plan in Place . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 366.5 Track Your Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Example Worksheet for Evaluating P2 . . . . . . . . . . . . . . . . . . . 36Spread the Word . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Table of Contents

iii

AppendicesAppendix A Glossary of Terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38Appendix B Electrolytic Silver Recovery . . . . . . . . . . . . . . . . . . . . . . . . . . . 41Appendix C Chemical Recovery Cartridges . . . . . . . . . . . . . . . . . . . . . . . . . 44Appendix D Off-Site Silver Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47Appendix E Evaporation and Distillation . . . . . . . . . . . . . . . . . . . . . . . . . . 50Appendix F Ion Exchange . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51Appendix G Testing for Silver . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53Appendix H Forms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Sample Spill Contingency Plan . . . . . . . . . . . . . . . . . . . . . . . . 56Worksheet for Screening Options . . . . . . . . . . . . . . . . . . . . . . . 57Pollution Prevention Plan Worksheet . . . . . . . . . . . . . . . . . . . . 58Worksheet for Evaluating P2 . . . . . . . . . . . . . . . . . . . . . . . . . . 59Processor Log Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

Table of Contents



1

Photo processing effluent is a by-productof processing film. After silver recovery,this effluent is generally discharged to thedrain where it goes to the publicly ownedtreatment works (POTW) for treatment andeventual release back to the environment.Processing solutions must not bedischarged to a septic system.

Silver is the component of film and paperthat makes it possible to form an image.While it’s not an ingredient of freshsolutions, during processing the silver isremoved from the film and paper and goesinto the solutions. Silver should berecovered from silver-rich solutions beforethey are discharged to the drain because:

• silver is a non-renewable resource,

• some sewage treatment plants(POTWs) and states restrict the amountof silver that can be discharged, and

• silver has economic value.

Effective silver recovery requires equipmentthat is appropriate to the size and activitiesof the commercial imaging facility. It alsorequires implementing a sound preventivemaintenance program for silver recoveryequipment.

Providing you with this information is theprimary focus of the Commercial ImagingGuide to the Code of Management Practice.

The principal elements of the

Commercial Imaging Guide to the Code

of Management Practice is a set of

recommended operating procedures

designed to reduce both the amount of

silver and the overall volume of

processing solutions discharged to the

drain.

The other element of the Guide is voluntarypollution prevention. In addition torecovering silver efficiently, commercialimaging processors should be concernedwith minimizing the amount of waste theycreate. Waste solutions are literally moneydown the drain. In cases where the solutionscan’t be discharged to drain, such as whenthe processor discharges to a septic system,it costs money for off-site disposal. That’swhy it makes sense to minimize waste inthe first place. The second half of the guidedetails several activities a commercialimaging processor can voluntarilyundertake to reduce waste and save money.

The Commercial Imaging Guide to theCode of Management Practice is a guide ofindustry recommended practices. It is NOTa legal requirement. It was written bypeople just like yourselves—people whomanage imaging operations.

1.0 Introduction

A silver-rich solution is a solution thatcontains sufficient silver that

cost-effective recovery can be doneeither on-site or off-site. Silver-rich

solutions include fixers and may includewater from recirculated washwater

systems.


2The Guide takes the guesswork out ofdetermining the specific silver recoveryconfigurations and preventivemaintenance activities you need. Termsused throughout this Guide are defined inthe Glossary of Terms (Appendix A).

Silver discharges can be regulated orcontrolled by two different approaches.The first approach establishes limits on theconcentration or total amount of silver inthe wastewater. The second approachrequires suitable treatment be appliedbefore the wastewater is discharged to thedrain. These categories are“concentration-based” or “performance-based,” respectively.

a. Concentration-based limitsThe traditional means of restricting silver isthrough concentration-based numericallimits in the state law or the city sewerordinance. For example, silver may berestricted to 4 parts per million (ppm).*This means that for every million parts ofeffluent, there can be no more than fourparts of silver.

Concentration-based limits have beenshown to be a poor way to regulatecommercial imaging operations for severalreasons:

1. Our industry strives to conserve waterthrough standby washing, wash waterrecycling and lower replenishment ratesfor process chemicals. As we use lesswater, the concentration of silver in theeffluent **increases. Concentration-based limits, therefore, actuallypenalize those who practice waterconservation.

2. Municipal and state sewage treatmentauthorities ideally develop pretreatmentlimitations by comparing wastewatercoming into the sewage treatment plantand the treated water leaving the plant.The discharge of treated wastewatermust meet limits set by the sewageauthority/EPA to avoid impact on thewater quality of the receiving body ofwater. Local development ofpretreatment limitations has resulted inwidely varying and often unrealisticrestrictions across the country.

3. The sampling point used to determinewhether or not a limit is being met isdetermined by the local sewerauthority. It may be the property linemanhole, a point where all processwastewater is combined or at the pointof generation. This introducesadditional variation from city to city.

4. Our industry’s ability to recover silvercost-effectively is dependent upon theequipment available in themarketplace. Restrictions in somejurisdictions are so stringent they cannot be met with any cost effectivetechnology available.

b. Performance-based limitsPerformance-based limits are spelled out asa percentage of the silver that must berecovered from discharged materials.

* ppm is the same measurement as milligrams per liter(mg/L).

** Effluent is the liquid waste generated from theprocessing of photographic material.

1.1 Regulating Silver

Silver

4/1/97

3These limits provide environmentalprotection while taking into considerationthe amount of silver-rich solutionsgenerated by the imaging operation and thecapability of the technology (equipment)available.

The Code of Management Practice placescommercial imaging facilities into one offour categories and provides specific silverrecovery equipment recommendations foreach category. The category could vary foreach processor in your facility. Forexample, there may be a processor thatruns only a few films per day. Thismachine would fall into the small category.In the same shop, there may be a busyprocessor that runs numerous films per dayand would fall into the medium or largecategory.

If the POTW were classifying your facility,it might take into consideration all theprocess effluent produced per day in theentire facility. For our purposes that’s notvery helpful. It could easily result inrequiring an extensive silver recoverysystem on every processor—even one onwhich only a few films per day areprocessed. If you have this type of situationin your facility, you may need to discussthis with your POTW when it comes tocategorizing your equipment.

The exception is in facilities where silverrecovery operations are centralized. Inthese cases, where fixer from manyprocessors are collected and desilvered ina central location, the category is based ona total volume of fixer and processingeffluent produced at the centralizedtreatment site.

Code of Management Practice Guide for Commerical Imaging

What’s the Concern With Silver?

We wear silver jewelry, eat offsilverware and carry silver fillings in ourteeth. Then why is the silver incommercial imaging processingsolutions regulated? The answer has todo with the different forms silver cantake. The metallic silver that we use ineating utensils and jewelry is nontoxic.But some forms of silver can be verytoxic to aquatic organisms. In fact, yearsago, silver was used as a biocide inwastewater treatment. Even today, silvernitrate is sometimes added to the eyes ofnew infants in order to kill bacteria.

Because the silver ion is highly reactive,it quickly and easily complexes withmaterials in the environment such assulfides and chlorides, to yieldcompounds with little or no toxicity.This means that silver rarely occurs inionic or noncomplexed forms. The silverfound in used fixer, for example, is inthe form of silver thiosulfate, a nontoxicform.

While there is general agreement amongregulators that it’s the ionic form of silverthat’s most toxic, there’s no accurate andrepeatable analytical test method tomeasure the ionic species. Therefore,regulations are based on total silver, withno differentiation between ionic andcomplexed forms of silver.

So silver discharge regulations impact allpre-press processors. While individualdischargers may have little impact onthe POTW, collectively, commercialimaging facilities discharge a significantamount of silver.

4The four categories of film processors, asidentified in the Code of ManagementPractice are as follows:

• A small commercial imagingfacility is one that producesless than two gallons per dayof silver-rich solutions and nomore than 1000 gallons per day of totalprocess effluent. Small facilities mustrecover silver to at least 90 percentefficiency.

• A medium commercialimaging facility is one thatproduces less than 20 gallonsper day of silver-rich solutionsand no more than 10,000 gallons perday of total process effluent. Mediumfacilities must recover silver to at least95 percent efficiency.

• A large commercial imagingfacility is one that producesmore than 20 gallons per dayof silver-rich solutions and nomore than 25,000 gallons per day oftotal process effluent. Large facilitiesmust recover silver to at least 99 percent efficiency.

• A significant industrial user (SIU) isone that discharges more than 25,000 gallons per day of totaleffluent.* SIUs have no set percentagerecovery efficiency as each SIU isindividually permitted by the city.

Through the use of this guide, thecommercial processor, together with thelocal agency can cooperatively regulatesilver discharges to sewer.

This Guide offers a uniform approach toregulation from city to city. Most existingrestrictions are unachievable given today’stechnology and the industry goal ofconserving water.

Performance-based limits are realistic,given the technology currently available tocommercial imaging operations.Performance-based limits that are uniformacross the country would allow theindustry to self-regulate.

Performance-based limits are the best wayto ensure environmental protection whileproviding economic incentive to thecommercial imaging operation.

Who is responsible for ensuring thisperformance-based silver managementprogram is implemented?

In a medium or large operation, theresponsible person is most likely the filmprocessing manager. While the technicalservice or even the processor operatormay be assigned the job of putting certainaspects of the CMP in place, the finalresponsibility rests with management. Thatresponsibility cannot be delegated. Even ifan outside contractor services theprocessors and silver recovery systems, theresponsibility stays with the facilitymanager.

In a small facility, the owner is most likelythe responsible person. The same holdstrue in this situation; while a technician orassistant may undertake part of the dutiesof silver management and pollutionprevention, the final responsibility lieswith the person in charge.


1.2 Implementing the Code

90%

95%

99%

* The EPA defines a significant industrial user as a facility that dischargesan average of 25,000 gallons per day or more of process wastewater tothe publicly owned treatment works (POTW) (excluding sanitary,noncontact cooling and boiler blowdown waste water). Individualmunicipalities are free to use a more stringent definition. (40 CFR 403.3(t)(ii))


5

The first step is to determine which of thefour categories best describes your facility:small, medium, large or significantindustrial user (SIU). Remember, if youhave centralized silver recovery, you mustconsider the amount of fixer producedthroughout the entire facility, rather thanby individual processing machines.

Step 1For a specific processor (or central silverrecovery site), calculate or measure theamount of fixer overflow produced in oneday. For a more accurate estimate, averagethe fixer overflow over several days. Makesure you are using typical processingvolume days.

Step 2On the chart below, locate the FixerOverflow column. Look down that columnand find the amount of fixer overflow youestimated in step 1. Identify the processorcategory size and the silver recoveryefficiency which corresponds to thisvolume.

Example: If in step 1 you estimated that agiven processor produced 6 gallons perday (GPD) of fixer, that processor would becategorized as medium and the silverrecovery efficiency required would be 95 percent.

Note: If your facility produces in total morethan 20 gallons per day (GPD) of fixer thenyou must also consider the total amount ofprocess wastewater produced. If the totalprocess wastewater volume is less than25,000 GPD then you can consider eachprocessor individually. If it is greater than25,000 GPD you are considered aSignificant Industrial User and need to talkto your POTW.

Step 3If you have more than one processor, usethe Processor Log Form in Appendix H tolist each processor, the category size, andthe required silver recovery efficiency.

2.0 Determining the Category

4/1/97

Fixer Wastewater % SilverCategory Overflow Volume Recovery

Small < 2 <1000 90%

Medium >2 but <20 <10,000 95%

Large > 20 <25,000 99%

SIU - >25,000 by permit

all fixer and wastewater measurements are in gallons per day, GPD


6

If you are a small facility, you have fourpractical options for compliance(achieving a 90 percent removal). Thesecan be configured in several ways,discussed below.

The following silver recovery options arerecommended for recovering at least 90%of the silver from silver-rich solutions:

1. one or two chemical recoverycartridges (CRCs) with manufacturerspecified flow control,* or

2. terminal electrolytic unit followed by achemical recovery cartridge (CRC) withmanufacturer specified flow control, or

3. off-site management, or

4. alternative technology providing atleast 90 percent silver recovery.

In this section for small facilities, we’llreview typical silver recovery equipmentconfigurations for each of the complianceoptions. Detailed information is availablein the appendices.

We’ll also describe the testing methodsand procedures to use with the equipmentto verify that it is recovering at least 90percent of the silver.

Finally, we’ll show you samples of simplesilver recovery logs to use for recordingthe results of the testing.

3.0 Small Commercial Imaging Facility

3.1 Compliance Options

A small commercial imaging facility is

one that produces less than 2 gallons

per day of silver-rich solution

Small facilities must recover silver to at

least 90 percent efficiency.

* Facilities that generate less than 0.5 gallons per day ofsilver-rich solutions need only one CRC. Due to thelow volume, a second CRC would oxidize andchannel by the time the first CRC was exhaustedresulting in no additional silver recovery.

For detailed information about a specifictype of silver recovery equipment, how itworks, and preventive maintenancerecommendations, refer to:

Appendix B Electrolytic Silver Recovery Appendix C Chemical Recovery CartridgesAppendix D Off-Site Management

3.2 Equipment Configurations


7

How it worksIn this configuration, the silver-rich overflowfrom the processor (A) is directed to an aholding tank (B - optional). Next, it ismetered (C - optional) at a fixed ratethrough the chemical recovery cartridges(CRCs) set up in series (E and G). In thisdiagram two CRCs are shown. Once thesolution exits the last cartridge in series (H)at least 90 percent of the silver has beenrecovered and the solution can bedischarged to the drain (I).

Testing methods for silver recovery efficiencyThere are two types of testing methodsyou must use:

• once each week, silver estimating testpapers or another method of approxi-mating silver concentration must be usedto indicate whether the system is working(if the paper shows any change in color,the system is not working), and

• once every year, highly accurateanalytical laboratory testing such asatomic absorption (AA) or inductivelycoupled plasma spectroscopy (ICP) mustbe used. Use an outside service foranalytical testing.

Testing procedures

1. To indicate whether the system isworking, check the solution weeklywith silver estimating test papers at twolocations:• after the first CRC at (F)• after the last CRC at (H)

2. To verify the percent efficiency of thesystem, use an analytical laboratory totest the solution once every year, fromtwo locations:• before the first CRC at (B)• after the last CRC at (H)

See Appendix G for more informationabout testing for silver.

Testing records• All test results must be recorded in a

silver recovery log. See the examplesbelow. Check with the publicly ownedtreatment works (POTW) to find outhow long to keep records on file.

Date

7/1/96

7/8/96

7/15/96

P

P

F

P

Silver Recovery LogWeekly Effluent Check*

CRC #1 CRC #2

P

P

* Pass (P) = no color, Fail (F) = color

Date

7/1/96

7/1/97

7/1/98

2800

Influent Effluent%

Recovery

280 90%

Annual Test

Silver Recovery Log (ppm)

1. One or two chemical recovery cartridges (CRCs) with manufacturerspecified flow control

Optional

When the weekly check indicatescartridge failure, refer to theequipment manual for themanufacturer’s recommendations.

To obtain the percent recovery, usethe following formula:100 - (effluent x 100 ÷ influent).


8

2. Terminal electrolytic unit followed by a chemical recovery cartridge (CRC)with manufacturer specified flow control

How it worksIn this configuration, the silver-richoverflow from the processor (A) isdirected to the electrolytic unit (B).When sufficient silver-rich solution hasaccumulated, the electrolytic unit beginsto desilver the solution. When the batch iscompleted, the partially desilveredsolution is pumped out of the electrolyticunit (C) into the holding tank (D-optional).From here, it is metered (E-optional) at afixed rate through the chemical recoverycartridge (G). Once the solution exits thecartridge (H) at least 90 percent of thesilver has been recovered and the solutioncan be discharged to the drain (I).


• once each week, silver estimating testpapers or another method ofapproximating silver concentration mustbe used to indicate the system is working,(if the paper shows any change in color,the system is not working), and

• once every year, highly accurateanalytical laboratory testing such asatomic absorption (AA) or inductivelycoupled plasma spectroscopy (ICP) mustbe used. Use an outside service foranalytical testing. Review Appendix G fordetailed information about testing.

Testing procedures

1. To indicate whether the system isworking, check the solution weekly

with silver estimating test papers at twolocations:• after the electrolytic unit at (D)• after the CRC at (H)

2. To verify the percent efficiency of thesystem, use an analytical laboratory totest the solution once every year, fromtwo locations:• before the electrolytic unit at (A)• after the CRC at (H)



silver recovery log. See the examplesbelow. Check with the POTW to findout how long to keep records on file.

Date

7/1/96

7/8/96

7/15/96

P

P

P

P


Electrolytic CRC

P

F


Date

7/1/96

7/1/97

7/1/98

2350

Influent Effluent%

Recovery

240 90%

Annual Test




Optional


9

How it worksIn this configuration, the silver-richsolution overflow from the processor isstored in a container (A) until it is picked-up by a licensed hauler for off-site silverrecovery, treatment and/or disposal (B).

Testing requirementsThere are no Code of ManagementPractice testing requirements for verifyingsilver recovery efficiencies. State wasteagencies, however, may require testing inorder to characterize the waste.

Additional requirementsCommercial imaging facilities using off-site management must meet the followingrequirements:

• Accumulate the silver-rich solutions ina container that’s compatible withprocessing solutions.

• Provide secondary containment forstorage tanks or containers, if requiredin your jurisdiction.

• Comply with all applicable hazardouswaste and DOT regulations.

• Keep records of volumes and types ofsolutions transferred off-site. See theexample log below.

• Maintain logs, hazardous wastemanifests, land disposal restrictionforms and other records for at least fiveyears. Make the records available forinspection by the sewage treatmentauthorities.

• Verify that the contractor is properlylicensed to transport your waste and ishandling it correctly.

3. Off-site management

OO ffff -- SS ii tt ee CChheemmiiccaa ll LLooggDate Amount Type of Manifest

(gallons) Solution NumberDate

2/6/96

3/5/96

44

44

silver - rich photo

silver - rich photo

MI 3084201

MI 3084202

MI 3084203

MI 3084204

MI 3084205

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48

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10

Remember: the category size of medium isbased on an individual machine, not thewhole facility, unless centralized treatmentis used. This is done to ensure the silverrecovery equipment and testingrecommendations are appropriate for thesize and utilization of the processingequipment.

If you are a medium facility, you have fivepractical options for compliance(achieving a 95 percent removal). Thesecan be configured in several ways,discussed below.

The following silver recovery options arerecommended for recovering at least 95percent of the silver from silver-richsolutions:

1. terminal electrolytic unit followed by achemical recovery cartridge (CRC) withmanufacturer specified flow control*,or

2. in-line electrolytic unit with a chemicalrecovery cartridge (CRC) withmanufacturer specified flow control, or

3. two or more CRCs with manufacturerspecified flow control, or

4. off-site management (includingevaporation/distillation), or

5. alternative technology providing atleast 95 percent silver recovery.

In this section for medium commercialimaging facilities, we’ll review typicalsilver recovery equipment configurationsfor each of the compliance optionsDetailed information is available in theappendices.

We’ll also describe the testing methodsand procedures to use with the equipmentto verify that it is recovering at least 95 percent of the silver.


A medium commercial imaging facility

is one that produces more than 2 but

less than 20 gallons per day of silver-

rich solutions. Medium facilities must

recover silver to at least

95 percent efficiency.

4.0 Medium Commercial Imaging Facility



Appendix B Electrolytic Silver Recovery

Appendix C Chemical Recovery Cartridges

Appendix D Off-Site Management

Appendix E Evaporation/distillation


* Flow control may be gravity feed or a metering pump,depending upon the design capabilities of the cartridge andthe processing workload. Work with your supplier todetermine the flow control appropriate for your system.


11

1. Terminal electrolytic unit followed by a chemical recovery cartridge (CRC)with manufacturer specified flow control

How it worksIn this configuration, the silver-richoverflow from the processor (A) is directedto the electrolytic unit (B). When sufficientsilver-rich solution has accumulated, theelectrolytic unit begins to desilver thesolution. When the batch is completed, thepartially desilvered solution is pumped out ofthe electrolytic unit (C) into the holding tank(D-optional). From here, it is metered (E-optional) at a fixed rate through the chemicalrecovery cartridge (G). Once the solutionexits the cartridge (H) at least 95 percent ofthe silver has been recovered and thesolution can be discharged to the drain (I).

Testing methodsThere are two types of testing methods youmust use:

• once each week, silver estimating testpapers or another method of approxi-mating silver concentration must be used toindicate whether the system is working (ifthe paper shows any change in color, thesystem is not working), and

• once every six months, highly accurateanalytical laboratory testing such as atomicabsorption (AA) or inductively coupledplasma spectroscopy (ICP) must be used.Use an outside service for analyticaltesting.

Testing procedures for silver recovery efficiency

1. To indicate whether the system isworking, check the solution weekly with

silver estimating test paper at twolocations:

• after the electrolytic unit at (D)• after the CRC at (H)

2. To verify the percent efficiency of thesystem, use an analytical laboratory totest the solution once every six months,from two locations:• before the electrolytic unit at (A)• after the CRC at (H)




Date

7/1/96

7/8/96

7/15/96

P

P

P

P


Electrolytic CRC

P

F


Date

7/5/96

1/5/97

7/1/97

2650

Influent Effluent%

Recovery

133 95%

Six Month Test




Optional

2.. In-line electrolytic unit with a chemical recovery cartridge (CRC) withmanufacturer specified flow control


12

How it worksIn this configuration, the silver-richoverflow from the processor (A) iscontinuously recirculated through theelectrolytic silver recovery unit (B) andback into the fixer tank (A). Fixer overflow(C) is fed into the holding tank (D). Fromhere, it is metered (e) at a fixed ratethrough the chemical recovery cartridge(G). Once the solution exits the cartridge(H) at least 95 percent of the silver hasbeen recovered and the solution can bedischarged to the drain (I).


• once each week, silver estimating testpapers or another method ofapproximating silver concentration mustbe used to indicate whether the system isworking (if the paper shows any changein color, the system is not working), and

• once every six months, highly accurateanalytical laboratory testing such asatomic absorption (AA) or inductivelycoupled plasma spectroscopy (ICP) mustbe used. Use an outside service foranalytical testing. Review Appendix G fordetailed information about testing.

Testing procedures

1. To indicate whether the system isworking, check the solution weeklywith silver estimating test papers at twolocations:• after the electrolytic unit at (D)• after the CRC at (H)

2. To verify the percent efficiency of thesystem, use an analytical laboratory totest the solution once every six months,from two locations:• before the electrolytic unit at (A)

(in the fixer processing tank)†

• after the CRC at (H)




4/1/97

Date

7/1/96

7/8/96

7/15/96

P

P

P

P


Electrolytic CRC

P

F


Date

7/5/96

1/5/97

7/1/97

2500

Influent Effluent%

Recovery

129 95%


Six Month Test



† Because no pre-silver recovery measurement is possible, abaseline silver level of 2500 ppm is assumed.


13

How it worksIn this configuration, the silver-rich overflowfrom the processor (A) is directed to theholding tank (B). Next, it is metered (C) at afixed rate through the chemical recoverycartridges (CRCs) set up in series (E and G).In this diagram two CRCs are shown. Oncethe solution exits the last cartridge in series(H) at least 95 percent of the silver has beenrecovered and the solution can bedischarged to the drain (I).



• once every six months, highlyaccurate analytical laboratory testing suchas atomic absorption (AA) or inductivelycoupled plasma spectroscopy (ICP) mustbe used. Use an outside service foranalytical testing. Review Appendix G fordetailed information about testing.

Testing procedures

1. To indicate whether the system isworking, check the solution weeklywith silver estimating test papers at twolocations:• after the first CRC at (F)• after the second CRC at (H)

2. To verify the percent efficiency of thesystem, use an analytical laboratory totest the solution once every sixmonths, from two locations:• before the first CRC at (B)• after the second CRC at (H)



silver recovery log. See the examplebelow. Check with the POTW to findout how long to keep records on file.

3. Two or more chemical recovery cartridges (CRCs) with manufacturerspecified flow control

Date

7/1/96

7/8/96

7/15/96

P

P

F

P


CRC #1 CRC #2

P

P


Date

7/5/96

1/5/97

7/5/98

1784

Influent Effluent%

Recovery

89 95%

Six Month Test

Silver Recovery Log (mg/L)




14

How it worksIn this configuration, the silver-richsolution overflow from the processor isstored in a drum (A) until it is picked-upby a licensed hauler for off-site silverrecovery, treatment and/or disposal (B).Commercial imaging operations canreduce the volume of waste usingevaporation or distillation to reducehauling charges. This technique does notchange the total amount of silveravailable. (see Appendix E.)


Additional requirementsCommercial imaging operation using off-site management must meet the followingrequirements:

• Store the silver-rich solutions in acontainer that’s compatible withCommercial imaging processingsolutions.

• Provide secondary containment forstorage tanks and drums, if required inyour jurisdiction.



• Maintain logs, hazardous wastemanifests, land disposal restrictionforms and other records for at least fiveyears. Make the records available forinspection by the sewage treatmentauthorities.

• Verify that the contactor is properlylicensed to transport your waste and ishandling it correctly.




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3/5/96

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44

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MI 3084201

MI 3084202

MI 3084203

MI 3084204

MI 3084205

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silver - rich photo

silver - rich photo

55

48

55

4/2/96

5/7/96

6/4/96


15

Remember: the category size of large isbased on an individual machine, not thewhole facility,unless centralized recoveryis used. This is done to ensure the silverrecovery equipment and testingrecommendations are appropriate for thesize and utilization of the processingequipment.

If you are a large facility, you have fourpractical options for compliance(achieving a 99 percent removal). Thesecan be configured in several ways,discussed below.

The following silver recovery options arerecommended for recovering at least 99percent of the silver from silver-richsolutions. Ion exchange may be used incombination with other complianceoptions to achieve 99 percent recoverywith the wastewater from the processors:

1. terminal electrolytic unit followed bytwo chemical recovery cartridge (CRC)with manufacturer specified flowcontrol, or

2. in-line electrolytic unit with twochemical recovery cartridge (CRC) withmanufacturer specified flow control, or

3. off-site management (includingevaporation/distillation), or

4. alternative technology providing atleast 99 percent silver recovery.*

In this section for large facilities, we’llreview typical silver recovery equipmentconfigurations for each of the complianceoptions. Detailed information is availablein the appendices.

We’ll also describe the testing methodsand procedures to use with the equipmentto verify that it is recovering at least 99 percent of the silver.


A large commercial imaging facility is

one that produces more than 20 gallons

per day of silver-rich solutions.

Large operations must recover silver to

at least 99 percent efficiency.

5.0 Large Commercial Imaging Facility



Appendix B Electrolytic Silver Recovery Appendix C Chemical Recovery CartridgesAppendix D Off-Site ManagementAppendix E Evaporation & DistillationAppendix F Ion Exchange


* This option allows for improvements to existing technology andfor new technology developed after this guide was written. Italso allows for less commonly used technology that isavailable and can meet the percent recovery requirements.


16

1. Terminal electrolytic unit followed by two or more chemical recovery cartridges (CRC) with manufacturer specified flow control

How it worksIn this configuration, the silver-richoverflow from the processor (A) isdirected to the electrolytic unit (B). Whensufficient silver-rich solution hasaccumulated, the electrolytic unit begins todesilver the solution. When the batch iscompleted, the partially desilvered solutionis pumped out of the electrolytic unit (C)into the holding tank (D). From here, it ismetered (E) at a fixed rate through the CRCs(G, J). Once the solution exits the last CRC(I) at least 99 percent of the silver has beenrecovered and the solution can bedischarged to the drain (K).


• once each week, silver estimating testpapers or another method of approximatingsilver concentration must be used toindicate whether the system is working (ifthe paper shows any change in color, thesystem is not working), and

• once every three months, highlyaccurate analytical laboratory testing suchas atomic absorption (AA) or inductivelycoupled plasma spectroscopy (ICP) mustbe used. Use an outside service foranalytical testing. Review Appendix G fordetailed information about testing.

Testing procedures 1. To indicate whether the system is

working, check the solution weekly

with silver estimating test papers atthree locations:• after the electrolytic unit at (D)• after the first CRC at (H)• after the last CRC at (J)

2. To verify the percent efficiency of thesystem, use an analytical laboratory totest the solution once every threemonths, from two locations:• before the electrolytic unit at (A)• after the last CRC at (J)

See Appendix G for more informationabout testing for silver


silver recovery log. See the examplebelow. Check with the POTW to findout how long to keep records on file.

Date

7/1/96

7/8/96

7/15/96

P

P

P

P


Electrolytic CRC #1 CRC #2

P

F

P

P

P


Date

7/5/96

10/5/96

1/5/97

1876

Influent Effluent%

Recovery

17 99%

2016 18 99%

Three Month Test

Silver Recovery Log (mg/L)




17

4/1/97

2.. In-line electrolytic unit with a chemical recovery cartridge (CRC) withmanufacturer specified flow control

How it worksIn this configuration, the silver-richoverflow from the processor (A) iscontinuously recirculated through theelectrolytic silver recovery unit (B) andback into the fixer tank (A). Fixeroverflow (C) is fed into the holdingtank (D). From here, it is metered (E) at afixed rate through the chemical recoverycartridges (E). Once the solution exits thecartridge (H) at least 99 percent of thesilver has been recovered and the solutioncan be discharged to the drain (I).



• once every three months, highlyaccurate analytical laboratory testing suchas atomic absorption (AA) or inductivelycoupled plasma spectroscopy (ICP) mustbe used. Use an outside service foranalytical testing.

Testing procedures

1. To indicate whether the system isworking, check the solution weeklywith silver estimating test papers atthree locations:• after the electrolytic unit at (D)• after the first CRC at (F)• after the second CRC at (H)

2. To verify the percent efficiency of thesystem, use an analytical laboratory totest the solution once every threemonths, from two locations:• before the electrolytic unit at (A)

(in the fixer processing tank)+

• after the last CRC at (H)




Date

7/1/96

7/8/96

7/15/96

P

P

P

P


Electrolytic CRC

P

F


Date

7/5/96

1/5/97

7/1/97

2500

Influent Effluent%

Recovery

129 95%


Three Month Test



† Because no pre-silver recovery measurement is possible, abaseline silver level of 2500 ppm is assumed.


18

How it worksIn this configuration, the silver-richsolution overflow from the processor isstored in a drum (A) until it is picked-upby a licensed hauler for off-site silverrecovery, treatment and/or disposal (B).Commercial Imaging operations canreduce the volume of waste usingevaporation or distillation to reducehauling charges. This technique does notchange the total amount of silveravailable. (see Appendix E.)


Additional requirementsCommercial imaging processingoperations using off-site management mustmeet the following requirements:

• Accumulate the silver-rich solutions ina drum that’s compatible withcommercial imaging processingsolutions.

• Provide secondary containment forstorage drums, if required in yourjurisdiction.



• Maintain logs, hazardous wastemanifests, land disposal restrictionsforms and other records for at least fiveyears. Make the records available forinspection by the sewage treatmentauthorities.

• Verify that the contractor is properlylicensed to transport your waste and ishandling it correctly.




2/6/96

3/5/96

44

44

silver - rich photo

silver - rich photo

MI 3084201

MI 3084202

MI 3084203

MI 3084204

MI 3084205

silver - rich photo

silver - rich photo

silver - rich photo

55

48

55

4/2/96

5/7/96

6/4/96


19

Your industry has a long history ofpracticing waste minimization or wastecontrol, whether it’s through the use ofphoto processing solutions with reducedreplenishment rates or reduction of silver infilms. Using good waste control practiceshas two benefits: it can lower the impactour businesses have on the environmentand it can save money through reducedmaterial consumption and labor.

In today’s language, waste control iscalled pollution prevention. Pollutionprevention, or P2, is the name given togood management practices, as well asequipment and chemical modificationsthat result in reducing or eliminatingwaste—before it’s generated.

Most commercial imaging facilities arealready using some pollution preventionpractices. In this section of the CommercialImaging Guide to the Code ofManagement Practice we’re going to giveyou a method to look at your imagingoperation, identify options for pollutionprevention, put a voluntary P2 plan inplace and follow-up on the success of thatplan. The diagram on the next pageshows the five steps of P2 planning:

1. Put a team together of interested andcapable staff and management employeesto develop and oversee pollutionprevention activities in your facility.

2. Identify and review your options byexamining your current practices in lightof alternative or additional measures thatcan reduce or eliminate waste.

3. Develop a P2 plan by deciding whichoptions you’ll adopt, the time frame foradopting them, and who will beresponsible for overseeing the option isimplemented and maintained.

4. Put the plan in place by providing thestaff with pollution prevention training andresources. Do not underestimate theimportance of the human factor.

5. Track your results and providefeedback by keeping records where theyare helpful and by routinely auditing orinspecting your imaging operation forpollution prevention.

Not every pollution prevention activitydiscussed in this section will make sensefor your facility. For example, if theprocessing volume is low, an in-line silverrecovery system may not be a goodchoice. This is just one example of whyit’s so important for you to conduct athorough review of your facility andexamine your options before you begin todevelop a P2 plan.

6.0 Pollution PreventionThis section of the guide introduces several

voluntary activities that can result in preventingpollution. We recommend that you readthrough it and adopt any ideas that are

appropriate to your processing operation. Whilemany of these activities are better suited to

larger operations, there are some that can alsobenefit even the smallest film processor


20

In the following pages of this section, weprovide you with specific P2 informationand checklists to assess your performance.

Commitment from management and staffis an essential element of a successfulpollution prevention plan.

Management shows its support by1) developing, implementing andmaintaining a P2 policy, 2) forming a P2team and 3) by allowing adequate timeand resources for P2 activities.

Staff shows its support by working withmanagement to ensure pollutionprevention is a priority.

a. Management activitiesThere’s no substitution for good leadershipin pollution prevention. Management has akey role to play by setting direction,eliminating barriers to change andmotivating employees.

A pollution prevention policy A pollution prevention policy is a simpleand clear statement that waste reductionand elimination are important goals of yourcompany. The policy can be developedwith the help of the P2 team (discussednext). We’ve provided an example of apolicy. Make sure it’s signed by thepresident, owner or plant manager to showcommitment and responsibility to P2activities.

Once the policy is developed, it should beposted for all employees, and customers,to see. Remember—the success of P2 dependsupon support from all the people in thecompany.

6.1 Put a Team Together

Pollution prevention is a key

consideration in all our business

decisions and is the responsibility of

every employee including management

We have a P2 plan in place

incorporating internal practices and

procedures that result in reducing both

liquid and solid waste. The plan is

routinely evaluated and modified to

improve our P2 accomplishments.

Manager and date

Planning for Pollution Prevention

Put a team together1 Identify and review

your options2

Develop a P2plan3

Put the plan in place4

Track yourresults5


21

The P2 team The pollution prevention team is the groupof managers and staff people whodevelop, implement and evaluate all theactivities that go into making up the P2plan.

• How many people should be on theteam? That depends upon the size of youroperation. In a three or four personprinting company, it might be a team ofone—the manager. In a large company, itmight be a team of five or six. You decidehow many people you need.

• Who makes the best team member?The best team member is someone who’sinterested in pollution prevention, wantsto be on the team and has a goodunderstanding of the entire Commercialimaging system. In large companies, try toget representatives of different departments

• What about a team leader? The P2team needs a leader. Management canleave that decision up to the team or itcan designate someone.

Time and resources for the P2 teamThe P2 team needs time and resources todo its job properly. Time means time tomeet, audit the facility, develop the P2plan, implement it and periodicallyevaluate it. Resources means training andtechnical information such as equipmentoperation, maintenance procedures, filmvolume and replenishment rates.Management must provide these as part ofits commitment to P2.

b. Staff activitiesEveryone has a part to play in pollutionprevention. Some staff will be part of theP2 team. Their responsibilities will includeparticipation in the development andimplementation of the plan.

The rest of the staff will be trained torecognize pollution preventionopportunities and to work in such a waythat doesn’t create waste in the first place.

Pollution Prevention Team

Yes No ?

• Do you have a company P2 policy?

• Has it been signed and dated by management?

• Is the policy posted where all employees can see it?

• Is the policy posted where all customers can see it?

• Have employees been told about the P2 policy and its purpose?

• Has the P2 team been formed?

• Are the team members knowledgeable about film processing?

• Has a team leader been chosen?

• Does management provide the team with the time and resourcesneeded for P2 planning and implementation?

ChecklistThis checklist reviews all the elements for putting together a P2 team. When you have the teamin place, you should be able to answer “Yes” to all questions. “No” answers are potentialpollution prevention opportunities. When you don’t have adequate information to answer, markthe “?” Then get the information you need to make an assessment.

22



23

Pollution prevention options for processingsolutions can be broken into threecategories:

1) management practices, 2) equipment modifications, and 3) process modifications.

Each of these will be examined here. We’llalso look at options for managing the solidwaste produced in a Commercial imagingoperation.

At this phase of the P2 process, we’re onlylooking at the available options. After eachdiscussion, we’ve included a checklist foryou to evaluate your practices andequipment. A “Yes” answer means you’realready practicing that P2 activity. Anytimeyou answer “No” you’ve found a potentialpollution prevention opportunity. Anytimeyou answer “?” it means you need moreinformation to evaluate the option. Whenyou finish, look back at the checklists andwith the team, choose the best P2 optionsfor your company.

a. Management practicesSome of the easiest and least expensivemanagement practices produce the mosteffective pollution prevention results. Keepthis in mind as we look at the followingmanagement practices.

Preventive maintenancePreventive maintenance should be yourfirst pollution prevention option. Byimplementing a complete preventivemaintenance program, the equipment willwork at its optimum level, keeping wasteat a minimum. Use the recommendationsfound in the equipment operating manual

as a starting point for your preventivemaintenance program.

Process controlProcess control is the routine monitoringof variables that affect the quality of yourproduct. These variables include:

• replenishment rates, • processing temperatures,• processing time, and• chemical mix procedures.

They should be checked on a periodicbasis to ensure that the film image qualityis good and waste is minimized. Thesevariables should be monitored on a setschedule tied to the preventivemaintenance schedule.

Commercial imaging operations shouldalso routinely run control strips, chart theresults of each strip (as shown on the chartbelow) and take action based on theresults.

Example process control chart

6.2 Review Your Options

Process Control Chart

Control Strip # Machine Speed Developer Date Installed Repl RateDeveloper Temp Fixer Date Installed Repl Rate

Dev

eloper

Spee

dEf

fect

ive

Contr

ast

Index

Time

Day

Month

Note

s

3 4 4 5 8 9 10 11 15 16 17 18 19 22 23 25 30 31 31 1 2

1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 3 3 3 3 3

5 6 7 8 9 9 12 13 14 14 16 19 20 24 26 28 1 4 5 5 6

6.6

6.1

18

13

8

#138 30 seconds Whatadot December 22

December 12

9

9Supra Universal90°F

Rep

l D

ev

Rep

l D

ev

Fre

sh F

ixer

Rep

l Dev

&F

ix

Dev

sw

itch

stuc

k


24

Inventory controlManaging the chemical inventory includesrotating the stock so that the oldest is usedfirst and maintaining an appropriate supplyof chemicals on-hand. This reduces therisk of having old chemicals in inventoryand reduces the amount of money tied-upin overstock.

Spill response planningAny time a solution is unintentionallyreleased it’s a spill. The key word isunintentional. When you produce a wastesolution during rack washing, it’sintentional. But if a container ofphotographic processing solution isdropped on the floor, ruptures and leaks,you have an unintentional spill.

Most spills are minor splashes or leaks andcan be cleaned up with a sponge or mop.Occasionally, however, a larger spill couldoccur requiring specialized clean-upmaterials and procedures.

The time to plan for a spill is long before ithappens. A good spill response plan willhelp minimize the effects of the spill onthe environment and ensure theCommercial imaging facility returns tonormal as quickly as possible. Some of thethings to include in your spill responseplan include:

• an inventory of all the chemicals usedin the commercial imaging operation;

• a floor plan showing the location of allchemicals in the processing area, floordrains, exits, fire extinguishers and spillresponse supplies;

• a description of the containment usedfor silver recovery cartridges, mixingtanks, chemical storage tanks and anyother containers that could leak orrupture;

• a list of spill response supplies andequipment such as mop, pail, sponge,co-polymer or other absorbentmaterials, neutralizing materials andpersonal protective equipment; and

• a set of tested procedures forresponding to a spill. A sample spillresponse procedure, as shown below isincluded in Appendix H.

Mr. Opaque Pre-Press Ltd.

SPILL CONTINGENCY PLANSpill Response Personnel

Name pager/phone

Name pager/phone

Name pager/phone

EnvironmentalEmergencyPhone (999) 999-9999 24 hours a day

7 days a week

EQUIPMENT REQUIRED

• Gloves • Bucket • Absorbent Materials• Apron • Mop • Neutralizing Materials• Goggles • Sponge

SPILL RESPONSE PROCEDURES

1. Put on gloves, goggles and an apron.

2. Contain the spill with a mop or absorbent materials available.

3. Check the appropriate material safety data sheet (MSDS) for specialhandling, ventilation, personal protection or other pertinent data.

4. Clean up the spill, as directed, using generous amounts of water.

5. Use the mop and sponge to clean the area thoroughly.

6. Package and label all contaminated absorbent materials for off-sitedisposal.

7. Notify the supervisor or manager that a spill has occurred.

8. (If required) Notify appropriate government agency that a spill hasoccurred.

Don Spillit 999-5555

Ruth Typeset 555-9999

Bill Sorbit 898-5656

25Good housekeepingIn a clean and orderly operation, there’sbetter control over materials andequipment and less likelihood of spills.This results in less operational waste andprevents pollution.

Good housekeeping is one of thoseinexpensive and simple managementpractices that can significantly reducewaste, increase productivity and lowercosts. You can’t afford to neglect it.

Here are three basic good housekeepingguidelines:

1. Designate an appropriate storage areafor all materials and equipment.

2. Require every employee to return allmaterials and equipment to theirdesignated area.

3. Establish a procedure and a scheduleto inspect chemical receiving, storage,mixing and use areas for spills, leaks,cleanliness and orderliness.

Safety and securityKeeping chemical areas safe and securecan minimize spills and other upsets.

• Make sure there is always someonetrained in spill response procedures inthe facility or who can be contacted torespond immediately.

• Restrict staff admittance to areas wherechemicals are used and stored to staffwho have had hazard communicationtraining.

• Make sure there’s an MSDS on file forevery chemical in the facility.

• Maintain a security system so that youknow when someone is in the facility,both during and after working hours.


ChecklistThis checklist reviews all the elements for evaluating management practices. “Yes” answersindicate that you’re already using that pollution prevention measure. “No” answers are potentialpollution prevention opportunities. When you don’t have adequate information to answer, markthe “?” Then get the information you need to make an assessment.

26


Management Practices

Yes No ?

• Is there a preventive maintenance program in place incorporating all the equipment manufacturer recommendations?

Yes No ?

• Are solution replenishment rates routinely monitored?

• Are processing tank temperatures routinely checked?

• Are processing times routinely checked?

• Are standard chemical mix procedures used by all staff?

• Are control strips run on processors at least once per shift?

• Are all control strips plotted on control charts?

• When corrective action is taken, is it noted on the control chart?

Yes No ?

• Is the oldest chemical stock always used first?

• Are appropriate levels of stock maintained?

Yes No ?

• Is there a spill response plan?

• Is it posted in the chemical mix area?

• Is an inventory of all chemicals posted in the imaging area?

• Is there a floor plan detailing the location of chemicals, floordrains, exits, fire extinguishers and spill response supplies?

• Is there containment around all permanent chemical containers?

• Are the spill response supplies easily accessible?

• Are spill response personnel properly trained?

Preventive Maintenance

Process Control

Spill Response Planning

Inventory Control

27


Management Practices (continued)

Yes No ?

• Are all materials and equipment kept in a specified location?

• Are all chemical containers routinely checked for cracks or leaks?

• Is all equipment wiped clean of chemical residue and dirt?

• Are all floors free of chemical spills and residue?

• Are aisles and walkways clear?

• Does the Commercial imaging area look orderly and clean?

• Are all employees held accountable for good housekeeping?

Yes No ?

• Is there at least one staff member trained in spill response inthe facility at all times?

• Are areas where chemicals are used and stored restricted tostaff trained in safe chemical handling?

• Is there an MSDS for every chemical in the facility?

• Is there a security system in place during working andnonworking hours?

Good housekeeping

Safety and Security


28

b. Equipment modificationsA second category of pollution preventionoptions is equipment modifications. Thisrefers to the changes made to film andpaper processors to reduce the amount ofwaste solution produced throughprocessing. As we examine each of theseoptions remember what we said earlier:Not every one of these options isappropriate for your equipment. In somecases, equipment cannot be modified or isnot an economical option. Check withyour equipment manufacturer.

Squeegee RollersSqueegees rollers are an effective P2option that improves silver recovery. Asthe film exits the fix tank, it carries over acertain amount of silver-rich solution intothe wash. Squeegee rollers reducecarryover, therefore keeping the silver inthe fix tank where the overflow can besent to silver recovery instead of being lostin the wash tanks.* Care and routinemaintenance can extend the life andeffectiveness of squeegee rollers.

In-line silver recoveryAnother way to reduce the silver carriedover from the fix tank into the wash tanksis to reduce the concentration of silver inthe fix. This can be done with in-linesilver recovery.

In-line silver recovery is an electrolyticunit through which the fix in the processortank is recirculated and constantlydesilvered. Because the silverconcentration is kept at a low, fixedamount, this significantly reduces theconcentration of silver carried over intothe wash.

There are other benefits of in-line silverrecovery. Generally, it’s possible to use alower fix replenishment rate which meanslower fixer consumption. Additionally, thesilver recovered is high grade silver flake.

If you use in-line silver recovery, checkwith your chemical supplier to determineif you need a specially formulated fixer.

Stand-by WashToday, most processors come equippedwith an extremely efficient water savingdevice called stand-by wash. This controlsthe wash water so it runs only when thefilm is being processed. When the filmclears the machine, the wash goes intostandby position and doesn’t begin againuntil the next film is processed. Thisequipment modification can savehundreds of gallons of water. If you havean older machine, check with yoursupplier to find out if it is possible to haveit modified for a standby wash.

* Squeegee rollers are also used between the developerand fixer tanks. This minimizes developer carryover thatcontaminate the fixer.

Equipment modifications

Yes No ?

• Are there squeegee rollers on processors capable of being equipped?

• Are all squeegee rollers routinely checked and replaced?

• Are all squeegee rollers cleaned as part of the shut-down procedure?

Yes No ?

• Is there an in-line electrolytic unit on all film fixer tanks?

• Is the silver concentration in the tank monitored so that itdoesn’t get below 500 ppm or above 1000 ppm?

• Is the fixer appropriate for in-line silver recovery?

• Has the fixer replenishment rate been reduced?

Yes No ?

• Are the processors equipped with standby wash?

ChecklistThis checklist reviews all the elements for evaluating equipment modifications. “Yes” answersindicate that you’re already using that pollution prevention measure. “No” answers are potentialpollution prevention opportunities. When you don’t have adequate information to answer, markthe “?” Then get the information you need to make an assessment.

29

In-line Silver Recovery

Squeegee Rollers

Standby Wash (if applicable)



30

c. Process modificationsThe third category of pollution preventionoptions is process modifications. Just aswith equipment modifications, not allprocessors can be changed toaccommodate every one of these processmodifications.

Solution regeneration and reuseRegenerating and reusing fixer may reducethe amount of chemicals to be desilveredor discharged to the drain. If theequipment can be modified and the filmuse is high enough, this pollutionprevention option can significantly reducewaste. Talk with your film and chemicalsuppliers to find out if this option isappropriate for your facility.

Off-site chemical recycling may also be anoption. In this case, the film processingfacility collects the fixer overflow at theprocessor and periodically ships thecollected solution to the recycler, Fromhere, the fixer is desilvered and alsoregenerated for reuse. The regeneratedfixer is then returned to the filmprocessing facility to be used as freshchemical.

Water reuse and recyclingReducing the amount of water used inprocessing reduces waste and conserves avaluable resource. Optional processmodifications for water conservationinclude:

• wash water recycling equipment

• manufacturer kits such as meteredwash water replenishment and washwater timers.

Because wash water has a direct affect onimage stability, always consult with yourfilm manufacturer before making waterconservation modifications to theprocessors.

Dry chemicals and automated mixingUnder some conditions, dry chemicalpackaging and automated mixing cancontribute to waste minimization throughextended shelf life and less packagingmaterial.

Process modifications

Yes No ?• Have replenishment rates been measured or adjusted

to manufacturer specifications

Yes No ?

• Are chemicals regenerated where it’s practical?

• Is the portion of the silver-rich chemicals that is not regeneratedsent for silver recovery?

• Are chemicals reused where it’s practical?

Yes No ?

• Are wash water rates set at manufacturer recommendations?

• Does the wash water run only during processing?

• Is wash water conservation being used?

(e.g., metered wash water replenishment or wash water timer)

Yes No ?

• Are dry chemicals used where it’s practical?

• Are automated mixers used where it’s practical?

ChecklistThis checklist reviews all the elements for evaluating process modifications. “Yes” answersindicate that you’re already using that pollution prevention measure. “No” answers are potentialpollution prevention opportunities. When you don’t have adequate information to answer, markthe “?” Then get the information you need to make an assessment.

31

Solution Reuse

Replenishment

Water Reuse and Recycling

Other Process Modifications



32

d. Solid wasteThere are pollution preventionopportunities for reducing the solid wasteproduced in Commercial imaging. Forexample, film can be sent out forprocessing and silver removal. Somemanufacturers will recycle plastic endcaps and chemical cubitainers.

Some cities have recycling programs forcorrugated cardboard, office paper andother materials. Reusing and recyclingreduces the amount of solid waste goingto landfill and lowers your waste disposalfees.

The example below is from a pre-pressfacility. Use it as a guideline in developinga pollution prevention guide for youroperation.

Pre-press Facility

waste film

waste plates

waste vinyl

waste acetate

packaging materials

low-silver solutions

systems cleaner

waste water

silver-rich solutions

recycled

recycled

trash

trash

trash

sewer

sewer

sewer

recycled

sewer

recycled

silver recovery

PackagingMaterials

tissueboxes

film

Suppliesfilm, plates

acetate, cutting bladesproof materials

Chemicalsdevelopers

fixer, film cleanersglass cleaners

system cleaners

Productsfilm

proofsplates

P2 Opportunities in a Commercial Imaging Operation

Solid Waste

Yes No ?

• Plastic core protectors?

• Paper cores (cardboard)?

• Photographic paper bags?

• Processing equipment filters?

• Packing materials including pallets and plastic wrap?

Yes No ?

• Films and plates?

• Chemical containers or cubitainers?

• Unwanted or excess exposed and processed film

• Paper cores (cardboard)?

• Office paper?

• Corrugated cardboard?

• Box board?

• Packing materials including pallets and plastic wrap?

ChecklistThis checklist reviews all the elements for evaluating your solid waste management program.“Yes” answers indicate that you’re already using that pollution prevention measure. “No”answers are potential pollution prevention opportunities. When you don’t have adequateinformation to answer, mark the “?” Then get the information you need to make an assessment.

33

Are the following solid wastes reused:

Are the following solid wastes recycled:



34

Now that the P2 team has finished theaudit or review, it’s time for them to lookat all the options and prioritize them as:

• High priority—needs immediateaction

• Medium priority—needs action within3 to 12 months

• Low priority—needs considerationwithin the next 1 to 2 years

Screening your optionsScreen each option by asking thefollowing questions and writing out youranswers:

1. What is the potential for reducingwaste and providing otherenvironmental benefits?

2. What is it going to cost in time,materials and equipment costs?

3. How much money will it save in timeand materials?

4. How difficult is it to implement?

To show you how this works, look at thefollowing example of screening the optionof using in-line silver recovery on the filmprocessor. A blank worksheet is includedin Appendix H. Make copies as you needthem and leave the original in this Guide.

6.3 Develop a P2 Plan

Example Worksheet for Screening Options Date

Option: Installing and maintaining an in-line silver recovery unit on the processor

1. What is the potential for reducing waste and providing other environmental benefits?Less silver will be lost to the wash tank and therefore the drain. In addition, we may be able toreduce replenishment rates.

2. What is it going to cost in time and materials?Cost of the electrolytic unit, labor for installation and periodic replacement, and labor formaintenance. (Estimate actual costs as closely as possible.)

3. How much money will it save in time and materials?The savings will come in the increased amount of silver recovered (estimate actual savings asclosely as possible) and lower fix replenishment rates.

4. How difficult is it to implement? Not difficult, We can schedule the installment during the next preventive maintenance check onthe machine. We need to buy the electrolytic unit. We also need to train process operators tokeep the silver concentration about 500 ppm to reduce the potential for sulfiding.

1/17/97


35Screening all the options you’ve identifiedwill take time but it’s time well spent. It’svery important that you actually write outyour answers. Doing your homework heremakes the difference between a P2 planthat exists only in your head vs. one that isimplemented and working.

Point systemYou might find it useful to develop a pointsystem for rating all the options. Forexample, you could assign a plus value toevery potential benefit and a minus valueto every negative impact.

Writing the P2 planWhatever system you use, you need to getto the point where you’ve prioritized all ofthe options. Now you can begin to draftthe P2 plan. For your first attempt atsystematic pollution prevention, werecommend that you start with only thehigh priority options. Work at getting

these into place and evaluate your successbefore addressing the medium and lowpriority options. Don’t make too manychanges as once—start with only 1 or 2items.

Keep your P2 plan simple. Here is theinformation you should include:

• Spell out each option and its purpose

• State a specific date when the optionwill be implemented

• List who is responsible

• Note if a record will be kept

Review the example below. A blankPollution Prevention Plan Worksheet isincluded in Appendix H. Make copies asyou need them and leave the original inthis Guide.

Example Pollution Prevention Plan Worksheet Date

Option or activity: We’re going to install the in-line unit on the film processor in order

to reduce the amount of silver in the wash water.

Implementation date: The unit will be installed during the December preventive

maintenance check.

Responsibility: Joe Smith, maintenance supervisor, will spec the unit, arrange for purchase,

develop an installation plan, ensure it is installed and be responsible for seeing it is

maintained. He will also train the process operators how to maintain and harvest the silver.

Record: In-Line electrolytic maintenance will be added to the preventive maintenance

checklist.

2/08/97


36

Now that you have a P2 plan it’s time toput it into action. These are the steps:

1. Make the plan known - Post it, explainits purpose and details to the employees,and talk it up. Through both your wordsand actions, make all employees aware ofhow committed management is topollution prevention. Keep employeesupdated on both the successes and failuresof the plan.

2. Provide training and education - Makesure that anyone who is given responsibilityin the P2 plan has the training andknowledge to carry out his/her tasks.

3. Provide the necessary resources - Makesure that anyone who is given responsibilityin the P2 plan has the time and materialsrequired to fully implement the P2 plan.

Your P2 plan isn’t a “Now I’ve done it so Ican forget about it” kind of thing. You

need to periodically review it, evaluatewhich elements are working, which needto be modified and which need to bediscontinued. A review every six monthsshould be often enough.

As you evaluate your P2 plan, keep inmind your original intent for pollutionprevention: minimizing or eliminatingwaste for both environmental andeconomic benefit.

Answer each of the following questions foreach pollution prevention option oractivity listed in your plan:

• How much waste has been reduced oreliminated as a result of this activity?

• How much has it cost?

• How much money has it saved?

In some cases, it may be hard to get exactanswers to these questions. But try. It’simportant that you fully evaluate every P2option implemented in your commercialimaging operation. Once again, let’s lookat installing an in-line unit as an example.

6.4 Put the Plan in Place

6.5 Track Your Results

Example Worksheet for Evaluating P2 Date

Option: Installing and maintaining in-line electrolytic silver recovery unit on the film processor

1. Waste reduction resultsAfter analyzing the wash water, we found the concentration of silver went from 95 ppm to 12 ppm.Over the 6 month period, we estimate this represents 386 troy ounces of silver.

2. CostsMaterials - unit= $1240. Labor - installation 1 1/2 hours x $20/hour = $30. Daily maintenance - 1minute at $12/hour = $.20 daily or $24 for 6 months. Total costs = $1294

3. Savings386 tr. oz. of silver at $5.40 tr. oz. = $2084. This was the amount of silver diverted from the wash.

4/20/97


37A successful P2 option or activity is onethat reduces waste and saves more moneythan it costs. Consider whether changing itwould make it even more successful orwhether to let it continue as is.

An unsuccessful option or activity is onethat doesn’t reduce waste, or it costs moremoney than it saves. With an unsuccessfuloption, consider whether changing itwould make it successful or whether todiscontinue using it.

Once you’ve done this evaluation forevery option, you can also considerwhether it’s time to put some of thosemedium priority options in place.Remember not to make too many changesat once.

Spread the wordEvery time you evaluate the success of theP2 plan, let the staff know the results—both the positive and the not so positive.When you decide to make changes orimplement new P2 activities, remember totrain the staff if there are any newprocedures.

Include your P2 success stories in yourfacility's annual report or newsletter. Ifthere’s no environmental section in thereport, now is a good time to start one.

With pollution prevention, everyone’s awinner: the impact of your business on theenvironment is reduced and the costsavings from lower waste means moremoney in your pocket.

P2P2

Code of Management Practice Guide for Commercial Imaging

38

AMSA: The Association of MetropolitanSewerage Agencies represents the interestsof the country’s largest wastewatertreatment agencies. AMSA maintains a keyrole in the development of environmentallegislation and implementation ofenvironmental rules, guidance and policy.

Anode: The positively charged electrode.When electrolytically desilveringcommercial Imaging processing solutions,the thiosulfate is oxidized at the anode.

Batch Process: The collection of silver-richsolution into a tank or container which isprocessed through a silver recovery ormanagement system.

Biocide: A chemical that discourages thegrowth of bacteria.

Cathode: The negatively chargedelectrode. When electrolyticallydesilvering commercial imagingprocessing solutions, metallic silver isdeposited on the cathode.

Commercial Imaging Facility: A facilityprocessing pre-press film, micrographicsor any other nondiagnostic black andwhite photographic process.

Code of Management Practice (CMP): Thesite-specific plan implemented by theindividual processing facility for thepurpose of controlling and reducingdischarges of silver to the POTW.

Continuous Process: The processing ofsilver-rich solution in a continuous flowfrom the processing machine through asilver recovery or management system.

Cradle-to-Grave: A phrase used todescribe the tracking system for hazardouswaste. All parties in the waste chain—generator, transporter, storage and disposalfacilities—use a common manifest thatidentifies them, the waste, and the finaldisposition of the waste.

CRC: A chemical recovery cartridge whichrecovers silver through a process knownas metallic replacement.

Distillate: The liquid recovered bycondensation during the process ofdistilling or concentrating used processingsolutions and wash waters.

DOT: Department of Transportation

Effluent: The solution exiting a process orpiece of equipment.

Electrolytic Silver Recovery: A method ofrecovering silver in which a direct currentis applied across two electrodes immersedin a silver-rich solution. Silver plates ontothe cathode and the thiosulfate is oxidizedat the anode.

Good Housekeeping: Maintenance of aneat, orderly and clean working environment.

Appendix AGlossary of Terms

4/1/97

4/1/97Code of Management Practice Guide for Commercial Imaging

39Influent: The solution entering a processor piece of equipment.

Ion Exchange: A reversible exchange ofions between a solid (resin) and a liquid(water containing ionized salts). Whenused with photo processing solutions, ionexchange removes silver and replaces itwith ionized salts.

Large Commercial Imaging Facility: Afacility which produces on average morethan 20 gallons per day (GPD) of silver-rich solution.

Low-Silver Solution: A solution containinginsufficient silver for cost effective silverrecovery. Low-silver solutions includeused developers, stop baths and washwaters.

Manufacturer Specified Flow Control:means a pump or restricted orificerequired by the manufacturer to meet andmaintain the silver recovery efficiency formetallic replacement cartridges.

Medium Commercial Imaging Facility: Afacility which produces on average morethan 2 but less than 20 gallons per day(GPD) of silver-rich solution and uses lessthan 10,000 GPD of process wash water.

Metallic Replacement: A method ofrecovering silver from silver-rich solutionsby an oxidation-reduction reaction withelemental iron and silver thiosulfate toproduce ferrous iron and metallic silver.The device used is commonly called achemical recovery cartridge (CRC).

Milligrams per Liter (mg/L): mg/L is thesame measurement as parts per million(ppm).

Off-Site Silver Recovery andManagement: Removal of silver-richsolutions from a facility by a haulingservice to a recovery facility.

On-Site Silver Recovery and Management:The management and treatment of silver-rich solutions on the premises in which thesilver-rich solutions are generated.

pH: An expression on a scale from 0 to 14of the extent of acidity or alkalinity of asubstance. Materials with a pH of 7 areneutral. Those below pH 7 are acidic andthose above pH 7 are alkaline.

Pollution Prevention: Any practice thatreduces or eliminates waste at the source.

POTW: Publically Owned TreatmentWorks. A wastewater treatment facility(WWTF) owned by the public(municipality or service authority).

Pre-Press: The photographic process usedin preparing film and separations.

Preventive Maintenance: A set ofprocedures routinely performed onequipment and processes to reduce therisk of a malfunction.

Pretreat: To change the characteristic of awaste by treatment before it is dischargedto a POTW.

Significant Industrial User (SIU): Anyindustrial user that: discharges an averageof 25,000 GPD or more of processwastewater to a POTW; contributes aprocess waste stream which makes up 5%or more of the average dry weatherhydraulic or organic capacity of thePOTW; or, is designated as such by theControl Authority on the basis that theindustrial user has a reasonable potential


40for adversely affecting the POTW’soperation or for violating any pretreatmentstandard.

Silver Recovery: The process of reclaimingsilver from silver-rich solutions such asfixers and low flow washes.

Silver-Rich Solution: A solution containingsufficient silver that cost effective recoverycould be done either on-site or off-site.Silver-rich solutions include fixers and lowflow wash.

Silver Estimating Test Paper: A test papercoated with an analytical reagent whichreacts by changing color in relationship tothe amount of silver in solution. Areference color code allows users toestimate the approximate amounts of silverin solution.

Small Commercial Imaging Facility: Afacility which produces on average lessthan 2 gallons per day (GPD) of silver-richsolution.

Source Reduction: A decrease in theproduction of both the volume andtoxicity of liquid waste.

Spill: Unintended release of liquid that isnot in the ordinary course of events.

Squeegee: Physical device (e.g. rollers.)used on processors to remove residualsurface liquids before the film or papertravels from one processor tank to thenext.

Sewer: An underground conduit forcarrying wastewater to a POTW.

The Silver Council: A national groupsupported by the photographic chemicaland equipment manufacturers andrepresenting more than 360,000 userswhose focus is to achieve sourcemanagement of silver-bearingphotographic imaging materials in theleast restrictive regulatory environment.


41

Electrolytic recovery is an efficient andcost-effective silver recovery technologyfirst used in 1931. Since then theequipment has evolved and been refinedso that today’s electrolytic units arereliable and can consistently achieve 90%recovery efficiency. The equipment iscontinuously reused and few additionalchemicals are required to perform therecovery operation.

Throughout this discussion, refer to thediagram in the right-hand column. Inelectrolytic silver recovery two electrodesare immersed in silver-rich solution.Electric current reduces the silver-thiosulfate complex in the solution andplates almost pure silver metal onto thecathode—the negatively chargedelectrode. The cathode is typically madeof stainless steel. The amount and qualityof the silver plated out depends upon theoperating amperage and the length of timethe solution is exposed to the current.

There are two basic types of electrolyticequipment: one in which the cathode rotates in the solution and the other inwhich the solution flows around a stationarycathode. Either type of equipment iscapable of recovering a significant amountof the silver from the silver-rich solutions.

In Addition, there are batch units andflow-though units. In the batch unit, the

solution is collected within a chamberinside the electrolytic unit until there issufficient quantity to constitute a batch.The solution is then pumped out all atonce, usually into a secondary recoverysystem. In a flow-through unit, the silver isrecovered continuously as it flows into theunit. This solution is displaced as moreprocessor overflow enters the electrolyticunit.

Depending on the percentage removalrequired, electrolytic units must be used inconjunction with another system.

In-line electrolytic silver recoveryBy using in-line electrolytic silver recoveryon fix solutions, the amount of silver insolution is significantly reduced. Thisresults in less silver carried over into thefinal wash water and subsequentlydischarged to the sewer. Where the use ofin-line silver recovery is possible, mixingand chemical usage can be reduced by upto 50 percent, further increasing the cost

Appendix BElectrolytic Silver Recovery

4/1/97

B.1 How it Works

Electrolytic Unit


42effectiveness of this technology. Thisapproach may not be feasible in allcircumstances. Solution overflow from in-line systems must be treated by anothersystem to further reduce the silverconcentration.

The electrolytic unit must have enoughcapacity to treat peak volumes of silver-rich chemical effluent produced by theprinter. The manufacturer/supplier of theelectrolytic unit can help the commercialimaging processor choose the appropriateequipment and provide preventivemaintenance information. Generallyelectrolytic unit are monitored for thefollowing: pH; silver concentration; sulfiteconcentration; time and amperage; and,mechanical operation. All of these arediscussed below.

a. pHFix solutions from commercial imagingprocesses are usually easy to desilverelectrolytically and require little, if any,pH adjustment.*

b. Silver concentrationThe concentration of silver in theoverflows from commercial imagingoperations will typically range fromapproximately 2,000 - 4,000 ppm prior toelectrolytic recovery.

Recovery efficiency is directly related tosilver concentration; the higher the silverconcentration, the higher the platingefficiency. Replenishment rates play an

important role in determining thisconcentration level. Over replenishmentdilutes the amount of silver. When silverconcentration falls below 500 mg/L,plating efficiency decreases significantlythus reducing the recovery rate of theelectrolytic unit.

It's very important to calibratereplenishment rates on the processorsroutinely.

c. Sulfite concentrationIn the plating process, for each atom ofsilver plated out of solution the processconsumes one atom of sulfite. It’snecessary, therefore, to have sufficientsulfite in the solution. This is particularlyimportant in in-line electrolytic silverrecovery where the fix solution iscontinually recirculated through theprocessing tank. Any degradation of thefixer can affect the final product. Checkwith the equipment manufacturer orchemical supplier to find out if you shouldbe using a fix with an increased level ofsulfite.

d. Time and amperageMany of the electrolytic silver recoveryunits sold today are automatic so theoperator doesn't have to set platingcurrent and batch times—two criticalfactors in electrolytic silver recovery. Thecorrect plating current must be maintainedto drive the silver out of solution onto thecathode. If the plating current is too highor the plating time too long, the silverdeposited on the cathode will be blackand sludgy, with much of it falling off thecathode and collecting on the bottom of

* It is highly recommended not to exceed a pH of 8.5.Above this level significant ammonia air emissions arereleased.

B.2 Proper Operation


43the electrolytic unit. This situation, knownas sulfiding, results in a low quality silverand a mess to clean. To avoid sulfiding,follow the manufacturer recommendationsfor setting both the plating time andamperage.

Attempts to achieve higher efficienciesthan those recommended by themanufacturer can actually lead to lowersilver recovery. By over extending theplating time or significantly raising thecurrent density, sulfiding will occur. Thisresults in coating the cathode with a blacksulfide precipitate rendering it unsuitablefor continued silver recovery.

e. Mechanical operationGeneral mechanical preventivemaintenance should be conductedperiodically to ensure the plating currentis correct, the cathode is rotating or thepump is working, and the color of thesilver on the cathode is creamy-grey ratherthan black or white. The silver should beharvested (removed from the cathode)periodically and sent to the refiner.

The most common mechanical problemwith electrolytic units is a poor electricalconnection to either the anode or thecathode. It is important that terminals andwires do not come in contact withsolutions. Corroded terminals or cableswill result in poor plating.

The person who is responsible for silverrecovery should follow all manufacturerrecommendations for preventivemaintenance and keep accurate recordsof any maintenance performed.

• Make sure you receive theoperations and maintenancemanuals for your silver recoveryequipment. These manuals are partof the purchase price of yourequipment and you are entitled tothem.

• Obtain data from the silverrecovery equipment manufacturer/supplier demonstrating theperformance capability of theequipment. For example, if you arerequired to recover silver to 99 percent efficiency, ask themanufacturer to provide you withdata showing the equipment canachieve this level.


44

Chemical replacement cartridges are arelatively low cost method of achieving afairly high level of silver recovery.

Metallic replacement is a process thatoccurs when a solution containingdissolved ions of an active metal such assilver, contact a more active solid metalsuch as iron. The more active metal, ironwhich is contained in a cartridge, reactswith the silver and dissolves in solution.The less active metal, silver, becomes asludge or solid and collects in thecartridge.

In essence, the dissolved silver in solutionchanges places with the solid iron in thecartridge. The exchange reaction isdependent on the contact of the silver-thiosulfate in solution with the ironsurface. To ensure good and controlledcontact, metallic replacement isaccomplished by metering the silver-richsolutions through a cartridge of iron. Assilver is removed from the solution, theiron metal filler in the cartridge becomesdepleted. The cartridge is then replacedwith a new cartridge and the accumulatedsilver sludge is sent to be refined.

A typical metallic replacement cartridgegenerally called a chemical recoverycartridge (CRC) is shown in the diagramon the right.

There are a variety of CRCs on the markettoday. They contain iron in the form ofchopped steel wool, spiral wound steelwool, a heavy iron mesh similar to doorscreening material, or iron chipsimbedded into a fiberglass support.

A properly designed and maintainedsingle-cartridge CRC system is capable ofrecovering more than 95 percent of thesilver from silver-rich solutions when usedin accordance with manufacturer specifiedflow rates. A two-cartridge system iscapable of recovering 99 percent of thesilver.

Where the flow of solution through thecartridge exceeds its rated capacity, flowcontrol must be used. While a meteringpump is generally recommended, inextremely low volume situations, a flowrestrictor may be adequate.

Appendix CChemical Recovery Cartridges

4/1/97

Chemical Recovery Cartridge

C.1 How it Works


45

The manufacturer/supplier of the CRC canhelp the photo processor choose theappropriate equipment. This is also thebest source of preventive maintenanceinformation. Generally chemical recoverycartridges are monitored for the following:flow rate; channeling; obstruction; pH;and, cartridge capacity.

a. Flow rateThe length of time the silver-rich solutionis in contact with the iron is critical foreffective silver recovery. If the solutionflows through the CRC too quickly, it willnot contact the steel wool long enough forthe iron/silver reaction to occur. The lowerthe flow rate, the better the recovery.

A pump or restricted orifice is used tometer the solution at a prescribed rate fromthe holding tank to the first CRC in theseries. To ensure proper flow rate, calibratethe metering pump each time the CRCs arereplaced. Consult the manufacturer for theoptimum flow rate.

b. ChannelingAs the recovery cartridge is used, theactive surface area is used up and smallchannels will begin to develop in the ironmaterial. This is known as channeling. Italso occurs when a CRC is used onlyintermittently due to low volume. When asmall volume of solution enters the CRCand sits on the surface, it slowly eatsthrough the steel wool, forming a verticalshaft or channel as it goes. As moresolution enters the CRC, it takes the pathof least resistance and flows through thechannel, thus contacting very little of thesteel wool in the cartridge. This causes

only a small amount of the iron to be used(that along the channel). When channelingoccurs, only low levels of silver arerecovered and high levels are dischargedfrom the CRC.

To avoid channeling: (1) select the propersize CRC for the average volume of filmand paper processed in your lab, and (2)prefill the CRC with water just prior tointroducing chemical solutions into it.

c. ObstructionWhen the iron in solution contacts air,iron hydroxide or rust forms. If the rust isallowed to build up in the lines leadinginto and out of the CRCs, it can eventuallyrestrict the flow of solution causing thesolution to back up. The CRC may alsoleak around the fittings and cover.

Obstruction also occurs when the centercore of the CRC is crushed or damagedand the solution cannot pass through it. Ifthis happens, replace the CRC with a newone. Consult the CRC supplier forinformation.

Finally, rust that passes through the CRCcan eventually build up in the floor drain,requiring expensive drain cleaning.

Monitor the system regularly forobstruction. Remove the lines and rinsethem with hot water each time the CRCsare replaced. Do this more often if thereare several hours each day when nosolution is flowing through the CRCs. Besure to run the overflow system downhillso there’s no chance of back-up.

To reduce the possibility of rust in thelines, make a loop in the line that willcreate an airlock.

C.2 Operation/Maintenance


46d. pHFor best results with CRCs, the pH shouldbe between 4.5 to 5.5. If the pH is toolow, the steel wool is etched too quicklyreducing the life of the CRC. If the pH ofthe solution is too high, etching does notoccur so the silver/iron exchange reactioncan't take place. Also, at higher pH levels,iron hydroxide (rust) is formed which cancause obstructions in the lines and drains.

Try to maintain a consistent pH in theinfluent going to the CRCs. This is bestaccomplished by plumbing the silver-richoverflow directly from the processors tothe silver recovery system. Typically thepH of commercial imaging fixers arebetween 4.5 and 6.5, and will not requirepH adjustment. Work with yourequipment supplier to determine the bestpH for your CRCs.

e. Cartridge capacityEach type of CRC has a limited capacity torecover silver depending on the type andamount of iron. Manufacturers generallyrate the capacity of their CRCs in bothgallons of solution and time. For example,depending on the silver concentration ofthe solution going in, a CRC might havethe capacity to desilver 100 gallons ofsolution or last 12 weeks, whichevercomes first. Ask the manufacturer to helpyou in selecting CRCs appropriate for yourlab.

Keeping a logKeep a silver recovery log to record all ofthe checks and testing you do on yoursilver recovery equipment. As soon as theweekly check (done with silver estimatingtest papers) shows color, you know thechemical recovery cartridge has failed andit’s time to change it. When you install a

The person who is responsible for silverrecovery should follow all manufacturerrecommendations for preventivemaintenance and keep accurate recordsof any maintenance performed.

• Make sure you receive theoperations and maintenancemanuals for your silver recoveryequipment. These manuals are partof the purchase price of yourequipment and you are entitled tothem.

• Obtain data from the silverrecovery equipment manufacturer/supplier demonstrating theperformance capability of theequipment. For example, if you arerequired to recover silver to 99 percent efficiency, ask themanufacturer to provide you withdata showing the equipment canachieve this level.

new CRC, mark the installation date on thecartridge.

Check with your local POTW authorities tofind out how long to keep these records onfile.

Blank silver recovery log forms areprovided in Appendix H. Make copies ofthese forms when you need them. Keep theoriginals in this Guide.


47

make sure you check with your state agencyfor its specific requirements.

a. Generator categoryIf you’re shipping off-site waste pre-pressprocessing solutions containing 5 ppm ormore of silver, it’s important that you knowhow to determine your hazardous wastecategory. This category is based on the totalamount of hazardous waste produced byyour company. The specific requirementsfor accumulation, storage, and manifestingvary depending on the category.

The chart on the next page shows thethree categories established in the federalResource Conservation and Recovery Act(RCRA). These categories, as shown acrossthe top of the chart, are:

• Conditionally exempt small quantity generator

• Small quantity generator

• Large quantity generator

To determine your category, track themonthly volume of hazardous wasteincluding waste processing solutionscontaining 5 ppm or more of silverproduced in your facility to be sent off-site.

For example, if you process film in severallocations within your facility and thesolutions are accumulated and taken off-site, add all the fixer produced in alllocations for one month. If it’s less than

The following information applies only tocommercial imaging operations that shipwaste off-site.

In some situations, off-site silver recoveryis the best option. For example:

• Commercial imaging operationsrequired to meet excessively restrictivesilver concentration limits may be forcedto ship the solutions off-site for treatment.

• If an imaging operation produces lessthan one gallon of silver-rich solution/day,a chemical recovery cartridge may oxidizeand channel long before the iron isexhausted. This may create more wastethan it prevents.

• For commercial imaging operationsdischarging to a septic tank and leachfield, there is no option; they must haul.Commercial imaging processingchemicals must not be discharged toseptic systems. This could cause an upsetthat would destroy the microorganismsresponsible for breaking down the wastewater.

Solutions containing 5 mg/L or greater of silverare currently classified as hazardous waste. Inorder to transport these solutions off-site, thefacility must fulfill the requirements fortransporting hazardous waste. In this section,we’re going to discuss the Federalrequirements for off-site silver recovery. Sinceindividual states may enact stricter regulations,

Appendix DOff-Site Management

F.1 Off-Site Requirements


48

100 kilograms (approximately 220 poundsor 25 gallons), your facility falls into thecategory of conditionally exempt smallquantity generator.

b. Generator identification numberSQGs and LQGs must obtain an EPAidentification number before shippingwaste off-site. This 12-character numberidentifies both your site where the waste isproduced and the type of waste. It’s a keyelement of tracking the waste from cradle-to-grave. Your state hazardous wasteagency can provide you with the properpaperwork.

In some states, CESQGs do not have toobtain an ID number.

c. Accumulation and storageCESQGs must never accumulate morethan 1000 kilograms (kg) of waste at anytime. (1000 kg is approximately 300gallons).

SQGs must never accumulate more than6000 kg of hazardous waste in any 180

day period. (6000 kg is approximately1600 gallons).

LQGs must not accumulate hazardouswaste on-site longer than 90 days.In all cases, wastes must be stored in tanksand containers suitable for commercialimaging processing waste. In addition:

• Clearly mark each container with thewords Hazardous Waste and with thedate you began to collect waste in thatcontainer.

• Use only containers in good condition.

• Keep containers closed except whenyou fill or empty them.

• Inspect areas where containers arestored, at least weekly, looking forleaks and deterioration.

• Provide secondary containment whereit’s required.

Hazardous Waste Category*

Conditionally Exempt Small Small Quantity Large QuantityQuantity Generator (CESQG) Generator (SQG) Generator (LQG)

* Any photo processing waste containing 5 ppm or more of silver is considered hazardous under the ResourceConservation and Recovery Act (RCRA). Most states and municipalities have additional regulations for discharge andtransport of silver and silver-bearing wastes. For more information contact your local state hazardous waste agency.

Facility that produces lessthan 100 kilograms permonth of hazardous waste

Facility that produces morethan 100 but less than 1,000kilograms per month ofhazardous waste

Facility that produces morethan 1,000 kilograms permonth of hazardous waste


49

d.Labels and marksContainers of silver-rich chemicals mustbe properly labeled and marked. The labelshown above contains the six requiredelements:

1. accumulation start date,

2. EPA waste identification number,

3. site name and address where the wastewas produced (generator name),

4. EPA generator identification number,

5. manifest number, and

6. Department of Transportation (DOT)shipping name for the waste.

e. ManifestsThe manifest is a multi-copy documentused to track the waste from the time itleaves the producer (the commercialimaging facility), to the time the receivertreats, recycles or disposes of it. Eachparty in the link—producer, transporter,receiver—have EPA identification numbersand each must complete its portion of themanifest.

The producer is responsible for obtainingnumbered manifest forms from the statehazardous waste agency. All links in thechain keep a copy of the manifest andreceive copies from the other links toacknowledge receipt of the waste.Manifests must be kept on file by theproducer for at least three years. Manifests are not required for CESQGs.Some transporters, however, may still askthey be used to help the transporter andreceiver fulfill their requirements.

f. Spill response and trainingSQGs and LQGs are required to developemergency plans and train employees onemergency response so that if a spill oraccident occurs, the facility is ready.Generally, the plans must includeprocedures and identify the necessary spillcontrol/response equipment.

One important element of the cradle-to-grave waste management system isliability. Once you’ve produced the waste,you retain some responsibility even afterturning it over to a licensed transporterand a licensed receiver. This means youmust choose your waste managementpartners carefully.

Talk with your colleagues, tradeassociations and state hazardous wasteagency to get the names of licensedcompanies that could handle silver-bearing processing wastes. Choose a firmwith a good reputation. Verify their EPAidentification numbers and any requiredpermits. Keep copies of their permits onfile. Visit their site to look at theirequipment and the general condition oftheir operation. Choose carefully and withconfidence.

F.2 Precautions

HAZARDOUS WASTEFederal Law Prohibits Improper Disposal

If found, contact the nearest police or public safety authority, or the U.S.Environmental Protection Agency

Accumulation Start Date: EPA Waste #:

Generator Name:

Address:

City: State: Zip Code:

EPA ID #: Manifest #:

DOT Proper Shipping Name, Class, UN#, and packing group:

Jan 12, 1997 D011

Mr. Opaque Pre-Press Ltd.

1500 Main Street

Your Town

XX9876543210 554332

NY 02143

RQ Hazardous waste liquid, n.o.s. (silver), Class 9, NA 3082, Packing group III


50

Evaporation and distillation are generallyused in conjunction with off-sitemanagement. These processes reduce thevolume of effluent to be taken off-site fortreatment and disposal. When the off-sitemanagement costs are based on thevolume of solution, evaporation anddistillation may help to reduce costs.

Because evaporation releases fumes to theair, permits are often required to operatean evaporator. Hazardous waste permitsmay be required. Most equipment usedtoday consists of both evaporation anddistillation where the water vapor isboiled-off, captured and condensed andthe fumes are contained.

In distillation, the liquid portion of theprocess overflow is heated to its boilingpoint. Then the vapors are captured andcooled resulting in a distillate ofessentially distilled water that can bedischarged to the drain or used to mixfixers. Since the distillate containsammonia and sulfite, using it to mixdevelopers is not generally recommended.

Depending upon the unit, 80 to 100percent of the water is removed leaving asilver-rich slurry or solid to be managedoff-site as a hazardous waste.

Routine cleaning of the evaporation ordistillation unit is the most importantpreventive maintenance operation. Driedchemistry and dust can easily accumulatereducing the performance of theequipment. Intake and overflow screensalong with air filters must be checked andcleaned periodically. The distillationchamber should be inspected andcleaned.

Appendix EEvaporation/Distillation

4/1/97

E.1 How it Works

E.2 Proper Operation

Evaporation/Distillation Unit


51

Ion exchange technology can be used torecover silver from dilute processingsolutions and wash waters. Keep silverlevels as low as possible in wash water bypreventive maintenance of the equipmentand monitoring replenishment rates.

Ion exchange is recommended for useonly to remove silver from some low-silversolutions (<1 percent ) such as washwater. It is not generally recommended foruse with fix solutions.

Ion exchange is a reversible exchange ofions between a solid (resin) and a liquid(water containing ionized salts). When ionexchange is used with low-silver solutions,the silver thiosulfate in solution is adsorbedto the resin in the column. Periodically,under a service contract, the column isremoved and the resin is rinsed with adilute sulfuric acid solution to decomposethe silver thiosulfate to silver sulfide, whichremains in the ion exchange column. Theresin is reused for many cycles and is thenincinerated to recover the silveraccumulated in it.

Ion exchange should not be used forrecovering silver directly from silver-richfix solution.

These concentrated thiosulfate solutionswill strip silver from the resin, and can

actually result in more silver beingdischarged from the resin column than ispresent in the feed solution. Ion exchange,therefore, lends itself only to the recoveryof silver from wash waters and diluteprocessing solutions. Typically, more than90 percent of the silver from wash waterscan be removed in a single-columnsystem. Two-columns used in series canprovide 99 percent silver removalefficiency.

Converting equipment to incorporate inline silver recovery greatly reduces thesilver content of the final wash water. Ionexchange technology is most effectivewhen used in conjunction with an in-linesilver recovery unit for the preceding fixersolution.

Appendix FIon Exchange

4/1/97

G.1 How it Works

desilveredsolution to drain

low silversolution in

outlet

Ion Exchange Column

G.2 Proper Operation


52Factors affecting the efficiency of ionexchange include:

• thiosulfate concentration, • flow rate, and • biological growth control.

a. Thiosulfate concentrationThe capacity of the resin to retain silver isvery dependent on the concentration ofthiosulfate in the influent. The higher thethiosulfate, the lower the capacity. That’swhy ion exchange is not recommended forrecovering silver from fix. These solutionsare high in thiosulfate.

If you operate under such severe dischargerestrictions that you must use ion exchangeto recover silver from silver-rich solutions,two steps are required:

1. desilver the silver-rich solutionsthrough an electrolytic unit, and

2. meter the desilvered solutions into thecollected wash water overflow at a ratenot exceeding their replenishment rate.

These procedures will reduce the silverconcentration prior to ion exchange andensure the thiosulfate levels are controlled.

b. Flow rateThe low-silver solutions must be meteredthrough the ion exchange columns at aprescribed rate in order to allow for theexchange between the silver and the resinto occur. Generally, this should neverexceed 1 bed volume of resin/minute.

c. Biological growth controlAlgae, bacteria and fungi grow quitereadily in ion exchange columns and feedon the dilute photographic processingchemicals. This growth causes twoproblems: 1) it forms a film on the resinbeads, thereby blocking the silverexchange reaction, and 2) it obstructs theflow of solution through the column.

To eliminate the problem of biologicalgrowth, the ion exchange column(s) mustbe flushed routinely with biocide.


53

You must routinely monitor your silverrecovery system to make sure it’soperating correctly. There are two differenttesting methods required: approximationsutilizing test papers are performedfrequently and exact analytical testing isperformed every three months, six monthsor annually, depending on the size of thecommercial imaging facility.

Silver estimating test papers are used toprovide only an approximation of howmuch silver is in a solution. The test stripsare coated with yellow cadmium sulfidethat forms brownish-black silver sulfidewhen it comes into contact with silverions. The higher the concentration ofsilver in solution, the greater amount ofbrownish-black silver sulfide will beformed. The color formed on the test stripafter it has been in solution, therefore,reflects the amount of silver contained inthat solution.

Generally, the procedure for using the teststrips is as follows:

1. Dip the test strip in the samplesolution for two (2) seconds so that thestrip is properly wetted.

2. Remove the test strip from solution,shake off any excess liquid, and placethe strip on a white card.

3. After about 15 seconds, compare thecolor on the moist test strip with thecolor key provided with the test strips.Find the color that most closelymatches. That is approximately theconcentration of silver in solution.

4. When evaluating a solution that hascolor, such as seasoned fixer, rinse thetest strip briefly under running watertoward the end of the 15-secondwaiting period. Take the color of thesolution into consideration whenyou’re making the comparison withthe color key.

A typical color key scale is shown below.As you can see from the scale of numbersranging from 0 to 10 g/L* (0 - 10,000mg/L), the silver readings are onlyapproximations of the actual silver insolution. Note that the lowest detectionpoint is .5g/L or 500mg/L (500 ppm).

The test strips are helpful in estimating theamount of silver in the solution exiting thesilver recovery system. Once the solutionhas gone through primary silver recovery,

Appendix GTesting for Silver

4/1/97

H.1 Silver Estimating Test Papers

* Silver estimating papers are generally scaled in grams perliter (g/L) rather than parts per million (ppm). Remember:mg/L and ppm are the same measurement.


54the concentration of silver should bebelow the 500 mg/L (ppm) mark. Since thelowest range on the silver estimating testpapers is 500 ppm, you should see nocolor change on the paper. These papersare only useful for finding majorproblems with the silver recovery system.

For example, if you are using chemicalrecovery cartridges, you are required totest the cartridge effluent using test stripsto determine the presence of silver. Theeffluent should be below 500 ppm andtherefore, not change the color of the teststrip. The only thing you’ve learned fromtesting the effluent with a test strip is thatthere are no major problems with thechemical recovery cartridges. A moreexacting measurement must be takenperiodically to verify the system is actuallyrecovering the percentage of silverrequired.

An exact analytical measurement isrequired to verify whether the silverrecovery system is achieving a specificpercentage recovery. Use an outsideanalytical laboratory to analyze thesolution samples.

Obtain a sample bottle from the analyticallaboratory, fill the bottle with a sample ofthe solution to be analyzed and bring thebottle to the laboratory. When they havefinished the procedure, the analyticallaboratory will provide the results of theanalysis.

Your best source of informationconcerning your sampling procedures andtechniques is the analytical lab that’sdoing your work. Work with them closelyto get your best results. Here are somegeneral considerations for sampling:

a. Sample containers• Obtain plastic containers from theanalytical laboratory. Don’t use glassbecause silver precipitates more easily onthe wall of a glass container.

• Make sure the laboratory knows thatyou are specifically testing for silver sothey provide you with the correct size andtype of container.

b. Sample preservation• Tell the analytical laboratory NOT touse a nitric acid preservative with thesample. Nitric acid precipitates the silverout of solution, thereby providing anartificially low silver reading.

• Return the sample to the analyticallaboratory as quickly as possible to avoidany change in the make-up of the sample.

c. Sampling methodology• Rinse the sample bottle with thesample once or twice before filling it foranalysis.

• Make sure that none of the equipmentyou are using to collect the sample hasbeen contaminated with another solutionor material.

d. Analytical test methodsThere are two methods the analyticallaboratory can use to detect silver in thesample:

1. Inductively coupled plasmaspectroscopy (ICP)

2. Atomic absorption (AA)

Either test will provide the same result.

H.2 Analytical Testing


55

Appendix HForms

4/1/97


56

4/1/97

SPILL CONTINGENCY PLANSpill Response Personnel

Name pager/phone

Name pager/phone

Name pager/phone

EnvironmentalEmergencyPhone (999) 999-9999 24 hours a day

7 days a week

EQUIPMENT REQUIRED

• Gloves • Bucket • Absorbent Materials• Apron • Mop • Neutralizing Materials• Goggles • Sponge

SPILL RESPONSE PROCEDURES

1. Put on gloves, goggles and an apron.

2. Contain the spill with a mop or absorbent materials available.

3. Check the appropriate material safety data sheet (MSDS) for specialhandling, ventilation, personal protection or other pertinent data.

4. Clean up the spill, as directed, using generous amounts of water.

5. Use the mop and sponge to clean the area thoroughly.

6. Package and label all contaminated absorbent materials for off-sitedisposal.

7. Notify the supervisor or manager that a spill has occurred.

8. (If required) Notify appropriate government agency that a spill hasoccurred.

* This plan will not meet the requirements in all states, including California.


57

4/1/97

Worksheet for Screening Options Date

Option:

1. What is the potential for reducing waste and providing other environmental benefits?

2. What is it going to cost in time and materials?

3. How much money will it save in time and materials?

4. How difficult is it to implement?


58

4/1/97

Pollution Prevention Plan Worksheet Date

Option or activity:

Implementation date:

Responsibility:

Record:

Pollution Prevention Plan Worksheet Date

Option or activity:

Implementation date:

Responsibility:

Record:


59

4/1/97

Worksheet for Evaluating P2 Date

Option:

1. Waste reduction results

2. Costs

3. Savings

Worksheet for Evaluating P2 Date

Option:

1. Waste reduction results

2. Costs

3. Savings


60

4/1/97

Processor Log FormProcessor Name (location) Fixer Volume Category % Silver Efficiency

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