Wastewater Practices: Photochemical Disposal
Introduction
Typical substances utilized in photo processing include fixer, bleach fixer, developers, stabilizers, and rinsewater. Due to the chemical constituents in these substances (used and unused), discharge of these substances to the sewer is typically (normally) prohibited. For example, used fixer typically contains levels of silver which exceed Massachusetts Water Resources Authority's (MWRA's) limitation of 2 parts per million (ppm). As a result, discharge of used fixer to the sewer is a violation of MWRA regulations. In these cases, Treatment and recovery equipment can be installed and operated to extract silver from the used fixer to allowable (reduce) levels below 2 ppm.
This Compliance Officer Sheet provides Harvard University personnel engaged in photo processing operations (including X-ray), with wastewater discharge best management practices (BMPs). The BMPs are designed to promote pollution prevention and ensure effective treatment and management of photo processing wastes prior to discharge. As a discharger of wastewater associated with photo processing operations, adhering to these BMPs will help to ensure your operation is managed in an environmentally safe and responsible manner and promote compliance with applicable MWRA regulations.1 A list of University photo processing operation locations is included as Attachment 1. Please contact Environmental Affairs at 495-1983 to report any photo processing operation at Harvard which is not on this list.
Applicable University Policy
Harvard University Environmental and Safety Management Policy
Applicable Regulation
MWRA Regulation 360 CMR 10.00, "Sewer Use"
Summary of Requirements
The following provides a summary of best management practices associated with photo processing operations:
1. Silver Bearing Wastes - Silver bearing wastes include, but are not limited to, fixer, bleach-fix, stabilizers and functionally similar solutions. Due to silver content, these wastes typically exceed MWRA's maximum daily limit for the discharge of silver (2 ppm). Normally a pre-treatment system is utilized to treat these substances so that silver levels are below MWRA limitations. Typically these silver bearing wastes are discharged through a properly sized, designed, installed, operated, maintained and serviced silver recovery unit prior to discharge to the sewer. These units extract silver from the material through physical or chemical methods. The silver recovery equipment must be operated and maintained in accordance with manufacturer's specifications. The facility should maintain the manufacturer's specifications for its silver recovery equipment (unit) along with the equipment (unit). In addition, it is recommended the facility maintain a silver recovery management log which records all maintenance and silver recovery activity. EH&S is available for assistance with these recommendations.
2. Prohibited Wastes and Local Limits - In addition to silver discharge limits, the facility must comply with MWRA Sewer Use Regulations on Prohibited Wastes and Local Limits contained in 360 CMR 10.021-10.026. These regulations list specific waste and materials which are prohibited from being discharged to the MWRA sewer system including, but not limited to, oils, solvents (i.e., xylene, toluene, benzene, MEK), high temperature liquids and vapors (greater than180 F), mercury, PCBs and various pesticides. Hazardous waste is strictly prohibited from being discharged to the sewer. Refer to "Wastewater Practices" Fact Sheet for additional information and/or contact EH&S for assistance.
3. Signs - As a reminder to personnel involved with or in the vicinity of photo processing operations, signs should be posted at nearby sinks indicating that untreated discharge of chemicals is strictly prohibited. An example of a sign is provided as Attachment 2.
Training
Employee Training: It is recommended that individuals involved in photo processing operations be trained in the operation and maintenance of silver recovery equipment, spill procedures and with applicable MWRA requirements. Contact EH&S for training assistance. Maintaining a training record/log which records personnel that have been trained is a recommended practice.
Reporting
All facilities that discharge to the MWRA sewer system are subject to certain notification requirements. It is recommended that these notifications be made after consultation with EH&S.
1. Accidental Discharge - Accidental discharge of the following requires immediate notification by telephone to the MWRA ((617) 241-2350) and the Municipality, (Boston Sewer and Water Commission (617) 989-7000) into whose sewer the accidental discharge was released.
1) Substances prohibited or limited by 360 CMR 10.021-10.024; or
2) Any slug2 loads or spills that may enter the sanitary sewer from the facility.
EH&S is available to assist the facility with compliance assurance during and after a release event.
2. Facility Operation and Physical Changes - Modifications and/or expansions to facility processes and physical layout which impact wastewater discharges associated with photo processing operations may be subject to a notification requirement. EH&S is available for assistance with this issue.
Inspections
Weekly Inspections: Weekly visual inspections of silver recovery equipment will help to ensure that the equipment is operating properly and that operational problems will be addressed in an expedited manner.
Preventive Maintenance: The silver recovery system should be maintained and serviced in accordance with manufacturer's recommendations. See your service vendor for details.
Recordkeeping
It is recommended that facilities conducting photo processing operations maintain the following records: weekly inspection records; silver recovery management documentation (i.e. manifests, bills of lading, cartridge management replacement records, etc.); employee training records; and manufacturers' specifications for photoprocessing equipment and treatment systems.
Written Program
A written program is not required unless specifically required by a permit. See Recordkeeping section.
University Resources
Cambridge/Allston Campus EH&S 495-2060
Harvard Longwood Campus EH&S 432-1720
Attachment 1
Wastewater Practices: Photoprocessing Operations
| CAMPUS | LOCATION |
| Cambridge | Sever Hall |
| Cambridge | Carpenter Center, 24 Quincy St. |
| Cambridge | Cruft Lab, 19A Oxford St. |
| Cambridge | Dunster House, 945 Memorial Drive |
| Cambridge | McKay Lab, 15 Oxford St. |
| Cambridge | Biology Stockroom, Sackler Museum |
| Cambridge | 50 Church St. |
| Cambridge | Mallinckrodt Lab, 12 Oxford St. |
| Cambridge | Widener Library |
| Allston | Office of the University Publisher, 219 Western Avenue |
Attachment 2
WASTEWATER PRACTICES: PHOTOPROCESSING OPERATIONS NOTICE ALL EMPLOYEES
In accordance with MWRA sewer use regulations, the following materials are PROHIBITED from being discharged to the sewer:
1) all cleaning solvents;
2) inks;
3) untreated silver-bearing wastes;
4) all other hazardous wastes.
If you have any questions concerning handling procedures, contact your supervisor.
