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Alaska Health Project

WASTE REDUCTION ASSISTANCE PROGRAM (WRAP)

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ON-SITE CONSULTATION AUDIT REPORT:

PHOTOFINISHING SHOP

ALASKA HEALTH PROJECT 131 bi . 7th Ave., Suite 101 ANCHORAGE, 86. 99501

July 15, 198'7

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-417 West Eighth Avenue - P.O. Box 10-1037, Anchorage, Alaska 99510 - (907) 2762864- @!3iEB

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READERS NOTE :

T h e i n f o r m a t i o n c o n t a i n e d h e r e i n i s i n t e n d e d t o b e g e n e r a l g u i d a n c e f o r t h e f a c i l i t y d e s c r i b e d i n t h i s r e p o r t a n d t h e i n d u s t r y a s a w h o l e . I t i s t h e p r o d u c t o f a p p r o x i m a t e l y 6 t o 8 h o u r s o f o n - s i t e c o n s u l t a t i o n . T h e f o c u s o f t h e r e p o r t i s w a s t e m a n a g e m e n t a n d was te r e d u c t i o n , n o t r e g u l a t o r y c o m p l i a n c e . R e g u l a t o r y i s s u e s m e n t i o n e d h e r e i n a r e d i s c u s s e d o n l y i n s o f a r a s t h e y i m p i n g e o n m a n a g e m e n t i s s u e s r e l a t e d t o h a z a r d o u s waste m a n a g e m e n t a n d was te r e d u c t i o n , a n d a r e n o t p a r t of a c o m p r e h e n s i v e d i s c u s s i o n a b o u t a l l p e r t i n e n t r e g u l a t i o n r e q u i r e m e n t s . Waste d e t e r m i n a t i o n s were made f r o m a v a i l a b l e d a t a , n o o n - s i t e s a m p l i n g t o o k p l a c e . M a n a g e r s i n t e r e s t e d i n s p e c i f i c i n f o r m a t i o n o n h a z a r d o u s w a s t e r e g u l a t i o n s s h o u l d c o n t a c t t h e n e a r e s t EPA o r D e p a r t m e n t of E n v i r o n m e n t a l C o n s e r v a t i o n o f f i c e . Waste r e d u c t i o n m e a s u r e s a r e d e s c r i b e d b r i e f l y a n d s h o u l d b e f u r t h e r e v a l u a t e d a n d b a l a n c e d a g a i n s t u n i q u e c o n d i t i o n s of e a c h s p e c i f i c b u s i n e s s .

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Table of Contents

1 . Int, roduc t. ion 1

A I The haste Reduction Assistance Program (%RAP) 1 B. Audit Yethods 2

11. Plant br. Photofinishing Process Description 3

- 111. kiaste Generation 3

A . Waste Generation by Process B . Regulated bastes

- 3 7

IV. iv’aste Planagement 9

A . Waste Storage B . Waste Disposal FIethods C. cos ts

9 9

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V. Waste Generation Reduction Alternatives 13

A . Incentives 1 3 B. Waste Reduction Categories 13 C. Potential Waste Reductions in the Photofinishing 1 4

Industry D. Feasibility Study 15

VI. Summary and Conclusions 1 7

VII. Appendis 19

.4. Synopsis of the SQGs Regulations 19 B. Copy of EPA letter on project confidentiality 20

Industries 21 C. Table of Hazardous Wastes from Printing & Allied

I. Introduction

A. The Waste Reduction Assistance Program (WRAP).

In 1986, the United States Environmental Protection Aqency ( b S EP.4) awarded a R C R A 8001 grant to the Alaska Health Pro.ject, a private non-profit organization located in Anchorage, Alaska. The grant was awarded to develop and deliver a pilot project to assist Alaska’s Small Quantity Generators (SGQs) in complying with new Small Quantity Generator regulations. The project, the haste Reduction Assistance Program (WRAP) has two principal goals:

1 . To conduct outreach and education activities to support E P A ’ s Small Business Initiative to achieve Small Quan- tity- Generator compliance with new hazardous waste regulations.

2 . T o conduct on-site audits to investigate hazardous waste management practices and processes for specific SQG’s categories.

W2.4P on-site consultation audits are conducted with the un- derstanding that the identity of selected SQGs remain confiden- tial and that all audit reports contain no specific facility identifiers. Audit results and recommendations are intended to be widely applicable to other SQGs in Alaska. Audit reports are aLrailable to interested parties upon request.

This report is the product of conducting an environmental audit of an Alaskan photofinishing shop. The report goals are to:

1 ) Analyze a typical photofinishing shop in Alaska and publish the findings in a report.

2 ) Provide a format, by making available this report, to other photofinishing shops and businesses to conduct their own environmental audit.

3 ) Identify the hazardous wastes produced in the photofinishing shops and the processes by which they are generated.

4 ) Make recommendations, if appropriate, to reduce the amount of hazardous wastes generated.

5 ) Identify common waste management practices and advise on possible better methods to store and ship hazardous wastes .

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6 ) Analyze the cost benefits of the waste reduction methods recommended in this report.

A l l recommendations, information, and cost data are subject to change. They will not reflect future market conditions, regulatory climate, and changes in shop processes. This report offers only general guidance to other small quantity generators and all the information provided should be balanced against the unique conditions of each specific business.

B . Audit Methods.

The audit team consisted of an environmental scientist and an environmental health specialist. The audit comprised two main steps:

1 ) Interview and data collection. 2 ) Shop walkthrough.

Step one consisted of an interview with t h e shop manager. The interview was designed t o collect the following information:

1 ) General shop information (size, operation, etc.).

2 ) Shop processes.

3 ) Platerial safety data sheets.

4) Current waste management practices.

The interview was also designed to provide the shop manager with a detailed description of the audit process.

In step two, the audit team and the shop manager conducted a visual inspection of the shop operations and processes. The audit team identified the processes generating potential hazard- ous wastes and investigated current waste management practices.

The approximately 6 hours of on-site consultation included no environmental sampling or industrial hygiene monitoring. A l l the information provided in this report is based on the inter- view, the walkthrough, and a review of the current and available literature. Hazardous waste determinations were based upon a review of material safety and data sheets, any existing laboratory reports, and EPA literature. Waste volume figures are based upon estimates made by the generator and the audit. team during the shop walkthrough.

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11. Plant, & Photofinishing Processes Description

The photofinishing plant described in this report is con- sidered to be large b y Alaskan Standards. The plant has a sur- face area 9,500 square feet and it employs a staff of 9 to 1 5 . The processes performed in the plant are:

1 ) Black & White Negatives Developing

2 ) Black & White Pictures Printing

3 ) C o l o r Negatives Developing

4 ) C o l o r Pictures Printing

5 ) Slides Developing

6 1 Custom Work (Reproductions, Enlargements)

These processes are common to the photofinishing industry. It should be noted, however, that not all Alaskan photofinishing businesses are equipped to perform all the processes listed aboL7e. One hour photofinishing businesses, €or instance, may only be able to process color film on their premises.

Photof inishing involves the developing of negatives and their printing onto paper. Slides and custom work are also com- monly processed by the photofinishing businesses. Some photofinishing businesses also perform graphic work and plate making €or the printing industry.

Negative developing involves the use of a film developer, bleach, a film processor (fixer), and a stabilizer. The printing of the negatives onto paper also makes use of bleach and fixer.

The Black & White and the Custom Work processes are a small percentage of this business volume. Each process has its own development and printing apparatus.

All the chemicals used by the plant are stored on the premises. Open drums of chemicals are kept at the point of use. The business has a warehouse where new and used chemicals are kept. The making of chemicals, by mixing raw materials is per- formed in the warehouse, Silver recovery also takes place in the warehouse.

Spent chemicals are not stored for periods exceeding two weeks. The chemicals are either replenished, recycled, or dis- posed of in the municipal sewer system.

The plant i s in an expansion phase and will be able to handle greater volumes. Improvement in operations are also

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planned. Drums of spent chemicals will no longer be carried on a d o l l y from their point of generation to the warehouse but will instead be piped.

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1 1 1 . Waste Generation

A . Waste Generation by Process.

The wastes produced by each photofinishing process are described in this section. Table 111.1 shows the type and quan- tity of the wastes generated by each photof inishing operation. The type and quantity o f the wastes generated were determined from an interview with the business owner, available ?laterial Safety and Data Sheets (PISDS), and literature. No sampling was performed.

Black 8 White D eve 1 ope r Negatives Developing Fixer

Orb i t bath

Black 8 White Picture Printing

Color Negatives Developing

Color Pictures Printing

Developer Stop bath Fixer

Deve 1 oper Bleach Fix Stabilizer

Developer Bleach-Fix

1 . 7 gallons/month 1 . 5 gallons/month 1.5 gallons/month

10 gallons/month 5 gallons/month 10 gallons/month

7 . 5 gallons/month None (Regenerated) 9 . 7 gallons/month 4 . 3 gallons/month

28 gallons/month 3 4 . 4 gallons/month

Slides Developing Developer #1 2 gallons/month Reversal bath 1 gallon/month Color Developer 0 . 6 gallon/month Conditioner 1 gallon/month Bleach 0.2 gallon/month Fix 1 gallon/month Stabilizer 1 gallon/month

Black & White Negatives Developing

The developing of black & white negatives makes use of a developer, a fixer, and an orbit bath. Figure III.1 shows a flow diagram of the film developing process. Negative developing also generates scraps. The scraps are soaked in a spent fixer bath for 1-12 hours. The soaking removes the silver f rom the nega-

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tives. The fiser is then treated to recover its silver content. The stripped negatives are dried and disposed of in the trash.

Figure 111.1 - Black & White Negative Developing Steps

Black & White Printing

This business utilizes a developer, a stop-bath, and a fiser t.0 make b l a c k &! white prints. A l l of these chemicals are dis- posed of in the drain. Again, the silver in the fiser is recovered prior to disposing of the fiser. Figure 1 1 1 . 2 shows a flow diagram f o r the Black & White Picture printing process.

Figure 1 1 1 . 2 - Black & White Printing Steps

Color Negative Developing ( C 4 1 )

The developing of negatives involves the use of a developer, a bleach, a fixer, and a stabilizer. Used developer is disposed of in the drain. The bleach is replenished periodically. In ad- dition to being replenished the bleach is regenerated whenever a replenisher container is used. Bleach regeneration takes place in the plant’s storeroom. No bleach from this process is wasted at 811. B-leach losses are due to carry over by the negatives into the wash. The fixer is processed to recover its silver con- tent. The stabilizer is flushed down the drain. This process also generates negatives scraps. The scraps are treated in the same manner as the Black & White negative scraps. Figure 1 1 1 . 3 shows a flow diagram of the Color Negative Developing process.

Figure 111.3 - Color Negative Developing Steps ( C 4 1 )

Color Printing ( E P 2 )

The printing of the negative onto photographic paper requires the u s e of a developer and a bleach-fix. The bleach-fix is processed to recover its silver contents. The developer is

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disposed of i n the drain. The printing process also generates some waste paper which is disposed of in the trash. Figure 111.4 shows a flow diagram of the color printing process.

fDevel-: I Bleach I I I I

Paper - > I oper I - - : F i x f--lhash:-->Finished Print I I 1 I 1 I

1 1 I 1 I 1 --

Figure 1 1 1 . 4 - Color Printing Steps (EP2)

Slides Developing ( C 4 1 )

A l l the chemicals utilized in slide developing are disposed of the drain ~ i t h the exception of the fixer. The fixer is treated to recover its silver content.

_____ --

f :C'ondi- IDevel-f i :Reversal :Color Film - ? : oper I--lWashl--;Bath ;--IDeveloperl--ltioner I - - >

I 1 I 1 I 1 I 1 I I 1 I--*1-1 1- 1 1 - I 1 I

~

I I 1 1 1 I 1 I I I 1 I 1 1 1 I

-->:Bleachf--IFix:--I~ashf--~Stabilizer~-->Finished Slide I I 1 I 1 1 1 I I I 1 - 1 I I 1 I

Figure 1 1 1 . 5 - Negative Developing Processing Steps ( C 4 1 )

Custom Work (EP2)

Custom Work makes use of a developer, a bleach, and a fixer. The bleach and the developer are disposed of in the sewer and the the fixer is treated to recover i t s silver content. Figure 111.6 illustrate .the custom work process.

1 1 I 1Devel-: I 1 I

Paper - > I oper I - - I B l e a c h - F i x l - - I W a s h t - - > F i n i s h e d Print I I 1 I 1 I I I 1 I 1 I

Figure 111.6 - Custom Work Processing Steps (EP2)

In addition to the various developers and fixers described above, the business consumes a large amount of water. The average water consumption for the summer months is around 100,000 gallons per month. During the winter months consumption is less. T h e business volume is much larger during the summer.

B. Regulated Wastes

Table TII.2 gives a classification of the wastes produced by the printing shop. The photographic baths in accordance with L o -

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cal, State, and Federal regulations, can be disposed of in the sewer if their hazardous materials concentrations do not exceed certain limits. The baths without silver recovery may exceed the silver concentration limit set by the Anchorage Municipal Code, Title 26.50. The municipal code sets a concentration limit of 0.02 mg of silver per liter of wastewater. Other metals and physical characteristics of the Wastewater are also regulated. The municipal limitations, however, apply to the total discharge from a user, exclusive o f sanitary wastewater. To insure com- pliance with the municipal ordinance, the photofinishing shop’s wastewater should be periodically tested for heavy metals and other regulated parameters.

Photographic Photographic wastes Hazardous Wastes Wastes containing heavy metals /Hazardous Waste

Solution containing Cadmium, Chromium, Lead, and Cyanide

The properties of the wastes listed in Table 1 1 1 . 2 were es- tablished from the information furnished by the MSDS f o r the chemicals used at the photofinishing shop. The property of the wastes will. of course vary with the chemicals used. Consult A p - pendix C f o r a more general description of the wastes produced by the printing industry. Many of these wastes may be generated by the photofinishing industry.

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IV. Waste Management

A . Waste Storage

A small quantity generator may not store hazardous wastes in quantities greater than 13,200 pounds for longer than 180 days. The waste may be stored for 270 days if it has to be transported over 200 miles to a licensed hazardous waste facility. This case applies to Alaska, which has no approved hazardous waste disposal facility. Generators of less than 220 pounds per month of haz- ardous wastes are subject to the Small Quantity Generator Regula- tions if they store more than 2,200 pounds of hazardous wastes.

Hazardous vastes containers should be clearly labeled "hazardous wastes". The containers should also be marked with the date the collection of the wastes began. The containers should be kept in good condition, closed, and inspected once per week. The wastes, if ignitable or reactive, should be placed as far as possible from the storage's property line. The wastes may be treated on-site without a permit if:

a) They are treated within 180 days (in Alaska, 2 7 0 days).

b) The containers conform to the regulation described in the abo1.e paragraph.

c) Steps are taken to prepare for and prevent accidents as described in the Small Quantity Generator Regulations.

Precautions should be taken to prevent accidents involving the hazardous materials stored on site. The regulations for the storage of hazardous materials and wastes were written to prevent accidental spills, fires, explosions, and release to the environ- ment. The- operator of a site should develop a contingency plan to deal with an accidenl involving the hazardous wastes being stored.

B . Waste Disposal Methods

Photographic Wastes

The photographic wastes can be disposed of in the sewer if they satisfy the limitations set by the Local, State, and Federal regulations. It is important to stress that the nature of photographic wastes can greatly vary with the type of photographic chemicals used. There is a large variety of developers and fixers available with different chemical composi- tions. Photographic wastes can easily contain sufficient heavy metals concentrations to prohibit their discharge to the sewer system.

The shop generates approximately 4 5 gallons per week of a

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bleach-fix and fix mixture with an average silver content of 2 2 . 7 grams of silver/gallon. This business feels that it attains a silver recovery efficiency of 99.7%. This high efficiency is the manufacturer's advertised maximum efficiency for the recovery system used. This business takes great care in monitoring its recovery system and feels that it can attain maximum recovery ef- ficiency on a consistent basis. The silver remaining after treatment of the bleach-fix and fix mixture can be calculated as follows:

22.7 grams Ag .y 45 Gallons x 4 . 3 Weeks x 0 . 0 0 3 = 1 3 . 2 grams A g Gallon Week Month Month

Where A,P = Silver

The shop water consumption is approximately 100,000 gallons per month. For the purpose of this calculation it is assumed that all of the water consumed is disposed of as wastewater. The silver content of the wastewater is obtained as follows:

1 3 . 2 grams .A4 x 1000 mg x GalLon s Month = 0 . 0 3 mg AFT Month gm 3 . 7 8 5 L 100,000 G Liter

Where A g = Silver G = Gallons gm = Grams L = Liters mg = Yilligrams

The wastewater silver content is above the 0.02 mg/l limit set by the Anchorage Municipal Code. The bleach-fix/fix mixture, therefore, cannot be disposed of in the sewer. The bleach- fix/fix mixture should be tested to insure that it is not class- ified as a hazardous waste. If it is found to be a hazardous waste it should be disposed of as such. If it is not found to be a hazardous waste, this business should contact the municipal landfill to determine if the waste, once solidified, will be ac- cepted for disposal as solid waste.

In the event that the waste is found to be hazardous, this business would be classified as a small quantity generator. The 4 5 gallons/week, or 1 9 4 gallons/month, weigh approximately 1600 pounds and, therefore, would subject the shop to the Small Quan- tity Generator Regulations.

Generally, there are three acceptable disposal methods for hazardous wastes :

1 ) Disposal in a l'icensed hazardous waste landfill.

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2 ) Disposal in a authorized high-temperature incinerator.

3 ) Disposal to an authorized hazardous waste recycler.

None of these facilities are available in Alaska and all wastes must be transported to a disposal site approved by the E P A . T h e wastes must be shipped in containers and by haulers as prescribed by DOT. A hazardous waste hauler should be able to offer assistance in assuring adequate packaging. The packaging requirements are described in the DOT regulations ( 4 9 C F R Part 1 7 2 ) .

C. cos ts

T h e cost , of disposing hazardous wastes can vary with the follow- ing factors:

1 ) Quantity and nature of the wastes.

2 ) Transportation distance.

3 ) Variations in prices charged by the haulers and dis- posal facilities for the transportation and disposal of the hazardous wastes.

It may be advantageous to contact other generators of haz- ardous wastes to coordinate shipments and realize savings through bulk shipments. Kaste determinstion fees may be eliminated if future waste streams remain constant.

In Alaska, there are no E P A approved hazardous wastes management facilities. A 1 1 hazardous wastes, as defined by R C R A , must be shipped out-of-state to an approved facility. The cost of 3hipping the hazardous waste increases the disposal costs con- siderably.

Comprehensive disposal costs f o r a 55-gallon drum of hazard- ous waste generated in Alaska can cost rip to $ 1 , 3 9 0 . 0 0 (Glean Incorporated). See Table I V . l for a cost breakdown. This is a very generalized estimate which assumes incineration as the dis- posal method. If the waste is disposed of in a landfill or by recycling, costs may be reduced. A l s o , as noted previously the cost can vary depending upon the hauler and the disposal fac i 1 i ty .

The high disposal cost o f hazardous wastes should be taken . into consideration when purchasing raw materials and planning ex-

penditures. Production processes and methods should also be analyzed to identify means of minimizing the generation of haz- ardous wastes and thereby disposal c o s t s .

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Transportation $ 310.00

Disposal Site Profile (On site lab analysis)

s 2 0 0 . 0 0

Waste Acceptance $ 125.00

Incineration $ 580.00

Total Cost

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V. Waste Generation. Reduction Alternatives.

A. Incentives

A number of incentives exist to promote hazardous wastes reduction in the private sector. Waste reduction incentives include:

1) High Disposal Costs: Land Disposal restrictions outlined in the Hazardous and Solid Waste Amendments of 1981 limit the number of untreated wastes that can be disposed of on land, and impose stricter standards on surface impoundments and underground tanks. In addi- tion, hazardous xastes management facilities are scarce in the United States. These and other factors con- tribute to the high disposal costs of hazardous wastes.

2 ) Financial Liability: Generators of hazardous wastes incur l i a b i l i t , y of their wastes from the time they are prciduced to the time of their ultimate disposal. This is known as the cradle to grave concept. The liability includes pot-entia1 improper' handling by the wastes transporter and disposal facility. Generators also are liable for any future sudden releases of disposed wast,es. The generator may be required to pay for the entire clean-up of a spill and/or waste site. Gener- ating a smaller quantity of hazardous wastes translates into decreased financial liability.

3 ) Public Relations: Employing waste reduction tech- niques in a business can improve the public perception of the business. A favorable perception can result, in better community relations and possible financial gains.

B . Waste Reduction Categories

Waste reduction techniques can be grouped into the following broad categories:

1 ) Process Technologies: This involves the use of tech- nology to reduce process wastes. Silver recovery is a waste reduction technology used successfully by the photof inish ing indust.ry.

2 ) Plant Operations: This ,category involves alterations in plant, operations t o decrease hazardous wastes gener- ation. Better inventory control and efficient use o f raw materials are examples of plant operations changes that can be made to minimize hazardous wastes produc- tion. The use of a squeegee between photographic

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baths, to wipe excess liquid from the photographic material being developed, is an example of waste reduc- tion through plant, operation changes. hiping excess chemicals from the photographic material prolongs the Life o f the bath by decreasing contamination through carry-ocer from one bath t o another.

3) PLant Input. Changes: Another way to reduce hazardous wastes generation is t o utilize raw materials that will not become hazardous wastes during the production process.

4) In-Process Recycling: This process recycles potential hazardous riastes by channeling them back into the production process. Replenishing and regenerating bleach as an alternative to disposal is an example of recycling.

C. Potential Waste Reductions in the Photofinishing Industry

?lost photofinishing processes can generate hazardous riastes. The L-aste rediiction techniques described i n the previous section can be applied t.0 the photofinishing industry. The photofinish- ing shop in this audit could benefit from these techniques as f o l l 0 r ; s :

Process Technologies

Silver recovery is a widely used process technology. This technology is relatively simple to operate and requires a minimum amount of maintenance. Silver recovery is usually a profitable operation. In addition to the profits it generates, it also con- siderably reduces the hazardous properties of the plant's waste stream. Consult section Q of this chapter for a detailed process review and economic feasilility study.

Use of non-absorbent "twin-checks" to identify negatives is another example of process technology successfully used by this shop. The non-absorbent labels help decrease the amount of chemicals carried form one bath to another and therefore increase the life of the baths.

Counter-current washing is a process technology that may be beneficial to this shop. Counter-current washing describes the use of water, from previous washes, to first contact the film being developed. Fresh water contacts the film at the final rinse stage and is then used again for the first film rinse. T h i s technology reduces the amount. of water utilized. This shop's developing machines make use of a limited counter-current washing process. It. m a y not. be advantageous for t h i s shop to invest in a more sophisticated counter-current system because this shop's water supply is cheap and plentiful. In situations,

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however, where water is scarce and expensive, counter-current technology may offer economic and environmental advantages.

Plant Operations Changes Rr. Plant Input Changes

The photographic chemicals should be chosen for their per- formance and their chemical properties. If the photographic chemicals cont,ain, f o r example, heavy metals or trich- loroethylene, they are likely to become hazardous wastes. The cost of waste disposal should be taken into consideration when comparing purchasing costs.

This shop also makes use of fioating lids on bleach and developer containers. The floating lids help retard oxidation through contact with air. It was found that in general this shop is run in an efficient fashion. The chemicals are closely monitored and care is taken to co~serve raw materials. A better in\-entory c o n t r o l may p r o ~ - i d e more insights to the shop owner and the shop maintenance empLoyee as to where additional economies of raw materials ma?; be made.

In-Process Recycling

Reduction in photoprocessing chemicals use should also be studied. l l o s t photoprocessing chemicals can be regenerated by making use of replenishers, thereby, decreasing the amounts of wastes produced. The low photographic wastes figures, indicated for the photofinisher in this audit, are due to an extensive use of replenishers/regenerators.

At present this shop replenishes and regenerates its bleach. Technology- has been developed to recycle most developers and fixers. This shop may benefit from such technology. This photofinisher used to recycle their bleach-fix until the chemical necessary for regeneration became unavailable.

Another recycling technology that may benefit the shop, is the recycling of its wastewater. As described in this chapter,. this shop’s wastewater silver content is in violation of the An- chorage Municipal Code. A closed cycle system may enhance silver recovery and solve this shop’s waste disposal problem.

D. Process Review and Economic Feasibility of Silver Recovery

This photofinisher successfully recovers 95-98 % of the sil- ver present in the spent bleach-fix and various fixers. The sil- ver recoL‘ery system is composed of an electrolytic plating unit and H metallic replacement unit. The Bleach-Fix and Fix are mixed together in a 30:50 ratio. The mix is tested with silver sensitive paper to approximate its silver content. The length of

1 5

t h e e l e c t r o l y t i c t r e a t m e n t v a r i e s w i t h t h e s i l v e r c o n t e n t o f t h e m i s . Prior a p p r o x i m a t e k n o w l e d g e o f t h e s i l v e r c o n t e n t o f R l e a c h - F i x / F i x m i x i s n e c e s s a r y i n o r d e r t o s e t t h e t r e a t m e n t t i m e c o r r e c t l y a n d t o e n h a n c e t h e e f f i c i e n c y o f t h e p r o c e s s . T h e e l e c t r o l y t i c b a t h r e m o l - e s 90% o f t h e s i l v e r p r e s e n t i n t h e m i s . T h e m i s i s t h e n p a s s e d t h r o u g h a s e a l e d d r u m c o n t a i n i n g s t e e l w o o l . I n s i d e t h e d r u m , t h e s t e e l w o o l is r e p l a c e d b y t h e s i l v e r i n t h e m i s . T h i s me ta l l i c r e p l a c e m e n t r e m o v e s a n o t h e r 6 0 t o 90% o f t h e r e m a i n i n g s i l v e r . T h i s p h o t o f i n i s h e r a l w a y s f i l l s t h e s ea l ed drum w i t h fryer p r i o r t o u s i n g t h e d r u m . T h i s i s d o n e t o i n s u r e a n e v e n d i s t r i b u t i o n of t h e b l e a c h - f i x / f i x m i x t u r e when t h e d rum i s o n - l i n e , T h e s i l \ - e r r e c o v e r y s y s t e m i s es t imated t o remrJve 9 7 % o f t h e s i l v e r p r e s e n t i n t h e m i x . T h e 9 7 % f i g u r e , a l - t h o u g h l o w e r t h a n t h o s h o p ' s e s t ima ted r e c o v e r y e f f i c i e n c y , was c h o s e n t o p r o v i d e ? . h e r e a d e r 1 ; i t h a c o n s e r v a t i v e e c o n o m i c f e a s i b i l i t y s t u d y .

The s i lx -e r r e c o l - e r y u n i t c o s t s $8900 a n d r e q u i r e s 3 h o u r s p e r i ;eek o f a t t e n d a n c e . T h e s h o p r e c o v e r s o n t h e a v e r a g e 3 2 T r o y o u n c e s o f s i l v e r . 'This f i g u r e w a s o b t a i n e d b y e s t i m a t i n g t h a t t h e a \ . e r a g e b l e s c h - f i s / f i s mix r o n t a i n s 0 . 7 3 T r o y o u n c e s o f s i l - v p r p e r g a l l o n . T h e s h o p p r o c e s s e s 4 5 g a l l o n s pe r week of t h e b l e a c h - f i s / f i s m i s a n d r e c o v e r s o n t h e a v e r a g e 9 i % of t h e s i l - \-er. A t a n a v e r a g e p r i c e of 9 7 p e r T r o y o u n c e t h i s r e p r e s e n t s a n income o f $ 2 2 3 / w e e k . T h e cost - o f o p e r a t i n g t h e u n i t i s e s t - i m a t e d a t 3 h o u r s / w e e k s $ l n / h r o r S-LS/weelr. I n a d d i t i o n t h e s h o p p a y s $0.45/0z. f o r a sme l t e r t o process t h e r e c o v e r e d s i l v e r . T h e n e t i n c o m e t o t h e s h o p i s $ 1 6 5 / w e e k . T h i s f i g u r e w a s o b t a i n e d w i t h n u m b e r s r e f l e c t i v e o f t h e summer b u s i n e s s . T h e w i n t e r v o l u m e i s e s t i m a t e d , b y t h e s h o p o w n e r , t o be a r o u n d 3 2 % o f t h e s u m m e r v o l u m e . T h e i n c o m e f o r t h e y e a r i s e q u a l t o $ 1 6 5 x 1 7 s u m m e r k-eeks t S i 6 5 x 3 5 w i n t e r w e e k s x 0 . 3 2 o r $ 4 6 5 3 . T h i s r e p r e s e n t s a p?y-back p e r i o d o f 2 y e a r s .

T h e p r e s e n t s i l v e r r e c o v e r y s y s t e m does n o t r e c o v e r e n o u g h s i l v e r t o allow t h e s h o p t o d i s p o s e of t h e i r b l e a c h - f i x / f i x mix i n t h e s e w e r . T h e r e a r e r e c o v e r y s y s t e m s a v a i l a b l e t h a t w i l l r e m o v e s i l c - e r to l e v e l s b e l o w t h e p r e s e n t A n c h o r a g e M u n i c i p a l C o d e . I t be may a d v a n t a g e o u s f o r t h i s s h o p , t a k i n g i n t o a c c o u n t t h e c o s t o f p r o p e r l y d i s p o s i n g o f t h i s p o t e n t i a l l y h a z a r d o u s w a s t e , t o i n v e s t i n s u c h a s y s t e m .

16

V I . S u m m a r y & C o n c l u s i o n s

The quantity- of hazardous wastes generated, by the photofinisher described in this audit, was determined with infor- mation provided by the photofinisher at the time o f the audit. The photofinisher may, in actuality, generate hazardous wastes in quantities other than the one described in this report. Changes in processes and chemicals will affect, the amount of hazardous waste generated.

The photofinisher in this audit Gas found to generate be- tween 220 pounds and 2200 pounds of hazardous wastes per month. At present, the wastes are disposed of in the sewer along with the plant’s wastehater. Better silver recovery or proper storage and disposal of the hazardous wastes should be implemented to comply with the Small Quantity Generator Regulations.

In general, a photofinisher should carefully monitor the chemicals used in the various photofinishing processes and note the ingredients present in those chemicals. Periodical testing of the wastes should also be performed to identify the nature of the wastes produced.

The literature available and this audit point to the fact that there are many products and technologies available on the market today, which decrease the generation of hazardous wastes. This photofinisher already makes use of several techniques to conserve raw materials and to reclaim wastes.

To further minimize the generation of hazardous wastes, this photofinisher and other photofinishers should:

a) E-xplore the possibility of bleach-fix and fix recy- cling.

b) Consider utilizing additional silver recovery technol- o g y to possibly eliminate the generation of hazardous wastes.

c 1 Have the bleach-f ix/f ix mixture analyzed to determine if it i s a hazardous waste.

d) Implement recycling of the bleach-fix/fix mixture and additional silver recovery.- The shop should dispose of the bleach-fix/fix mixture as a hazardous waste if it is found to be hazardous. The bleach-fis/fix mixture may he disposed o f as a solid waste if the waste is not hazardous. The municipal solid waste services should be consulted to determine a proper method, if any, to dispose of the bleach-fix/fix mixture as a solid waste.

1 7

c ) Provide training programs to workers to insure e f f i - cient u s e of raw materials.

11) D e v e l o p an inventory control to monitor more closely the quantity of raw materials used.

In general, conduct,ing periodic environmental audits can prove to be an excellent tool to decrease the hazardous wastes generated and to improve overall plant efficiency.

18

. -

Appendix A

Synopsis of the Small Quantit_v Generators Regulat.ions

Facilities producing between 220 and 2200 pounds of hazard- ous wastes per month are subject to the Small Quantiy Generator regulations. These regulations will require waste producing fa c i 1 i t y to :

1 ) Identify the hazardous wastes produced.

2) Obtain an EPX identification number.

3 ) Ship hazardous wastes for treatment, storage, or dis- posal in El?-\ approved facilities. The shipment wili have to meet the requirements set by the Federal Department o f Transportation for hazardous wastes. In addition the shipment will have to be accompanied by a manifr.st2 containing the generator’s name and address, the shippers name, and the name and address of the receiving facility.

4 ) The hazardous wastes should be offered, at least every 180 days, to shippers and disposal facilities with an EP-\ identification number. In Alaska, because there are n o EPA certified hazardous waste disposal sites within 200 miles, the wastes can be stored for 2 7 0 days. The maximum weight o f the rGastes being stored, however, cannot exceed 13,200 pounds.

5 ) Finally, the waste generator should keep a copy of the shipping manifest f o r three years.

19

REmr ro M/S 530

APPENDIX B U.S. ENVIRONMENTAL PROTECTION AGENCY

REGION 10 1200 SIXTH AVENUE

SEATTLE. WASHINGTON 98101

David Wi gg1 esworth Alaska Health Project 417 W E i g h t h Avenue Anchorage, A1 aska 99501

Dear Mr. Wi gg1 esworth:

Alaska Health Project 's small quantity generator study. project i s t o study general waste management procedures and processes f o r specific small quantity generator categories. We hope t o identify comon current waste practices tha t can be be t t e r managed, and/or methods where waste generation can be minimized.

applicable t o other generators as possible, we would l ike t o obtain information which characterizes the representative generators you are studying. Me do not feel any fac i l i ty -spec i f ic i d e n t i f i e r s w i l l be necessary, but we would l ike any information on the f a c i l i t y type, process, size of operation, and/or any other information which would have bearing on the usefulness o r extrapolation of the data t o other generators, both i n and outside of A1 aska.

:/7.&.c 6.y' . / T h i s i s i n reply to your question regarding information required by the

The purpose of this

Because we wish the study resu l t s and recomendations t o be a s widely

I f you have further questions, please feel f r e e t o contact me.

Sincerely ,

RCRA Program Development

Pnnting and Ahed Industnes U

APPENDIX C

Your fin I> included in Printing and .+llied Industncs i f i t i s inrolbcd in.

lhandr b typeserring b Lithography b Lmerpress b Cnvurc b Engraving tlt3tiOnCryJ

)hllrl

Phococngnving

b Huuet Lihgraphy b Non Heatset Lithography

b q e n o s n p h y b Business Fonn Printing

Sheetfed Lithography Lnrerprcts Pnnting (including flerography) Gnvurc Pnnting

b Screen R r s Pnnting

b h l c a i Binder Manufacturers b Tnde Binding Operations b Book Binding Opcraiions b In Houx Binding Operations b Magazine and Cualog Binding Operations

w u u . However. i f you use ignitable I t l u h point 4 IM'FI solvents. smng acidr alkaline solutions. paint or ink containing solvenu or heavy metals 1 in concentrations greater rhan the EP Toxiciry levels) or both. the wastes you gcnerrtc may k hyardous. I f so, you may k subject to new RCSOUKC Consmarion and Recovery Act [RCRAI provisions conccming the generatan and transponation of huudous wastes. Table 1 lists t y p i d ptocesseGopentions in the pnnttng and allied induitries whrch could produce hazardous wastes.

Wsm-

Not 111 printing or allied industry operations pmducc hanrdou~

WARDWS WASTES FROM PRINTING An0 U E D lOWTRlES

bnl ing p c r i t c c w i s t e ink 3nd ink A~Cipe% thJl ma: .iiwain w~vents and somerimes heavy metal, The wmpuviiun ~ i r ink\ used in pnniing and Jllicd mdustne% vane5 yrcitl? depcndinj 8111 whcthcr an ink i i to bt used rur Iiihugnph?. lecterprc\\. Srabure. flerognphy. or screen printins. Oil-based or paste ink\ are gencnlly composed 01' colorant of pigments icJrbon blacL. inorganic. and organici. varnish [drying oils. JLyd. rc\in- m l i c . rcsin-ester,. dncr icobrlt. mmpanese. or rircwwum fany acid compoundsi. sometimes an mender. \ol\enc\ and modifien iwaxcs. pcirolcum wlvents. 3nd mmynesiai Fluid ink\ contain a vehicle compnscd of resin and SOIV~IU or oil. and additives such u waxes. dncr 3nd wetrins ;rgcncs While nor d l YUIC inks and ink sludges wi l l k hazardous. tho\e containing solvents or heavy mcralr gcncrAly sre.

Photognphic processes arc used in ~ 1 1 of the malor printing opnuons for image conversion and plate-making. Phuiopiphis wastes. therefore. c o m p n x a large ponion of the hazardous genenied in ihcie industnes. Photojnphrc pmccssing soluriuns. dcvelopcn. hardenen. plating chemicals. lbuntain wlutions. or fixing baths that ~lr: rent to publicly-ouned treatment uorkr (POPWS) for disposal. however. arc cwmpt irom new IRCRAI requirements. Silver-containing sulutionr that pass through elccUolyUc. chemical replacement. or iun cxchmmpe r i l b c r

recovery units located on your premise. are similarly eqcmpt. However. i f you send your w s r e s off-rite for recycling 1i.c.. \ilvcr movery or solvent recovery, the wastes muzt k accompanied b) a ManifcJt.

If your business produces 220 pounds or more of hazardous waste per month. you are rquired to use a Uniform Hrurdous Waste Manifmt when you ship such wasres un your premises. Item 1 I on the %ianiicst requires the 0cp;lnment of Transpanxion (DOT) shipping descnption: the proper DOT shipping name. b u d class. and UWNA idcntific;rliun number This information i s provided in Table 2. I f you do nor find >our waste listed here. but suspect it may k humlour. plc;rw c'ontxt your sure hazardous waste management agcnc) for dditiunal UsisranCC.

k d pluing bath

Spnc salvents

S p n c mlrcntr

Wmc ink wrch d u e n o r chmmiumr kdbaf lum ink sludges rich chrwn- iumi leldr barium

Spent plating v w c

O R W E

0R.U.A

WII~C Ethyl Alcohol

WLIlC I ~ p r n o l

Wahtc Ethyl Benzene

Wale I . I . I .Trichlomthan

Flrmmrblc Lyuid

Flammable Liquid

Flammrble Lquid

0U.U-A

l w a n o l . lsapmpyl rlcuhol

Ethyl knzem

I .I . I .Trrh lomthan Aemhane lT. Chlonen. Inhibid. Trichlor- 0clh .n~ Chlomthcn N U NC1€0&526. Heihvlchlorofwm Chlomhcne LC. Chlomtlum NU OllomreN

0u.H-A .-by- Chbrid.

Combustible c N 2167 Liquid' FlammaOle Liquid CNl?lO

WUIC Ink Waste Ink

ORM-A

Cmouve Mlcenal

OIldlXer

C-cve .H.tcnal

Camire Yumal

Jrlluric Acia SUI~U~C wid. Oil of Vitriol. HZSO.

C u n n ~ Yucnal Cbmk Acid C h m u uid

MY-E

Flammable Lqud cIwnavui0lc L y u J FIam"e Sold