Page
1
of
9
Memorandum
From:
Jan
Matuszko
USEPA/
OW/
OST
ph:
(
202)
566
1035
matuszko.
jan@
epa.
gov
To:
Public
Record
for
the
2006
Effluent
Guidelines
Program
Plan
EPA
Docket
Number
OW­
2004­
0032
(
www.
epa.
gov/
edockets/)

Date:
August
11,
2005
Re:
Photoprocessing
1.0
Introduction
In
1997,
EPA
published
a
"
Preliminary
Data
Summary
for
the
Photoprocessing
Industry
(
1997
PDS).

1.1
Industry
Profile
Photoprocessing
includes
facilities
in
SIC
codes
7221,
7335,
7336,
and
7384.
The
1987
SIC
Code
Manual
defines
these
SIC
codes
as
follows:


7221:
Establishments
primarily
engaged
in
still
or
video
portrait
photography
for
the
general
public.
Included
in
this
classification
are
school,
home,
and
transient
portrait
photographers.
Establishments
primarily
engaged
in
commercial
photography
are
classified
in
Industry
7335;
those
primarily
engaged
in
video
tape
production
other
than
portrait
are
classified
in
Industry
7812;
and
those
primarily
engaged
in
film
developing
and/
or
print
processing
for
the
trade
or
for
the
general
public
are
classified
in
Industry
7384.


7335:
Establishments
engaged
in
providing
commercial
photography
services
for
advertising
agencies,
publishers,
and
other
business
and
industrial
users.
Establishments
engaged
in
still
and
video
portrait
photography
are
classified
in
Industry
7221,
and
those
primarily
engaged
in
mapmaking
are
classified
in
Industry
7389.
Establishments
primarily
engaged
in
medical
photography
are
classified
in
Industry
8099.
Establishments
primarily
engaged
in
producing
commercial
video
tape
or
films
are
classified
in
Industry
7812.


7336:
Establishments
primarily
engaged
in
providing
commercial
art
or
graphic
design
services
for
advertising
agencies,
publishers,
and
other
business
and
Page
2
of
9
industrial
users.
Producers
of
still
and
slide
films
are
classified
here.
Establishments
primarily
engaged
in
art,
except
commercial
and
medical
art,
are
classified
in
Industry
8999;
those
engaged
in
medical
art
are
classified
in
Industry
8099;
and
those
providing
drafting
services
are
classified
in
Industry
7389.


7384:
Establishments
primarily
engaged
in
developing
film
and
photographic
prints
and
enlargements.
Data
for
retail
outlets
(
kiosks),
which
are
owned
and
operated
by
photo
finishing
laboratories
for
the
pickup
and
delivery
of
film,
are
merged
with
data
for
the
laboratory
which
owns
them
and
are
not
treated
as
separate
establishments.
Establishments
primarily
engaged
in
processing
motion
picture
and
video
film
for
the
motion
picture
and
television
industries
are
classified
in
Industry
7819.

Table
1­
1
presents
facility
counts
for
the
Photoprocessing
Category
from
the
U.
S.
Census
and
the
1997
PDS.

Table
1­
1.
Census
and
1997
PDS
Data
SIC
Code
NAICS
Code
Number
of
Establishments1
Number
of
Establishments2
As
Primary
Business
As
Primary
or
Secondary
Business
1997
2002
7221:
Photographic
Studios,
Portrait
541921:
Photographic
Studios,
Portrait
27,607
32,184
13,245
14,587
7335:
Commercial
Photography
541922:
Commercial
Photography
(
except
medical
photography)
14,845
18,414
4,298
4,255
7336:
Commercial
Art
and
Graphic
Design
541430:
Graphic
design
services
31,476
37,264
14,582
15,828
7384:
Photofinishing
Laboratories
812921:
Photofinishing
laboratories
(
except
one­
hour)
10,430
13,171
7,055
4,723
812922:
One­
hour
photofinishing
Total
84,358
101,033
39,180
39,393
Sources:

1.
1997
U.
S.
EPA
Photoprocessing
Industry
PDS
2.
U.
S.
Census
Bureau.

No
facilities
reported
to
TRI
in
2000,
and
one
facility,
USGS
­
EROS
DATA
CENTER
in
Sioux
Falls,
has
data
in
the
2000
PCS.
Table
1­
2
lists
the
facility
data
available
in
the
2000
TRI
and
PCS.
In
addition,
the
1997
PDS
indicates
that
the
majority
of
photoprocessing
facilities
are
small
in
size
(
less
than
ten
employees),
which
exempts
them
from
TRI
reporting.
Page
3
of
9
Table
1­
2.
Facility
Counts
in
TRI
SIC
Code
Number
of
Facilities
Reporting
to
2000
TRI
Number
of
Facilities
Reporting
to
PCS
2000
Direct
Indirect
Both
No
Reported
Discharge
Direct
(
Major)

7221
0
0
0
0
0
7335
0
0
0
0
0
7336
0
0
0
0
0
7384
0
0
0
0
1
Source:
PCSLoads2000
and
TRIReleases2000.

1.2
Wastewater
Characteristics
For
2000,
no
TRI
data
are
available,
and
PCS
contains
discharge
information
for
a
single
facility.
There
is
no
central
database
containing
information
on
indirect
dischargers.
However,
the
1997
PDS
provides
information
on
wastewater
sources
and
characterization.
Table
1­
3
summarizes
photoprocessing
wastewater
streams
and
their
major
constituents.

Table
1­
3.
Aqueous
Wastes
from
Photoprocessing
Solution
Constituents
Prehardeners,
Hardeners,
and
Prebaths
Organic
Chemicals
Chromium
Compounds
Developers
Organic
Chemicals
Stop
Baths
Organic
Chemicals
Ferricyanide
Bleaches
Ferricyanide
Dichromate
Bleaches
Organic
Chemicals
Chromium
Compounds
Clearing
Baths
Organic
Chemicals
Fixing
Baths
Organic
Chemicals
Silver
Thiocyanate
Ammonium
Compounds
Sulfur
Compounds
Neutralizers
Organic
Chemicals
Stablilizers
Phosphate
Page
4
of
9
Sound­
track
Fixer
or
Redeveloper
Organic
Chemicals
Ammonium
Compouns
Monobaths
Organic
Chemicals
Source:
1997
U.
S.
EPA
Preliminary
Data
Summary
for
the
Photoprocessing
Industry
Process
water
used
in
photoprocessing
consists
of
a)
film
and
paper
wash
water;
b)
solution
make­
up
water;
and
3)
area
and
equipment
wash
water.
According
to
the
PDS,
photoprocessors
typically
discharge
less
than
1,000
gallons
of
wastewater
per
day.
The
PDS
also
documents
296
million
square
feet
of
film
and
4,130
million
square
feet
of
paper
processed
per
year.
Table
1­
4
provides
information
on
wastewater
flows
associated
with
this
industry.

Table
1­
4.
Total
U.
S.
Commercial
Photoprocessing
Wastewater
Flow
for
1994
Wastestream
Flow
Demands
(
mL/
sq.
ft)
Total
U.
S.
Flow
(
MGal/
year)

1994
2003
Range
Average
Film
Paper
Film
&
Paper
Film
Paper
Film
&
Paper
Developer
paper:
5­
30
film:
15­
100
paper:
17.5
film:
57.5
4.5
19.1
­

­
4.3
15.4
­

­

Bleach
5­
30
17.5
­
­
20.4
­
­
16.7
Fix
15­
100
57.5
­
­
67.2
­
­
54.8
Bleach­
Fix
5­
30
17.5
­
­
20.4
­
­
16.7
Stabilizer
10­
30
20.0
­
­
23.4
­
­
19.1
Wash
(
per
tank)
200­
1000
600.0
­
­
700.9
­
­
571.9
Total
=
Developer
+
Bleach
+
Fix
+
Stabilizer
+
Three
Wash
Tanks
2,258
1,843
Source:
1997
PDS
and
2003
Photo
Manufacturers
Association.

1.3
Pollutant
Loadings
The
PDS
also
provides
an
estimate
of
the
pollutant
loadings
associated
with
this
industry.
For
purposes
of
this
evaluation,
EPA
assumed
the
same
concentrations
as
the
1997
PDS
(
except
where
noted
for
silver)
and
used
the
flows
from
Table
1­
4
for
2003
flows.
Table
1­
5
summarizes
the
estimated
pollutant
loadings.
As
can
be
seen
in
Table
2­
5,
99%
of
the
toxic
load
associated
with
this
industry
is
from
silver.
While
the
overall
annual
TWPE
is
300,000,
the
TWPE
per
facility
is
less
than
10.
Page
5
of
9
Table
1­
5.
Pollutant
Loadings
Estimated
for
1994
and
2003
Pollutants
of
Concern
Concentration
(
mg/
L)
3
Loads
Before
POTW
Removal
(
lbs/
year)
TWF
TWPE
Before
POTW
%
Removal
(
lbs/
year)
POTW
%
Removal4
Loads
After
POTW
Removal
(
lbs/
year)
TWPE
(
lbs/
year)

Range
Average
1994
2003
1994
2003
%
Data
Source
1994
2003
1994
2003
Ammonia
20­
300
160
3.02E+
06
2.46E+
06
0.0022
6,633
5,413
39%
TRI
table
1,839,156
1,500,947
4,046
3,302
Biochemical
Oxygen
Demand
(
BOD)
200­
3000
1600
3.02E+
07
2.46E+
07
NA
NA
NA
NA
NA
NA
NA
NA
NA
Chemical
Oxygen
Demand
(
COD)
400­
5000
2700
5.09E+
07
4.15E+
07
NA
NA
NA
NA
NA
NA
NA
NA
NA
Iron
<
10­
100
55
1.04E+
06
8.46E+
05
0.0056
5,804
4,737
83%
CWT/
RREL
176,190
143,789
987
805
Silver
(
ion;
after
recovery)
1,2
<
0.1­
5
10
1.88E+
05
1.54E+
05
16.47
3,103,576
2,532,847
88%
TRI
table
22,085
18,024
363,739
296,850
Sulfates
50­
250
150
2.83E+
06
2.31E+
06
5.60E­
06
16
13
NA
NA
NA
NA
NA
NA
Thiosulfate
100­
1000
550
1.04E+
07
8.46E+
06
NA
NA
NA
NA
NA
NA
NA
NA
NA
Total
Dissolved
Solids
(
TDS)
300­
3000
1650
3.11E+
07
2.54E+
07
NA
NA
NA
NA
NA
NA
NA
NA
NA
Total
Kjeldahl
Nitrogen
(
TKN)
30­
350
190
3.58E+
06
2.92E+
06
NA
NA
NA
90%
I&
S/
Steel
POTWs
358,032
292,192
NA
NA
Total
Suspended
Solids
(
TSS)
<
5­
50
27
5.09E+
05
4.15E+
05
NA
NA
NA
NA
NA
NA
NA
NA
NA
Zinc
<
0.75
0.75
1.41E+
04
1.15E+
04
0.0051
NA
NA
79%
TRI
table
2,948
2,406
15
12
Total
1.34E+
08
1.09E+
08
3,116,029
2,543,010
2,398,412
1,957,358
368,787
300,969
Source:
1997
Photoprocessing
Industry
PDS
(
Orginial
data
source:
1994
WEF
study)

Notes:
NA
=
No
TWF
available
and/
or
no
POTW
percent
removal
available.

1.
The
value
range
<
0.1
­
5
is
low
compared
to
the
concentration
ranges
presented
in
Table
7.3,
for
95
percent
silver
recovery,
combined
wastestream
(
combined
with
wash
water),
of
5­
20
mg/
L.
The
value
of
10
mg/
L
has
been
taken
to
be
more
realistic.

2.
The
TWF
value
is
for
silver
as
taken
from
the
TRIReleases2000.
mdb
database.

3.
2003
concentrations
are
assumed
to
be
the
same
as
1994
concentrations.
Concentration
values
from
1994
WEF
study.

4.
POTW
removal
values
are
from
the
TRI
Calculations
2002
database,
the
POTW
removals
table,
where
available.
Values
were
supplemented
using
POTW
Removals
from
the
CWT
and
Iron
and
Steel
Rulemakings.
Page
6
of
9
1.4
On­
Site
Treatment
Technologies
and
Pollution
Prevention
Activities
The
1997
Preliminary
Data
Summary
includes
a
detailed
discussion
of
control
and
treatment
technologies.
These
include
source
reduction,
water
reduction,
and
silver
recovery
technologies.
Table
1­
6,
which
is
reproduced
from
the
PDS,
provides
a
comparison
of
various
silver
recovery
and
management
systems.
According
to
the
PDS,
silver
recovery
is
almost
always
practiced
to
some
extent.
The
most
common
methods
are
metallic
replacement
and
electrolytic
recovery.

Table
1­
6.
Silver
Recovery
Technologies
Technology
Advantages
Disadvantages
Metallic
Replacement
Can
achieve
99%
recovery;

Can
be
used
for
all
silver
rich
solutions;

Low
capital
and
operating
and
maintenance
costs;

Simple
operation
Must
be
replaced
on
schedule;

Tendency
to
channel
and
cause
concentrated
silver
discharge;
efficiency
diminishes
with
use;

High
smelting
and
refining
costs;

effluent
not
suitable
for
re­
use
Electrolytic
Recovery
Can
achieve
90%
recovery;

No
additional
chemicals
released;
fix
solution
can
be
recycled;

Moderate
capital
costs
Low
refining
costs
Cannot
achieve
5
mg/
L;

Not
suitable
for
silver­
poor
solutions
Precipitation
Can
attain
0.1
mg/
L
Little
maintenance
Low
to
moderate
capital
costs
High
smelting
and
refining
costs;

complex
operation;

operation
costs
vary
from
moderate
to
high;

treated
solution
not
suitable
for
reuse
Evaporation/
Distillation
Can
reduce
wastes
up
to
90%

Virtually
zero
overflow
of
silver
High
energy
requirements;

Moderate
to
high
capital
cost
Reverse
Osmosis
Efficiently
recovers
silver
from
dilute
silver
wastestreams;

Reduces
effluent
volume
significantly;

No
water
treatment
chemicals
required;

Purified
water
is
recyclable
Capital
and
O&
M
Costs
vary
significantly;

Frequent
maintenance
of
membranes
and
pumps;

works
best
with
dilute
solutions
1.5
Code
of
Management
Practice
for
Silver
Dischargers
(
Silver
CMP)
Page
7
of
9
Virtually
all
discharging
photoprocessors
discharge
indirectly
to
POTWs.
Many
POTWs
have
stringent
silver
limits
in
their
NPDES
permits
or
need
to
reduce
metals
concentrations
in
biosolids.
POTWs
have
identified
photographic
facilities
as
a
whole
as
a
major
source
of
silver.
In
an
attempt
to
provide
photoprocessing
facilities
and
POTWs
with
a
cost­
effective
alternative
to
numeric
limits
and
monitoring,
in
1997,
AMSA,
the
Silver
Council
and
two
industry
groups
for
the
Photographic
industry
developed
a
"
Code
of
Management
Practices
for
Silver
Dischargers"
(
Silver
CMP).
The
Silver
CMP
provides
recommendations
on
control
technologies
and
management
practices
for
controlling
silver
discharges
to
POTWs,
and
encourages
pollution
prevention
technologies
such
as
water
conservation.
The
recommended
practices
are
defined
by
a
minimum
recovery
of
silver
from
silver­
rich
processing
solutions
(
e.
g.
90%,
95%,
and
99%).
The
minimum
recovery
and
recommended
practices
vary
with
the
size
of
the
photoprocessor,
defined
by
flow
volume
of
silver­
rich
solution
and
wash
water.
Four
POTWs
documented
loadings
reductions
of
20%
to
52%
over
historical
baselines
after
CMP
implementation.

1.6
Multimedia
Environmental
Releases
In
addition
to
silver­
laden
wastewater,
photoprocessors
generate
solid
and
hazardous
waste.
Sludge
from
photoprocessing
silver
recovery
is
usually
contract
hauled
as
hazardous
waste
(
D011)
(
RCRA
In
Focus).
Photoprocessors
may
also
generate
hazardous
waste
from
acid
regenerants,
system
cleaners,
and
photographic
activators
(
D002),
dichromate
based
cleaners
(
D007).

1.7
Industry
Trends
The
use
of
digital
photography
and
digital
printing
increased
in
the
U.
S.
from
2002
to
2004.
In
2002,
digital
cameras
were
owned
by
18
percent
of
adults
(
Market
Research).
In
2003,
digital
cameras
were
owned
in
30
­
50
percent
of
U.
S.
households
(
Photo
Industry
Reporter).
In
2004,
shipments
of
digital
still
cameras
in
the
U.
S.
grew
by
roughly
30
percent
(
Business
Week
Online),
indicating
digital
camera
use
in
60
­
80
percent
of
U.
S.
households.
Digital
photography
should
decrease
the
discharge
of
silver­
laden
wastewater
associated
with
silver­
halide
printing.

Contrarily,
pictures
from
digital
cameras
can
still
be
printed
using
silver­
halide
technology,
for
better
quality.
Although
this
is
not
currently
an
identified
trend,
film
manufacturers
have
incentive
to
establish
this
trend,
to
keep
their
part
of
the
market
share
(
Business
Week
Online).

1.8
References
Association
of
Metropolitan
Sewerage
Agency
(
AMSA)
and
the
Silver
Council.
Code
of
Management
Practices
for
Silver
Dischargers.
Available
online
at:
http://
www.
p2pays.
org/
ref/
02/
01994.
pdf.
Accessed
January
25,
2004.
Page
8
of
9
Stice,
Richard.
Kodak's
Many
Negatives.
Business
Week
Web
Page.
Available
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