RECYCLING PHOTO/X-RAY PROCESSING AND PRINTING WASTES
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Overview: | Disposal of spent photographic and
X-ray processing and printing solutions is expensive and difficult. The
wastes generated by these processes typically contain elevated
concentrations of heavy metals, organic compounds, and other toxic
constituents unacceptable for direct discharge to a sewer system. In
addition, as a result of the specialized characteristics of these
solutions, they generally have very little, if any, value other than for
their intended application. Various technologies are available that
can be applied to treat certain solutions prior to disposal and/or to
recover constituents of the waste streams that have value (e.g., silver
recovery from specific photographic process wastes).
Silver may cause a material to be classified as a RCRA hazardous waste by the Toxicity Characteristic Leaching Procedure (TCLP) (40 CFR 261.24). However, for a material to be a RCRA-hazardous waste, it must first fit the definition of a solid waste under RCRA (40 CFR 261). Per a July 16, 1990, letter from Sylvia Lowrance (EPA) to Ralph Eschborn, the EPA considers spent photographic solutions as "spent materials," which is a subcategory of solid wastes (40 CFR 261.2 [c], Table 1). Further interpretation is provided by a February 28, 1994, letter from Michael Shapiro (EPA) to Scott Donovan: "Provided that economically significant quantities of silver are reclaimed from the [spent] solution, [then] the generation, transport, and storage prior to reclamation of the solutions is not subject to the general RCRA Subtitle C requirements for recyclable materials... but rather a different set of regulatory requirements specified at 40 CFR Part 266 Subpart F [40 CFR 266.70]." In addition, "Under RCRA Subtitle C regulation [and 40 CFR 261.2 (c), Table 1.], characteristic sludges being reclaimed are not within the definition of solid waste." In summary, 40 CFR 266.70 states that persons who generate, transport, or store recyclable materials that are reclaimed to recover economically significant amounts of gold, silver, platinum, or any combination of these must apply for an EPA or EPA-approved state generator identification number, and must also use the EPA or EPA-approved state manifest system to document all off-site transportation of solutions destined for reclamation of precious metals. However, once reclaimed, the silver is exempt from all hazardous waste regulations. Also, if the resulting treated liquid does not exceed the RCRA toxicity characteristic limits for silver (5 mg/L) or any other TCLP compound, then it is considered to be a non-hazardous material. The DoD’s Precious Metal Recovery Program (PMRP) (DoD 4160.21-M) is a program that promotes the economic recovery of precious metals from excess and surplus precious metal-bearing materials, and also the reutilization of recovered fine precious metal for authorized internal purposes. The PRMP sets responsibilities, turn in and processing requirements, precious metal recovery equipment requirements, transportation requirements, security requirements and reutilization requirements. Under the PRMP, recovered silver is refined and placed in a depository account until its use is required for other DoD purposes. Various technologies are available for recovering/recycling materials from spent photographic and X-ray processing and printing waste solutions. The most concentrated silver-containing waste in film and image processing is spent or excess fixer bath solution. In a typical film developing operation, fixer solution is continuously added to maintain solution strength. As a result, the fixer typically overflows from the bath. The concentration of silver in the overflow may vary greatly depending on the type and amount of film processed, frequently exceeding 5 grams per liter. Because of this high silver concentration, silver recovery from the fixer solution is cost effective. When the film is moved from the fixer to the rinse, it carries a small amount of silver which is removed by the rinse water. Rinse waters contain low concentrations of silver, ranging from less than 1 milligram per liter (mg/l) to greater than 5 mg/l. Although little economic benefit is gained from recovering silver from rinse water, environmental regulations prohibit discharge of untreated rinse water if the silver concentration exceeds regulatory limits. Nearly all the silver in photographic wastes is bound up in silver thiosulfate complexes, which are highly stable. However, federal, state, and local regulations governing silver-containing wastes do not distinguish among different forms of silver. Several technology categories
are used for silver recovery, including precipitation, ion exchange,
reductive exchange, electrolytic recovery, reverse osmosis, and
electrodialysis. The specific technology to be applied for a particular
waste stream will be based on the waste characteristics, volume, and
treatment objectives. For example, if reduction of silver concentrations
to meet wastewater effluent limitations is the primary treatment
objective, then a technology which achieves extremely high silver recovery
from the waste stream is probably not a cost-effective application. On the
other hand, in cases where silver recovery is of primary importance, then
application of a highly efficient system, such as reverse osmosis or ion
exchange, makes sense. The following paragraphs provide brief descriptions
of various technologies used for treating silver-laden waste streams.
Although this discussion centers on the application of these technologies
for silver treatment and/or recovery, these technologies are also
effective in addressing additional waste constituents, as described
herein.
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Compliance Benefit: | Recycling spent solutions allows
generators to decrease the amount of hazardous waste regulations they must
comply with under 40 CFR 262. According to 40 CFR 266.70, persons
who generate, transport, or store recyclable materials that are reclaimed
to recover economically significant amounts of gold, silver, platinum, or
any combination of these (which includes spent solutions) are only subject
to the following requirements: apply for an EPA or EPA-approved state
generator identification number, and use the EPA or EPA-approved state
manifest system to document all off-site transportation of solutions
destined for reclamation of precious metals (40 CFR 262, Subpart
B). The recycling of spent solutions will also help facilities comply with
EO 13101, Greening the Government Through Waste Prevention, Recycling,
and Federal Acquisition.
The compliance benefits listed here are only meant to be used as general guidelines and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g., the amount of workload involved. | |||||||||||||||||||||
Materials Compatibility: | No material
compatibility issues were identified.
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Safety and Health: | These materials must be handled
with caution. Skin absorption is the main health concern. Chemicals like lead are experimental teratogens and carcinogens. Proper personal
protective equipment is highly recommended.
Consult your local industrial health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing this technology. | |||||||||||||||||||||
Benefits: |
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Disadvantages: |
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Economic Analysis: | Economics depends on site-specific
information including system characteristics, waste volumes and treatment
objectives. In general, the higher volume and the higher concentration of
the process solution being handled, the more cost-effective implementation
of a reuse/recovery system becomes. For low volume operations,
installation of a metallic replacement system is typically a cost-effective
alternative. Installation of an electrolytic recovery unit
becomes economical for higher processing volumes, since the capital
installation cost will be more than offset by the savings incurred from
fewer changeouts of metallic replacement cartridges. In-line electrolytic
recovery units will reduce silver refining costs since the collected
silver is in a form that is more readily recoverable. In cases where low
effluent silver concentrations are required, installation of an ion
exchange system may be necessary. However, the capital investment and
chemical handling costs associated with this method are higher than for
alternative technologies.
Wright-Patterson AFB, Ohio, indicated that it received a electrolytic silver recovery system and replacement cartridges at no cost through its DRMS in Columbus, Ohio. Using estimated costs provided by Peoria, Illinois, Air National Guard base the following analysis can be calculated. Assumptions:
Annual Operating Cost
Comparison for Recycling and Disposal of X-Ray Processing
Wastes Economic Analysis Summary:
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here to View an Active Spreadsheet for this Economic Analysis and
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NSN/MSDS: |
*There are multiple MSDSs for most NSNs. The MSDS (if shown above) is only meant to serve as an example. To return from the MSDS, click the Back arrow on the Tool Bar. | |||||||||||||||||||||
Approving Authority: | Appropriate
authority for making process changes should always be sought and
obtained prior to procuring or implementing any of the technology identified herein.
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Points of Contact: | For more information | |||||||||||||||||||||
Vendors: | This is not meant to be a complete list, as there may be
other suppliers of this type of equipment.
Eastman Kodak Company 5951 Clearwater Drive Minnetonka, MN 55343-8995 Phone: (952) 933-2277 Service: Ion Exchange Treatment AWS Industries 2825 W. 31st. St. Chicago, IL 60623 Phone: (888) 297-7470 Service: Silver Recovery Equipment Specialty Metals Refining Co. 1915 Black Rock Turnpike Dept. 10712 Fairfield, CT 06432 Phone: (203) 372-0481 FAX: (800) 426-2344 Service: Silver Refiners & Scrap Purchasers MRP Co., Inc. 10107 Marble Court Cockeysville, MD 21030 Phone: (410) 666-2775 FAX: (410) 666-2777 Service: Silver Refiners & Scrap Purchasers | Source(s): |
Mr. Jeff Hanna, New York Air National Guard, September 1998. Mr. Don Tam, Wright-Patterson AFB, September 1998. Mr. Terry Christie, DRMO, September 1998. |