United States 

Environmental Protection 

Agency

Solid Waste and

Emergency Response

(5305W)

EPA530-K-99-002

January 1999

www.epa.gov/osw

INFOCUS

■ REGULATORY

REVIEW

■ REDUCING

RISK FROM

PHOTO PROCESSING

SOLUTIONS

■ RESOURCES

FOR THE

PHOTO PROCESSING

INDUSTRY

PHOTO PROCESSING
DRAFT: DO NOT CITE OR QUOTE.

CONTENTS

Foreword 1

Frequently Asked Questions About RCRA 2

The Life Cycle of a Typical Photo Processing Waste 6

Requirements for Regulated Photo Processors 8

Silver Recovery Methods 10

Reduce or Minimize the Hazardous Wastes You Generate 12

Other Environmental Laws Affecting the Photo Processing Industry 14

Contacts and Resources 16

FOR MORE INFORMATION CALL:

RCRA Hotline

U. S. Environmental Protection Agency

800 424-9346 or TDD 800 553-7672.

In the Washington, DC, area: 

703 412-9810 or TDD 703 412-3323.
Foreword

I

f you are a photo processor, your business probably generates

hazardous waste. That means you must follow regulations issued

by the Environmental Protection Agency (EPA or the Agency)

under a law called the Resource Conservation and Recovery Act

(RCRA). Under RCRA, you are required to follow certain practices and procedures associated with the safe management of hazardous

waste. RCRA in Focus provides an overview of the basic federal regulations covering wastes that are likely to be hazardous in your business. It

also provides recycling and pollution prevention options to help businesses decrease the amount of hazardous waste they produce.

EPA acknowledges the photo processing industry for taking steps to

practice and foster pollution prevention for silver-bearing wastes. This

industry continually works to control silver discharges from photographic

processing plants. Photo processors have developed a voluntary Code of

Management Practice for Silver Discharge, which provides a cleaner, cheaper,

and smarter means of promoting environmental performance by

enhancing silver recovery by processors of photographic materials, in

firms of all types and sizes. These management systems could decrease

the amount of silver released to the environment and increase silver

recycling and reuse. Employing these practices, however, does not relieve

photo processors from their RCRA regulatory obligations.

EPA currently is assessing the risks associated with the management of

silver-bearing wastes. The data from the study will provide the basis for

determining whether silver needs to remain a RCRA-regulated

hazardous waste. If the study determines that silver poses minimal risks

to human health and the environment, EPA will initiate the process to

change current regulations. While the Agency is assessing the RCRA

regulatory status of silver-bearing wastes, wastes that meet the Toxicity

Characteristic must be managed as hazardous waste.

PHOTO PROCESSING 1

FOREWORD
Frequently

What Is RCR

RCRA is a federal law that encourages environmentally sound methods for managing

A? Asked

commercial and industrial waste as well as household and municipal waste. It regulates facilities that

generate, transport, treat, store, or dispose of hazardous waste. The vast majority of photo processors

are considered hazardous waste generators, rather than treatment, storage, and disposal facilities

(TSDFs), which are subject to more rigorous regulations.

The term “RCRA” is often used interchangeably to refer to the law, the regulations, and EPA

policy and guidance. The law describes the waste management program mandated by Congress that

gave EPA authority to develop the RCRA program. EPA regulations carry out the Congressional

intent by providing explicit, legally enforceable requirements for waste management. EPA guidance

documents and policy directives clarify issues related to the implementation of the regulations.

All of the RCRA hazardous waste regulations can be found in the Code of Federal Regulations

(CFR), Title 40, Parts 260 to 279. The CFR can be accessed at <www.access.gpo.gov/nara> or

purchased through the U.S. Government Printing Office (GPO).

Who Is Regulated?

Any photo processor who generates waste is potentially subject to RCRA hazardous waste

requirements. You must conduct tests required by the regulations or use your knowledge of and

familiarity with the waste you generate to determine whether it is hazardous waste (as opposed to

other types of waste). You might be subject to substantial civil and criminal penalties if you fail to

properly or completely identify hazardous waste generated by your business.

What Is Hazardous Waste?

To be considered hazardous waste, a material first must be classified as a solid waste. EPA defines

solid waste as garbage, refuse, sludge, or other discarded material (including solids, semisolids,

liquids, and contained gaseous materials). If your waste is considered solid waste, you must then

determine if it is hazardous waste. Wastes are defined as hazardous by EPA if they are specifically

named on one of four lists of hazardous wastes (listed wastes) or if they exhibit one of four

characteristics (characteristic wastes). Each type of RCRA hazardous waste is given a unique

hazardous waste code using the letters D, F, K, P, or U and three digits (e.g., D001, F005, P039).

See pages 8 to 10 for additional information on photo processing waste.

Listed Wastes. Wastes are listed as hazardous because they are known to be harmful to human health

and the environment when not managed properly, regardless of their concentrations. Photo processing

labs do not typically generate listed wastes. The lists include the following three types of waste:

■ Non-Specific Source Wastes. These are material-specific wastes, such as solvents, generated

by several different industries. Waste codes range from F001 to F039.

■ Specific Source Wastes. These are wastes from specifically identified industries. Waste codes

range from K001 to K161.

■ Discarded Commercial Chemical Products. Off-specification products, container residuals,

spill residue runoff, or active ingredients that have spilled or are unused and that have been, or

are intended to be, discarded. Waste codes for acutely hazardous chemicals are P001 to P205.

Waste codes for toxic chemicals are U001 to U411.

Characteristic Wastes. Even if your waste does not appear on one of the hazardous waste lists, it still

might be regulated as hazardous waste if it exhibits one or more of the following characteristics.

2 RCRA IN FOCUS

FREQUENTLY ASKED QUESTIONS

ABOUT RCRA

STATE 

REQUIREMENTS

You may be regulated both by your

state hazardous waste

agency and EPA. RCRA

allows states to receive

legal permission, known

as authorization, to

implement the RCRA

hazardous waste program.

You must always contact

your state authority to

determine which state

requirements apply to

your business. 

To operate a hazardous

waste program, a state’s

regulations must be consistent with, and at least

as stringent as, the federal program. Some states

adopt more stringent

requirements for facilities handling hazardous

waste, which are considered part of the authorized program. 

MORE 

QUESTIONS?

Call the RCRA

Hotline at 800

424-9346 or TDD 800

553-7672 for additional

information about RCRA

rules and regulations. 

In the Washington, DC,

area, call 703 412-9810

or TDD 703 412-3323.
Questions y

Hazardous wastes generated during photo processing are typically hazardous wastes due to the

toxicity characteristic. A typical photo processor’s waste is hazardous because of silver only. 

■ Ignitability. Ignitable wastes create fires under certain conditions or are spontaneously

combustible, and have a flash point less than 60 °C (140 °F). Examples in the photo processing

industry include wastes oils and used solvents. The waste code for these materials is D001.

■ Corrosivity. Corrosive wastes are acids or bases that are capable of corroding metal containers,

such as storage tanks, drums, and barrels. Examples include chromium compounds generated by

Kodachrome color reversal films that use ferricyanide. The waste code for these materials is D002.

■ Reactivity. Reactive wastes are unstable under “normal” conditions. They can cause explosions,

toxic fumes, gases, or vapors when mixed with water. Examples include lithium-sulfur batteries

and explosives. The waste code for these materials is D003.

■ Toxicity. Toxic wastes are harmful or fatal when ingested or absorbed. When toxic wastes are

disposed of on land, contaminated liquid may drain (leach) from the waste and pollute ground

water. Toxicity is defined through a laboratory procedure called the Toxicity Characteristic

Leaching Procedure (TLCP). The waste codes for these materials range from D004 to D039.

Silver (D011) contained in films, papers, and silver-rich solutions is generated during film

processing.

How Are Generators Regulated?

If your business generates hazardous waste, you must manage it according to the regulations for

your specific generator type. Hazardous waste generators are divided into three categories, according

to how much they generate in a calendar month:

■ Large Quantity Generators (LQGs). LQGs generate greater than or equal to 1,000 kg

(approximately 2,200 lbs) of hazardous waste per month, or greater than 1 kg (approximately 2.2

lbs) of acutely hazardous waste per month.

■ Small Quantity Generators (SQGs). SQGs generate greater than 100 kg (approximately 220

lbs) but less than 1,000 kg of hazardous waste per month.

■ Conditionally Exempt Small Quantity Generators (CESQGs). CESQGs generate less than

or equal to 100 kg of hazardous waste per month, and less than or equal to 1 kg of acutely

hazardous waste per month.

Some states do not recognize the CESQG class. Contact your state environmental agency to find

out if the CESQG status is recognized. To find your appropriate state contact, call the RCRA

Hotline at 800 424-9346.

Under the federal RCRA requirements, your generator status might change from one month to

the next as the quantity of the waste you generate changes. You must comply with whichever

standard is applicable for a given month. In many cases, small businesses that fall into different

generator categories at different times choose to always satisfy the more stringent requirements

(usually state requirements) to simplify compliance. Generators must “count” the amount of waste

generated during a calendar month, which involves adding up the total weight of all quantities of

characteristic and listed waste generated at a particular facility. Certain wastes, such as those that are

reclaimed or recycled continuously on site, are not counted under the federal regulations. 

PHOTO PROCESSING 3

AM I REGULATE

BY RCRA OR

SUPERFUND?

RCRA regulates 

treatment, stora

and disposal of hazard

waste being generated

now and in the future

Superfund was create

pay for the identificat

inspection, investigati

ranking, and cleanup 

abandoned or uncontrolled sites where ha

ardous substances we

disposed of, and wher

the people responsibl

contamination are un

or unwilling to clean 

Call the RCRA Hotli

for more information
RCRA IN FOCUS

Frequently Asked

4

Hazardous wastes generated by a photo processing facility, for instance, may be regulated

differently depending upon how the wastes are managed. For example: 

■ If a spent characteristic photographic fixer waste is stored on site and then reclaimed, it must be

managed as a hazardous waste and counted towards the facility’s generator status. The

reclamation process itself is exempt from regulation.

■ If the spent characteristic photographic fixer waste is directly reclaimed without prior storage, the

waste is not counted towards the facility’s generator status. The reclamation process itself is

exempt from regulation.

■ If the waste is destined for precious metals recovery (i.e., recovery of economically significant

amounts of precious metals) then reduced standards for the generators, transporters, and storers

of these materials apply.

Also, the reclamation of photographic fixer of photo processing wastewater may generate a

characteristic sludge that contains silver. If this sludge is sent for reclamation, it is not a solid waste

and thus, is not regulated as a hazardous waste. If the sludge is sent for disposal, it is subject to

hazardous waste requirements.

Do Exclusions Exist?

The RCRA regulations contain many exclusions for wastes and waste management practices that

are not considered to be hazardous. Several exclusions and exemptions pertain to the photo processing industry.

Exclusions and Exemptions

Characteristic Sludge

Exclusion

“Closed Loop Recycling”

Exclusion

Description

A secondary material that meets the definition of sludge and

exhibits a characteristic of hazardous waste is not considered

a hazardous waste when it is reclaimed. (This includes silver

recovery residuals such as silver-flake, spent metallic replacement cartridges, precipitation sludges, and spent ion

exchange resins being sent off site for silver reclamation.)

Some secondary materials that are returned to the process or

processes in which they were generated are excluded from

the definition of solid waste.
y

PHOTO PROCESSING 5

Questions

Exclusions and Exemptions

Domestic Sewage

Exclusion

Precious Metals Exemption

Wastewater Treatment Unit

Exemption 

Description

Mixtures of domestic sewage and other wastes that pass

through a sewer system to a POTW for treatment are

excluded from the definition of a solid waste. Generators are

encouraged to contact their local POTW for prior approval

and any pretreatment requirements.

Recyclable materials from which precious metals are recovered are exempt from full hazardous waste regulation. These

materials are subject to administrative requirements only,

including obtaining an EPA identification number, complying with recordkeeping requirements, using a manifest when

shipping materials off site, and complying with land disposal

restrictions notification requirements.

Any hazardous waste tank system that is used to store or treat

the wastewater that is managed at an onsite wastewater treatment

facility with a Clean Water Act permit, or that discharges to a

POTW, is exempt from the RCRA regulations.
6 RCRA IN FOCUS

7 

111213

6 

1 2 

You've just processed a large job and are left with silver-bearing spent fixer and washwater (D011) hazardous waste that must be managed according to

RCRA. You generate a small quantity of this type of waste

each month. To comply with local pretreatment limits, you

have decided to recover your silver on site. You evaluate the

merits of each recovery unit, which include: the initial capital cost, operating and maintenance costs, and the ability of

the unit to recover the highest percentage of silver based on

the types of wastewater received.

This example details one typical waste life cycle at a

photo processing business and illustrates the most common

scenario of activities you would conduct as an environmental manager. Other life cycles could apply depending on the

waste, whether on site treatment will occur, the type of

waste management units used, and your generator status.

See page 4 for information about exemptions.

THE LIFE CYCLE

OF A TYPICAL

PHOTO PROCESSING

WASTE

IDENTIFY WASTE

By running tests or using

your knowledge of the waste,

identify whether the waste is

hazardous. Based on these

analyses, you determine that

the waste is hazardous due to

its toxicity characteristic (silver.) Keep all records of test

results, waste analyses, and

other determinations made

in the hazardous waste identification process for 3 years.

COUNT WASTE

As a second step, determine the

amount of waste generated in th

calendar month. Count spent ch

acteristic photographic fixer was

that is stored on site, even if it i

destined for reclamation. Do no

count waste placed directly into

exempt recycling units. If the w

streams contaminated with silve

placed directly into a silver reco

unit, the initial waste stream is n

regulated and not counted. The

characteristic sludge removed fr

the recovery unit is excluded fro

the definition of solid waste, as 

as the sludge will be reclaimed.

Spent fixer that is sent off site fo

reclamation is not exempt from 

ardous waste regulation. Only c

sludge that is to be sent for treat

ment or disposal.

COMPLY WITH RECORDKEEPING REQUIREMENTS

Since you are storing recyclable

materials, keep records to

document that you are not

accumulating such materials

speculatively. A material is not

accumulated speculatively if

you can show that the material

is potentially recyclable and

has a feasible means of being

recycled and that 75 percent

of accumulated materials is

recycled annually. 

IMPLEMENT SQG

PREPAREDNESS AND

PREVENTION REQUIREMEN

You ensure that emergency preparedness and prevention requi

ments are met. These include a

quate emergency response syste

and notification to local emerge

response authorities.

CONTRACT WITH

HAZARDOUS WASTE

TRANSPORTER

To send waste off site to a

treatment, storage, or disposal

facility, contract with a registered hazardous waste transporter. A common carrier can

be used to send silver-bearing

materials (sludges, precipitate,

and ion-exchange resins) to a

refiner that are not classified as

a hazardous waste.

PREPARE HAZARDOUS

WASTE MANIFEST

Send a manifest along with all h

ardous waste sent off site to a tr

ment, storage and disposal facil

(TSDF). Keep copies of all man

fests for 3 years. The manifest c

tains a certification statement th

you have made a good faith effo

to minimize waste generation a

select the best waste manageme

method available to an SQG th

an SQG can afford.

FOLLOW U.S.

DEPARTMENT OF

TRANSPORTATION

(DOT) PACKAGING

STANDARDS

Before shipping waste off

site for treatment, storage, or

disposal, package, label, and

mark waste containers in

accordance with all applicable DOT requirements.

Photo processing produces several silverbearing waste streams,

ranging from less than

5 milligrams per liter

(mg/l) to 12,000 mg/l of

silver. The silver concentration depends primarily upon two factors: (1) the stage from

which the wastes originate and (2) the type of

film being processed.

The predominant

sources of recoverable

silver are from the

photo processing

solutions and spent

rinse water. The silver

in these two waste

streams exists predominantly as soluble silverthiosulfate complex

with small amounts of

silver sulfide. 
PHOTO PROCESSING 7

8 9 10

14 15

3 4 5 DETERMINE GENERATOR

STATUS

Based on waste counting, determine

your generator status. In this case, you

have produced between 100 and 1,000

kg/month, which means you are an

SQG.

OBTAIN EPA IDENTIFICATION

NUMBER

To identify your business as a hazardous

waste generator, obtain an EPA identification number by submitting Form 8700-12

(Notification of Regulated Waste

Activity), which can be obtained from

your state hazardous waste agency.

Remember, your state requirements

might be different.

ACCUMULATE SILVER-CONTAINING

WASTES PRIOR TO RECOVERY 

Place counted hazardous waste, such as

spent characteristic fixer that is stored on

site and characteristic sludge that is destined for disposal, in RCRA accumulation units (tanks or containers compatible with the waste). You are not required

to store materials that contain economically significant amounts of precious

metals (in this case silver) in RCRA-regulated management units. EPA provided

a partial exemption for wastes containing

precious metals because the agency

assumes that these materials will be managed carefully due to their economic

value. Not all states may recognize the

reduced regulatory requirements for precious metals waste. 

PREPARE CONTINGENCY

PROCEDURES 

SQGs must assign a facility emergency coordinator, who is often the

facility owner. The coordinator’s

responsibility is simply to be on site

or on call at all times and be prepared

with contingency procedures.

IMPLEMENT PERSONNEL TRAINING

Ensure that all employees are thoroughly

familiar with proper waste handling and

emergency procedures relevant to their

responsibilities.

RECOVER SILVER

FROM DIFFERENT

WASTE STREAMS

(See page 10)

SEND WASTE OFF SITE FOR

TREATMENT, STORAGE, OR

DISPOSAL

Using your registered hazardous waste

transporter, send the waste to a hazardous waste TSDF accompanied by the

appropriate manifest and LDR notifications and certifications. Generators can

send hazardous waste to certain permitted or interim status TSDFs that can

accept your type of waste.

PREPARE APPROPRIATE LAND

DISPOSAL RESTRICTIONS

NOTIFICATION AND

CERTIFICATION FORMS

Ensure that all hazardous waste sent

off site for treatment, storage, or disposal is accompanied by appropriate

Land Disposal Restrictions (LDR) program notifications and certifications.

(See page 9 for a description of LDRs).
REQUIREMENTS FOR REGULATED PHOTO PROCESSO

The following table presents an overview of the federal RCRA regulatory requirements for photo processors that are either LQGs, SQGs, or CESQG

have different or more stringent requirements. 

RCRA REGULATORY REQUIREMENTS

IMPLEMENTATION EXPLANATION

REGULATORYREQUIREMENT LQGS SQGS CESQGS

EPA IdentificationNumberHazardous WasteIdentificationWaste CountingAccumulation AreaOther AccumulationAreas (Time andQuantity Limits)Requirements forRecyclable MaterialsUsed for PreciousMetal RecoveryAccumulation UnitRequirementsPreparedness andPrevention

✓ ✓✓ ✓ ✓✓ ✓ ✓✓ ✓✓ ✓ ✓✓ ✓✓ ✓✓ ✓

• Obtain an EPA identification number for each facility within your company. EPA and states use this 12-character 

ardous waste activities.

• Obtain an EPA identification number by submitting form 8700-12 (Notification of Regulated Waste Activity), which 

waste agency. This is a one-time notification. Contact your state regarding the need for renotification if circumsta

• Identify whether you generate hazardous waste to determine if you are subject to the RCRA hazardous waste reg

described in “Test Methods for The Evaluation of Solid Waste, Physical/Chemical Methods, SW-846” or tests can 

• Determine how much hazardous waste you generate to determine your generator status.• You can accumulate waste in a “satellite accumulation area” with minimal regulatory burden. This area must be a

under the control of the operator of the process generating the waste.

• There is no time limit on accumulation in the satellite accumulation area for waste under 55 gallons.• There is a 55-gallon accumulation limit in the satellite accumulation area. Excess waste beyond the 55-gallon lim

accumulation area within 3 days.

• You must accumulate the waste in containers.

• Waste containers must be marked with the words “Hazardous Waste” or other words that identify their contents.• This waste is exempt from other accumulation provisions while in the satellite accumulation area.• If waste accumulation does not meet the requirements for satellite accumulation, it is subject to more stringent re

waste on site for up to 90 days without a permit. SQGs can accumulate waste for 180 days, or 270 days if the SQthan 200 miles to a designated facility.

• Begin counting accumulation time when waste is first placed in the accumulation unit.• Waste must be put in an exempt unit, recycled, or sent off site within the proper time period stated above.• If an LQG accumulates wastes beyond the allotted time period, the facility is fully subject to the requirements of a 

unless granted an exemption. SQGs cannot accumulate more than 6,000 kg of hazardous waste at any time.

• CESQGs cannot accumulate more than 1,000 kg of hazardous waste, more than 1 kg of acutely hazardous wast

acutely hazardous waste at any time.

• Exempt from all RCRA standards except obtaining an EPA identification number, manifesting all waste off site, m

with LDR notification requirements. 

• Accumulate waste only in units that are in good condition, remain closed except when adding or removing waste

compatible with the types of waste, and meet special standards for ignitable waste and reactive waste. 

• LQGs can use accumulation tanks and containers that have been assessed for integrity, have a secondary conta

each operating day. SQGs can use certain accumulation tanks.

• LQGs can use containment buildings.• For all units, the date that the accumulation period begins must be clearly marked and visible on each container. 

clearly marked or labeled with the words “Hazardous Waste” and accumulation units must be shut down and closstandards at the end of the unit life.

• LQGs and SQGs can treat their waste without a RCRA storage permit in accumulation units that meet standards• LQGs and SQGs must comply with preparedness and prevention requirements, including the following:

- An adequate internal alarm or communications system.- A device capable of summoning emergency personnel.- Portable fire control equipment.- Adequate water pressure to operate fire control systems.- Adequate testing and maintenance of all emergency systems.- Access to communication or alarm systems during waste handling activities.- Adequate aisle space for emergency response.
Preparedness and

PreventionContingency PlanPersonnel TrainingDOT PackagingOffsite Managementof WasteOnsite Managementof WasteManifestLand DisposalRestrictionsNotificationHazardous WasteMinimizationBiennial ReportRecordkeeping

✓ ✓✓ ✓✓ ✓✓ ✓ ✓✓ ✓ ✓

✓

✓ ✓✓ ✓✓ ✓✓✓ ✓

LQGs and SQGs must comply with preparedness and prevention requirements, including the following:- An adequate internal alarm or communications system.- A device capable of summoning emergency personnel.- Portable fire control equipment.- Adequate water pressure to operate fire control systems.- Adequate testing and maintenance of all emergency systems.- Access to communication or alarm systems during waste handling activities.- Adequate aisle space for emergency response.- An arrangement with local emergency response authorities.

• LQG facilities must prepare a facility contingency plan in accordance with regulations.• The contingency plan must be designed to minimize hazards from fires, explosions, or any unplanned release of 

• A copy of the contingency plan must be kept on site and an additional copy must be submitted to all local emerge

• LQGs and SQGs must have an emergency coordinator on site or on call at all times to respond to emergencies.• Emergency response information must be posted next to the telephone.• In the event of a fire, explosion, or release that could threaten human health outside the facility or when a spill ha

gency coordinator must notify the National Response Center at 800 424-8802.

• LQGs must have a personnel training program in accordance with regulatory standards.

- Training must instruct facility personnel about hazardous waste management procedures and emergency re- Training must be completed within 6 months from the applicability of requirements.- The facility must undertake an annual review of initial training.

• SQGs must ensure that all employees are thoroughly familiar with proper waste handling and emergency proced

• Before being transported, waste must be packaged, labeled, and marked in accordance with applicable DOT req

materials information line at 202 366-4488 for information.

• Hazardous waste sent off site for handling may only be sent to a hazardous waste TSDF or recycling facility unle

• CESQGs: See onsite management of waste below.

• CESQGs may either treat waste on site, if the generator qualifies as one of the following types of facilities, or ens

following types of facilities: permitted RCRA TSDF; interim status TSDF; state authorized to handle hazardous w

tered by state to handle municipal solid waste according to standards; permitted, licensed, or registered by state managed after January 12, 1998, facility is permitted, licensed, or registered by state to handle nonhazardous wafacility beneficially uses or reuses, or legitimately recycles or reclaims its waste; facility treats its waste prior to berecycling or reclamation; or a universal waste handler in accordance with standards.

• Hazardous waste sent off site must be accompanied by a manifest, a multipage form that documents the waste's 

age, and disposal. It can be obtained from your state agency.

• The manifest must have enough copies to provide the generator, each transporter, and the destination facility wit

second copy to be returned to the generator after completion by the designated facility operator.

• SQGs that have a contractual agreement with a waste reclaimer that specifies the types and frequencies of shipm

wastes if they retain a copy of the agreement in their files.

• Your waste must meet certain treatment standards under the LDR program. Waste must be treated to reduce the 

by EPA or the waste must be treated using a specified technology. All waste sent off site for treatment, storage, 

by appropriate LDR program notifications and certifications. There are no required forms but these papers mumeet treatment standards or whether the waste is excluded from the definition of hazardous or solid waste, or 

• To encourage generators to produce less hazardous waste, LQGs are required to have a program in place to red

waste generated to the degree economically practicable, and must select a currently available treatment, storagepresent and future threats.

• LQGs and SQGs must sign a certification of hazardous waste minimization on the manifest.• SQGs must make a good faith effort to minimize waste generation and to select the best available waste manage

• LQGs must submit biennial reports of waste generation and management activity by March 1 of every even-num

and the public use this information to track trends in hazardous waste management.

• LQGs must maintain personnel training records until the facility closes.• LQGs must keep copies of each biennial report for 3 years.• LQGs and SQGs must keep LDR notifications for 3 years.• LQGs and SQGs must keep a copy of each manifest for 3 years.• LQGs and SQGs must keep records of test results, waste analyses, and other hazardous waste determinations f
10 RCRA IN FOCUS

Silver Recovery 

SILVER RECOVERY

METHODS

Silver Recovery From Fixers

The most common methods of silver recovery from fixer and bleach fix processing

solutions are metal replacement, electrolytic recovery, and chemical precipitation.

For low-silver wash waters, ion exchange is used. Reverse osmosis, distillation, and

evaporation are used to concentrate silver in dilute solutions. Some facilities use a

primary silver recovery unit, which removes the bulk of silver, in combination with

a tailing unit to treat the relatively low silver concentration wastewaters from a primary silver recovery system. Color developer wastewater does not flow through a silver recovery unit because the silver content is very low and the pH of the developer, if mixed with the other silver-bearing solutions, could reduce the efficiency of silver recovery and could result in ammonia generation.

Regardless of the technique used for silver recovery, the silver-bearing material must be sent to a

refiner to complete the process. In addition, photographic films and papers may also be a source of

silver from photo processing facilities. They also will require refining.

METALLIC REPLACEMENT

Metallic replacement occurs when an active solid metal, such as iron, contacts a solution containing dissolved ions of a less active metal, such as silver. The more active metal goes into solution

as an ion, being replaced by an atom of the less active metal in the solid matrix. The dissolved silver,

which is present in the form of a thiosulfate complex, reacts with the solid metal.

Silver ions will displace many of the common metals from their solid state. Because of its economy and convenience, iron, in the form of steel wool, is used most often. 

ELECTROLYTIC RECOVERY

An electrolytic unit can be used for a primary or a tailing waste stream, and can be either batch

or continuous. This silver recovery method applies a direct current across two electrodes in a silverbearing solution. Metallic silver deposits on the cathode. Sulfite and thiosulfate become oxidized at

the anode. An electrolytic system should recover about 90 percent of the recoverable silver.

BATCH ELECTROLYTIC RECOVERY

In batch recovery, overflow fixer from one or more process lines is collected in a tank. When

sufficient volume is reached, the waste fixer is pumped to an electrolytic cell for silver recovery. The

desilvered fixer can be discharged to a sewer, disposed of as a solid waste, or reused. If reused, it is

transferred to a mix tank where sodium thiosulfate is added to replenish its strength.

Primary batch system cells are usually designed to desilver the fixing batch at initial silver concentrations of about 5,000 mg/L. The silver concentration in the effluent is typically 200 to 500

mg/L. Effluent of 20 to 50 mg/L is possible with additional treatment time and careful current density control. An electrolytic tailing unit typically achieves the lower range because the process can be

optimized for low initial silver concentrations.

CHEMICAL PRECIPITATION

Chemical precipitation is the oldest and cheapest method for recovery of silver. It is widely used

by manufacturers of photographic supplies but usually not by photo processors. Photo processors
PHOTO PROCESSING 11

Methods

no longer use precipitation technologies based on sulfide, borohydride, or amine borate due to the

hazards associated with their use. Alternative precipitants currently in use do not generate hydrogen

sulfide gas. Sludges resulting from the alternative precipitants do not have to be managed as hazardous waste. They are characteristic sludges for silver and, therefore, are not solid waste when

reclaimed.

Silver Recovery From Rinsewater

Even with an efficient fixer solution silver recovery system and an effective squeegee on the fixer

tank, up to 10 percent of the recoverable silver is lost by carry-over into the rinse tank. The silver

concentration in the spent rinsewater is typically in the range of 1 to 50 mg/L, too low for economical recovery with electrolytic or metallic replacement methods. In addition, the iron byproduct from

metallic replacement precludes reuse of the rinsewater, although some photo processors use metallic

replacement to meet municipal sewer effluent limits. Precipitation is uneconomical for rinsewater.

Two methods are currently being used for effective recovery of silver from rinsewater: resin ion

exchange and reverse osmosis.

ION EXCHANGE

Ion exchange is the reversible exchange of ions between a solid resin and a liquid. A variety of

weak and strong anionic resins are effective in silver recovery. Ion exchange has been shown to be

very effective, recovering as much as 98 percent of the silver and achieving effluents with silver concentrations as low as 0.1 ppm. High capacity units can process as much as 500 gallons per hour.

REVERSE OSMOSIS

Photo processors may employ a concentration process such as reverse osmosis (RO), distillation,

or evaporation prior to silver recovery. In reverse osmosis techniques, the wastewater stream flows

under pressure over the surface of a selectively permeable membrane. Water molecules pass through

the membrane and other constituents are left behind. The extent of separation is determined by

membrane surface chemistry and pore size, fluid pressure, and wastewater characteristics. The RO

unit has one inlet to receive the waste stream, and two discharge outlets. The process reportedly can

recover 90 percent of the silver thiosulfate. 

Shipping Silver-Bearing Materials

High purity flake silver from electrolyte silver recovery units is considered a product by EPA and

is not regulated as a hazardous waste under RCRA when sent for refining. Silver-bearing sludge,

precipitate, and ion-exchange resins that are destined for refining are considered characteristic

sludges being reclaimed and are not regulated as a hazardous waste under RCRA. If these silverbearing materials are not sent for refining, they must be classified as a hazardous waste if they contain leachable silver. The Toxicity Characteristic Leaching Procedure (TCLP) can be used to determine if the material is hazardous. If the material leaches more than 5 parts per million (ppm) of silver, it is classified as a hazardous waste for silver under RCRA.
Minimize Wastes

Recycling and pollution prevention measures can significantly reduce your regulatory

burden and may save your business considerable money. This section presents

information on hazardous wastes typically generated by photo processing businesses

and provides suggestions for how to recycle them or implement pollution prevention measures. This list might not cover all chemicals used or wastes produced by

the photo processing industry. Consult the hazardous waste lists and characteristics to determine

if you generate other hazardous wastes.

Only the federal hazardous waste codes are provided here. Your state might have different

codes for some waste streams. You should check with your state hazardous waste authority for

additional waste codes and requirements.

12 RCRA IN FOCUS

REDUCE OR MINIMIZE THE

HAZARDOUS WASTES YOU GENERATE

Silver (D011)

■ Recover silver through metallic replacement, electrolytic recovery, or precipitation.

■ Send silver recovery residuals to a silver refiner via commercial recycler or common 

carrier (in states that allow it).

■ Ship silver waste, using a registered hazardous waste transporter, to a hazardous waste

TSDF for treatment and disposal.

■ Discharge spent fixers (within allowable discharge limits) to a sewer system pursuant to

a Clean Water Act permit. 

■ Follow manufacturers recommendations for pH levels and stop bath use.

■ Replenish the strength of the fixer by adding ammonium thiosulfate when necessary.

■ Keep fixer covered when not being used to prevent oxidation and minimize emissions.

■ Use floating covers on solution tanks.

■ Add ammonium thiosulfate to silver contaminated baths to extend the allowable buildup

of silver.

Washing

Silver (D011)

■ Recover silver through ion exchanges.

■ Send silver recovery residuals to a silver refiner via commercial recycler or common carrier (in states that allow it).

■ Ship silver waste, using a registered hazardous waste transporter, to a hazardous waste

TSDF for treatment and disposal.

PROCESS

RCRA Waste

Generated

Potential Recycling,

Treatment, and

Disposal Methods

Potential Pollution

Prevention Methods

PROCESS

RCRA Waste

Generated

Potential Recycling,

Treatment, and

Disposal Methods

The following

examples show

hazardous wastes

typically generated

by the photo processing industry and provide suggestions for

how to recycle, treat,

or dispose of them

according to federal

regulations. 

Processing and Developing Negatives and Prints

(including bleach-fix, untreated fixers, bleach-fixers, reversal bleaches

used in plumbingless minilabs, reversal bleaches, and system cleaners) 
PHOTO PROCESSING 13

Potential Pollution

Prevention Methods

PROCESS

RCRA Waste

Generated 

Potential Recycling,

Treatment, and

Disposal Methods

Potential Pollution

Prevention Methods

PROCESS

RCRA Waste

Generated 

Potential Recycling,

Treatment, and

Disposal Methods

Potential Pollution

Prevention Methods

PROCESS

RCRA Waste

Generated 

Potential Recycling,

Treatment, and

Disposal Methods

Potential Pollution

Prevention Methods

■ Discharge post-fix wastewaters (within allowable discharge limits) to a sewer system

pursuant a to Clean Water Act permit.

■ Improve the efficiency of the wash bath by keeping the water at 80 °F, add ammonia to

keep pH above 4.9, and add washing aids (salts). (Adding ammonia to adjust pH can

result in local noncompliance for ammonia nitrogen pretreatment discharge limits.)

■ If an ion exchange system is used, recirculate the effluent from the unit.

■ Employ countercurrent (using water from previous rinsings in initial film washing stage)

rather than parallel rinse techniques.

■ Collect wash water and reuse.

Stabilizing

Silver (D011)

■ Recover silver through metallic replacement, electrolytic recovery, precipitation, or 

evaporation.

■ Send silver recovery residuals to a silver refiner via commercial recycler or common carrier (in states that allow it).

■ Ship silver waste, using a registered hazardous waste transporter, to a hazardous waste

TSDF for treatment and disposal. 

■ Use floating covers on solution tanks.

■ Use squeegees to minimize chemical carryover.

System Cleaning

Acid regenerants, system cleaners, and photographic activators (D002), dichromate based

cleaners (D007)

■ Neutralize waste and discharge it to a sewer system pursuant to a Clean Water Act permit.

■ Send waste to a hazardous waste TSDF for neutralization and/or disposal.

■ Collect cleaners and reuse them.

Storing Products 

Off-specification chemicals that are RCRA hazardous for corrosivity (D002) or ignitability (D001) 

■ Dispose of hazardous off-specification chemicals by sending them to a hazardous waste

TSDF.

■ Recycle unused commercial chemical products.

■ Exercise inventory control to avoid disposal of off-specification film and chemicals.

■ Store unused chemicals and paper away from heat and light.
14 RCRA IN FOCUS

Laws 

OTHER ENVIRONMENTAL LAWS

AFFECTING THE PHOTO

PROCESSING INDUSTRY

THE CLEAN WATER ACT

The Water Pollution Control Act, commonly known as the Clean Water Act (CWA), is the federal

program designed to restore and maintain the integrity of the nation’s surface waters. CWA controls

direct discharges to surface waters (e.g., through a pipe) from industrial processes or stormwater systems associated with an industrial activity. It also regulates indirect discharges, or discharges to publicly owned treatment works (POTWs) through a public sewer system, by requiring industrial facilities to pretreat their waste before discharging to a public sewer. A serious concern with wastewater

discharges from photo processing labs is the high level of silver contained in photographic fixer solutions and rinsewaters. These solutions will not meet wastewater treatment plant discharge limits

unless the silver is removed. 

CWA Resources:

■ 40 CFR Parts 100 to 129 and 400 to 503

■ EPA Office of Water home page: <www.epa.gov/OW>

■ EPA Office of Water: 202 260-5700

■ Your state water authority, regional EPA office, and local POTW

COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND

LIABILITY ACT (CERCLA OR SUPERFUND) 

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of

1980, commonly known as Superfund, authorizes EPA to respond to releases, or threatened releases, of hazardous substances that might endanger public health, welfare, or the environment, that

might come from any source. Superfund also grants EPA the authority to force parties responsible

for environmental contamination to clean it up or to reimburse response costs incurred by EPA.

The person in charge at your business must report to the National Response Center (phone: 800

424-8802) any release of a hazardous substance that exceeds a designated “reportable quantity” for

that substance within a 24-hour period.

Superfund Resources:

■ Internet access: <www.epa.gov/superfund>

THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT 

The Superfund Amendments and Reauthorization Act (SARA) of 1986 created the Emergency

Planning and Community Right-to-Know Act (EPCRA). This law was designed to improve community access to information about potential chemical hazards and to facilitate the development of

chemical emergency response plans by state and local governments. The EPCRA regulations establish several types of reporting obligations for facilities that store or manage specified chemicals.

Photo processors are likely to use some of the following extremely hazardous substances: ammonia,

formaldehyde, hydroquinone, and nitric acid.

EPCRA Resources:

■ 40 CFR Parts 350 to 372

■ The State Emergency Response Commission (contact available from RCRA Hotline)

■ Internet access: <www.epa.gov/opptintr/tri/index.htm> and <www.epa.gov/swercepp>

CFR GUIDE TO

HAZARDOUS

WASTE

REGULATIONS

To review the

RCRA regulations

referred to in this document, consult the following citations in 

40 CFR:

Part 260—Hazardous

waste management system: general.

Part 261—Identification

and listing of hazardous

waste.

Part 262—Standards

applicable to generators

of hazardous waste.

Part 263—Standards

applicable to transporters

of hazardous waste.

Part 264—Standards for

owners and operators of

hazardous waste and

specific types of hazardous waste management facilities.

Part 265—Interim status

standards for owners and

operators of hazardous

waste TSDFs.

Part 266—Standards for

the management of specific hazardous wastes

and specific types of

hazardous waste management facilities.

continued
PHOTO PROCESSING 15

Laws Affecting Photo P SAFE DRINKING W

The Safe Drinking W

ATER A

ater Act (SD

CT 

WA) mandates that EP rocessing A establish regulations to protect human

health from contaminants present in drinking water. Under the authority of SDWA, EPA has developed national drinking water standards and created a joint federal-state system to ensure compliance

with these standards. EPA also regulates underground injection of liquid wastes under the SDWA to

protect underground sources of drinking water. 

SDWA Resources:

■ 40 CFR Parts 141 to 148

■ SDWA Hotline: 800 426-4791

■ Internet access: <www.epa.gov/ogwdw>

TOXIC SUBSTANCES CONTROL ACT

The Toxic Substances Control Act (TSCA) allows EPA to collect data on chemicals to evaluate,

assess, mitigate, and control risks that might be posed by their manufacture, processing, and use.

Photo processing facilities may be affected by some TSCA requirements. 

TSCA Resources:

■ 40 CFR Parts 702 to 799

■ TSCA Hotline: 202 554-1404

■ Internet access: <www.epa.gov/internet/oppts>

CFR GUIDE 

continued

Part 268—Land dispo

restrictions.

Part 270—EPA-admin

tered permit program

the Hazardous Waste

Permit Program.

Part 271—Requireme

for authorization of st

hazardous waste programs.

Part 272—Approved

state hazardous waste

management program

Part 273—Standards f

universal waste manag

ment.

Part 279—Standards f

the management of u

oil.

See the regulations at

<www.access.gpo.gov/

nara>.

FOR MORE 

INFORMATION

For additional inf

mation on any o

these laws, contact th

RCRA Hotline at 

800 424-9346 or

703 412-9810 in the

Washington, DC, area

TDD (hearing

impaired): 800 553-76

or 703 412-3323 in th

Washington, DC, area
Contacts

HOTLINES AND INFORMATION

CENTERS

RCRA Hotline

U.S. Environmental Protection Agency

Phone: 800 424-9346 

or TDD 800 553-7672

In the Washington, DC, area: 703 412-9810 

or TDD 703 412-3323

Home page: <www.epa.gov/epaoswer/

hotline>

Answers questions on matters related to

RCRA solid waste, hazardous waste, and

underground storage tanks, EPCRA, and

CERCLA.

RCRA Information Center

U.S. Environmental Protection Agency

RCRA Information Center (5305W)

401 M Street, SW.

Washington, DC 20460

Phone: 703 603-9230

Fax: 703 603-9234

E-mail: rcra-docket@epamail.epa.gov

Holds and provides public access to all

regulatory materials on RCRA and distributes technical and nontechnical information on RCRA issues.

Small Business Ombudsman

Clearinghouse/Hotline

U.S. Environmental Protection Agency

Small Business Ombudsman (2131C)

401 M Street, SW.

Washington, DC 20460

Phone: 800 368-5888

Fax: 202 401-2302

Home page: <www.smallbizenviroweb.org>

Helps private citizens, small businesses,

and smaller communities with questions

on all program aspects within EPA.

EPA Headquarters Library

U.S. Environmental Protection Agency

Headquarters Library

401 M Street, SW., Room 2904

Washington, DC 20460

Phone: 202 260-5921 or 5922

Fax: 202 260-6257

E-mail: library-HQ@epamail.epa.gov

Home page: <www.epa.gov/natlibra/

liblists.html>

Maintains environmental reference materials for EPA staff and the general public,

including books, journals, abstracts,

newsletters, and audiovisual materials

generated by government agencies and the

private sector. Also provides access to

online computer service bulletin boards

and CD-ROM systems.

U.S. Department of Transportation

Hazardous Materials Information Center

Phone: 800 467-4922

Provides information about DOT’s 

hazardous materials regulations.

U.S. Government Printing Office

Superintendent of Documents

P.O. Box 371954

Pittsburgh, PA 15250-7954

Phone: 202 512-1800

Fax: 202 512-2250

Home page: <www.access.gpo.gov>

Prints and distributes the Code of Federal

Regulations. Title 40, Parts 260 to 299,

contains most of the RCRA requirements.

National Response Center (NRC)

Phone: 800 424-8802

In the event of a fire, explosion, or other

release of hazardous waste that could

threaten human health outside the facility,

call the NRC to report the emergency. The

NRC will evaluate the situation and help

you make appropriate emergency decisions.

ADDITIONAL INTERNET

ADDRESSES

EPA Home Page

<www.epa.gov>

EPA RCRA Hazardous Waste

Resources

<www.epa.gov/osw/topics.htm>

Code of Federal Regulations

<www.epa.gov/docs/epacfr40>

Envirosense 

<es.inel.gov>

(contains technical, policy, and general

information on pollution prevention topics)

INDUSTRY CONTACTS

Photo Marketing Association

International

3000 Picture Place

Jackson, MI 49201

Phone: 517 788-8100

Fax: 517 788-8371

Home page: <www.pmai.org>

Represents professionals in the imaging

industry in over 100 countries. Publishes

Photo Marketing, which contains some articles about pollution prevention.

The Silver Council

5454 Wisconsin Avenue

Chevy Chase, MD 20815

Phone: 301 664-5150

Fax: 301 664-5156

Home page: <www.silvercouncil.org>

Develops and promotes environmentally

sound and cost-effective methods for

recovering silver from photographic 

processing operations.

Eastman Kodak Company

Kodak Environmental Services

Phone: 716 477-3194

Fax:: 800 242-2424

Developed a series of publications on silver recovery from photographic processes.

ADDITIONAL RESOURCES

Code of Management Practice for Silver

Dischargers provides information about

cost-effective and sound environmental

management systems, including pollution

prevention and silver recovery. This document is published by the Association of

Metropolitan Sewage Agencies and the

Silver Council and can be obtained from

the National Association of Photographic

Manufacturers at:

550 Mamaronek Avenue, Suite 307

Harrison, NY 10528-1612

Phone: 914 698-7603

Home page: <www.silvercouncil.org>

Call the RCRA Hotline (800 424-9346) to

order any of the following documents:

Understanding the Hazardous Waste Rules: A

Handbook for Small Businesses, 1996 Update

(EPA530- K-95-001) provides an overview

to help small business owners and operators understand how best to comply with

federal hazardous waste management regulations. This booklet defines the three

categories of hazardous waste generators

and assists small businesses in determining if federal regulations apply. This document also explains how to obtain an EPA

identification number, manage waste on

site and ship waste off site.

RCRA: Reducing Risk From Waste (EPA530-

K-97-004) provides a brief overview of

the national RCRA program and the role

of the states. This booklet defines RCRA

hazardous waste and how the RCRA regulations apply to generators, transporters,

and TSDFs. It focuses on hazardous

waste and also addresses municipal and

industrial nonhazardous solid waste. It

provides examples of waste and waste

treatment and disposal methods, waste

minimization tips, links to other environmental laws related to hazardous substances, a glossary of terms, and a guide to

the RCRA sections of the Code of Federal

Regulations. 

CONTACTS AND RESOURCES

16 RCRA IN FOCUS

2 Printed on paper that contains at least 30 percent postconsumer fiber.