HomeMy WebLinkAbout0492.000I • r-
I -
i -,
6 ·~';\r··
II ;~---,,-,," _" ~_-_____ ..I.~ __ =. ___ ....l. __________ ~ ___ ~ _______ ~ .. ,, _____ _
!j (f) 15
-
septem~r 6~ 1990
THE HONORABLE CITY COUNCIL
Palo Alto, Califo~nia
Amendments to the Palo Alto MuniciwLcode SeW_E2'r Use Ordinance
Members or the Council:
Purpose statement
This report recommends that Council approve amendments to the Se'Wer
Use ordinance (Attachment A) to im::lud:e new requirements for
photoprocessors., x-ray faci lities, and other facilities which
develop silver-bearing film and paper. The purpos-e of the neW'
requirements is to reduce tha silver discharged ~rom the Regional
Water Quality Control Plant (RWQCP) in San Francisco Bay.. as
mandated by the discharge penait issued by the Regional Water
Quality Control Board.
Background
Tbe purpose of the Sewer Use Ordinance is to contro1 contaDinants
being discharged to the sewers in order to protect ~orkers~ the
sewer systeD, the RWQCP and San Francisco Bay (recipient of the
treated wast-evater). Tbe proposed modifications are necessitated
by the discharqe permit tor the RWQCP~ which requires approximately
a 15 per-cent red~"Ct.ion in silver discharge by December 199:. and the
immediate implementation of a pilot source reduction program for
silver. The provisions related to silver, as well as several other
modifications to the ordinance, are described below.
Silver ModiJications
Modifications are being made to the discharge limits for ind·ustrial
facilities ~hich have been regulated historically. New require
Ilents are being proposed .for photoqraphic materials processors
'Which typically have no-t been regulated. The silver discharge
Ii_it for ind·us.trial facilities (not including photographic
materials processing) is being lowered to 0.25 mg/l. This value
was determined to be necessary by back-calculatinq from the RWQCP's
new requirements. ThE proposed revisions vere drafted in May and
sent to all regulated industries in the service area (approximately
400) ~ There 'Were no adverse comments. A proposal for the
photographic materials process~rs also was drafted in Hay.
Substantial comments were received and an in-depth discussion of
the proposed revisions is presented in the following t~o sections.
-1-
,
•
\
\ ,
\ .. ,
\ ~ \ -,
..J
, ,
~--,
:''-> : ... : -,
,.~ ....
\
• I
---
,-
-
.. . , .
-,
Photographic Materials Processors -The Proposal
The proposed modification is summarized in Attachment B. A pboto
processor would have three options:
1.
z.
J.
Haul spent -fix· and 5i_ilar solutions (spent solutions) for
silver recovery,
Treat ~nd discharge spent solutions and meet a 0.5 mg/l silver
discharge li.it, or
In addition to the treatment in option 2.. install water
conservation equipment and meet a 1.0 mq/l silver discharge
limit.
These options reflect several changes made in response to comments
received in writing and at five public meetings beld in Palo Alto
and MOuntain view since the May 1990 proposal vas released. Host
of the comments indicated that the proposed 0.25 mq}l standard was
too low to be met economically.. The c01'elllentors believed that
businesses yould not be able to compete with businesses north ~f
Palo Alto vbere such liDits are not being proposed (sample letters
ara enclosed --Attachments C and D).
A second comment was that a hlqher concentration standard was
app~opriate for very low water users, because the mass of slIver
could equal bigh volume water users but appear in a higher
concentration. staff agrees and bas included a new optIon, option
3, to encourage water conservation. A third comment was that it
would not be equitable to allow large facilities to haul spent
solutions off-site and not have to treat washwater~ as the facili
ties choosing options 2 and 1 would have to do. staff aqre.p,s~ and
large facilities Cqreater _than 100 qallons per month of spent
solutions) viII be required to utilize the washwater treatment
regardless of the option chosen.
A number of other, less critical ... comments were received; and
numerous modifications to the Kay revisi~ns were made and released
at an August 8, 1990 public meeting. The latest revised o~dinance
was mailed to all affected facilities (approx:iIilately 40'O) on Auqust
10, 1990. The reaction ~o the revisions has been favorable. No
major comments have been left unaddcessed. Attachment E contains
typical questions raised at the earlier public meetings and staff
~esponses.
Photographic Material~_Processing -Cost of the proposal
The cost to affected business was a major issue raised by com
llentO:l'S to the )fay 1990 draft.. The treatment costs associated with
the present proposal are substantially lower. due to the aVailabil
ity of appropriate recovery equipment able to meet the 0.5/1.0 mg/l
standard and the reduced. cost of syste. design and operation.
Small facilities still may elect to have vaste solutions hauled
-z-
0!R:49Z:Q
•
,
!
t
f
'-
•
\
'c
\
.. ~.
\
\ ,
\
..-, .. ".-. .. -:1 i . . -. . ... -.
-,
I
: i
"
,
I . r-I .
-,
. J
"i
-
o o
away for otf-site silver recovery. Anticipated economic impacts
ar~ addressed below for several common scenarios4
Treatment
The net cost of meeting the proposed requirements by on-site waste
treatment ~ill vary acc~rdin9 to the volume of waste produced, the
nature of the photographic process employed~ recovery equipment
presently in operation, and the market price of silver.. All
facilities choosing treatment will incur monthly self-monitoring
costs of $25 to $100 depending upon flow4 Record: keepir.g(reporting
time and expense ~ill be minimal (several h~urs per year l more for
the largest tacilities).
Small-to medium-sized x-ray facilities, 0-100 qallons per month,
may choose to install relatively new technology ~hich ensures low
or Eero silver disch&rqe and bas a lease cost between $40-$200 per
mon·th. Captured silver may be resold to offset leasing expenses ..
Xid-si~e~ ~toprocessing facilities qenerating 20-S~O gallons per
month of spent solutions may augment existing systems or install
new-on-site recovery equipment for a total .. one-time equipment cost
of $1 .. 000 to $5~OOO. Annual operating expense will be largely
offset by the value of silver recovered~ Several hours per week of
operator ~i~e will be necessary to ensure proper system operation.
Large ~acllities which have substantial treatment systems mayor
~ay not need to upgrade to meet proposed requirements.. Tbe total
cost to larqe facilities will Qepend entirely on system-specific
decisions. though cost wi}~ be proportionately siDilar to expenses
incurred by .id-si~ed faci1ities.
Wat.er conservat.ion equipment (not required by the proposal) is
expensive to purchase and install ($10#(H}O-$.c.O,0'O'O) but has a quick
payback time of two to five years, based on vater and energy cost
savings and reduced seW'er fees. Fix: and bleach fix regeneration
systems vary in price from $50~ per year tor leasing to $20#COO per
year for purcbase. These systems also result in dramatic energy
and chemical cost saving'S. Water and chemical recirculation
systems have the added benefit of buf£ering the facility against
futUre energy~ sewer and water rate increal::·es. Staff feels that
the capital outlay for vater conserva~ion equipment and solution
regeneration equipment vili be in the best interest of many larqe
f~cilities~ due to the reduced volume of waste and the higher l~O
mgJl ii_it .. which is more easily attainable~
Hauling
Very s.mall businesses, such as dental offices .. will probably choose
to haul spent solutions oft-site and will not have to purchase any
recovery equipment. The cost of hauling is estimated ~o be $2-$6
per gallon once regular pick-up routes are established~ A mid
sized dental office with five qallons per month would pay $10-$30
-)-
C>!R:492: 0
•
•
. ,
,
1.
\
\
\
•• \
•
,
,.
" ____ ~~1 ~~ ____ , ____ ." ,_" ~:: __ z<'_ "<:"" ___ :.. ___ -=:.,""-_e>-,~ ".: -~ __ ~'i"~M_~:"~,.",,4 _-6:p~
o
per month~ To facilitate the establishment of -.ilk-run-pick-ups
(.any small volume pick-ups per day by ~ waste hauler) and ensure
reasonable prices. a pick-up service sponsored by the RWQCP may be
a~ropriate~ ThiS possibility will be studied this fall.
RecommendatIons to the partner aqencies viII be made in ~cember
1990# ~ell abead of the June 30. 1991 compliance date.
!;ity Costs
Approximately 125 facilities in Palo Alto and 4-0'0 in the RWQCP
service area will be affected by the proposal. The cost of city
staff and consultant services needed to administer the program is
estimated to be 1. 5 person-years and $30.G(}Q per year respectively ..
and has been included in the Wastewater Fund FY 1990-91 operating
budqet~ No. new appropriations are being requested~
other Modifications
Several other ~odifications to the Se~er Use Ordinance are being
proposed ~ith this package in the interest of efficiency. They are:
1.
2.
Lowering the zinc discharge limitation from 5.0 mq/l to 2.0
mg/l. No adverse comment was received. This modification
brings the Palo Alto li.it in line 'With <other Santa Clara
county jurisdictions.
Increasing concentration standards on two non-toxic constitu
ents (chemical oxygen demand and suspended solids] to encour
age water conservation~
3. Making it illegal to discharge domestic or industrial waste to
the storm sewer. This modification is necessary to bring the
palo Alto Ordinance in line with other Santa Clara County
cities and to act as a basis fo~ the Illegal DUmpinq Preven
tion Program budgeted for FY 91-92.
4. clarifying several technical provisions of the ordinance.
Partner Cities
The ordinance and suppo~tinq materials have been sent to the other
jurisdictions within the service area for adoption. Palo Alto
staff has worked with other jurisdictions during the last six
Ilonths to ensure that concerns from those jurisdictions 'Were
addreSSed. All publIc meeting notices and draft ordinances 'Were
sent to affected parties in the entire service area. One of the
public meetings was held in Mountain View. It is anticipated that
the ordinance will be adopted in the other jurisdictions immediate
ly following adoption by the Palo Alto City Council.
-4-
CMR,cg2:0
..... ---~ ... ~~---. ....... ~ .... --, ',,""'"
L',
-
i ,
!
;--~ .
'''"'' ~
\
\
1
t ,
\
\
\
~ ,~;:-.
._--
-
'-•
o
RecMmendatjoD
staff recommends that Council approve the attac:hed ordinance
amending sections in Palo Alto Municipal Code Chapter 16 to reflect
new requIrements ~or the red~tion of silver discharged from the
Regional water Quality Control Pla~t into San Francisco Bay.
R~Spectfully submitted,
PHILIP BOBEL
Engineering Manaqer
~Jj{jj~
DAVID G. ADAMS
Director of Public Works
Assistant city Hanaqer
co: Partners
Related CMRS: 192:0; 196:0
Attachments:
Se~er Use Ordinance
Photoprocessing Summary
A.
B.
C.
D.
E.
National Association of Photographic Manufacturers letter
Phototime letter
~estions and Answers
-5-
CMR:492:0
•
\
,
c
;
t •
, ,
)
"
-
D o • HTACfUIENT A
ORDINANCE NO.,~~-=~~
ORDINANCE OF THE COUNCIL OF THE CITY OF PALO ALTO
AMENDING CHAPTER 1£.09 OF THE PALO ALTO MUNICIPAL
COOE, RELATING TO PHOTOGRAPHIC MATERIALS PROCESSING
The council of the City of Palo Alto does ORDAIN as
follows:
SECTION 1, Section 16.09~OlO (Definitions) of Chapter
Hi.09 (Sewer Use ordinance) of the Palo Alto Municipal Code is
bereby amended by adding it new subsection (v) and renmnbering
subsections (v) and (v) to new subsections (v) and (x). to read as
follows:
] 6.09.010 [)efinitions. The fo:nowlng words ~nd phrases.
whenever used in this chapter. shall be as defined herein. Words.
terms and phrases used in this ~hapter not othervise defined shall
be as defined or interpreted or used in the pretreatment reg,ula
tions. Terminology for analytical testing shall be that contained
in -Guidelines Establishing Test Procedures for the Analysis of
Pollutants-, published at Title 40 CFR, Fart 136.
"
.... Me· ~'. ' .. '.G ;"~S".;'~nr:'!'e· .·y'?fttu...o.2~'t.h~! •... t.·",,!q).t1l!\t?'o;te .. o~t>i~ And i;.Iia~I.~ .. u .. ~"$P,,,r ........ ~ ... ~.,t.;?~~.
iYtJ~i -superintendent-shall mean the manager of the
Palo Al to Reg:~Onal Water Quality control Plant.,. his or her designee
or such other person as may be designated by the city manager.
-fwtJx} -U.npolluted water-means water to which no
constituent has"been added# eitner intentionally or accidentally ..
that would render such water unacceptable for disposal to storm or
natural drainage or directly to surface waters~
sECTION 2. section 16.09.106 is herebJ added to Chapter
16.09 (Sewer Use Ordinance) of the Palo Alto Municipal Code to read
as tollows:
~ION 3. Subsection ee) of Section 16.09.110 (stan
dards) of the Palo Alto Municipal Code is hereby amended to read as
follows:
1
L
:--__ ~. ___ ~ c
•
\
•
-",-.
..
.J-
I
I
I
I
-
J,
o o
eel In addition to the requirem.ents of Ca) and (b)
above J the following requirements shall apply where they are more
stringent::
Average
Concentration
Instantaneous
Par.ellleter Maximum ~
(eS9, -1/1.J
Oil ~ .. rease< (mq/L)
Oil. qrease (total). (mg/L}
Suspended solids (»gIL) ~,~
Total Dissolved Solids (»gIL) ~o-o'd""
Temperature, (Degrees F)
3D gp_ , < 30 .inutes:
All other times:
Fluoride (mq/-L-) 65
pH
.GOG
20
200
~j;m
l'b~6d
HO G !'
120 G II
65
11.0
<
5.5
• Gravity separation at a temperature of 20' C and a pH ~f 4.5
~~ ~ection (ll) of Section 16.09.110 of
Chapter 16.09 (Sewer Use Ordinance) of the palo Alto Hunicipal Cooe
is bereby amended to read as follows:
Hi.09.11Q Sblndar4s. The following standards shall
apply to all dis~arqes to the sewer:
(m) Toxicity.
toxic substances and the
disCharge:
The folloving is a DOnexclusive list of
maximum concentration allowed for each
Toxicant
Arsenic
Barium
Beryllium
Bor-on
Cadllium
Chromium, Hexavalent
Chromium Total
Cobalt
Copper
Cyanide
Formaldehyde
Lead
Manganese
Ker-cury
-------.--
2
Inst.antaneous
Maximum
Concentration Allowable
0.1 mg/liter
5.0 JIg/liter
1. 0 mgJliter
1. 0 mq/liter
0.1 mg/liter
LO mgfliter
2.0 mg/liter
1.0 mgjliter
2.0 »gfli ter
1.0 mgjliter
5.0 Eg/liter
0.5 mq/liter
1. 0 »g/liter
0.05 lIg/liter
•
•
\
\
\
\ .
\:'
.,:,. ;.-. '
< ~, -.
I
, I
~
-
o
Nickel
Phenols
Selenium
silver
!ine
•
o
1 .. 0 mgJliter
1.0 lIlq/liter
2 .. 0 BIg/liter
h9 \I.ll' l>gjliter
-~ilf'lIlq/liter
These li.it3tions set forth in this section are subject
to chanqe in tbe future as the requirements placed on the Plant
become more stringe.nt and as the process for estab1ishing tlle
industrial ~asta liuitations is refined ..
SECTION 5. Section 16.09.111 is hereby added to Chapter
16.09 (Sewer Use Ordinance) of the Palo Alto Municipal Code to read
as follows:
16.~9.111 Requirements for Pbotographtc Materials
processing, Cal All pb<>toprocessors shall comply with either
subsection (2) or subsection (3) of this subsection (a). Persons
'WhO folly comply with subsection (3) shall not be requ.ired to
obtain an i.ildustrial waste discharge penait pursuant to Section
16.09.020, unless required to do so pursuant to other sections of
this chapter, but shall be required to meet all applicable
wastewater discharqe limits and requirements.
(1) Definitions.
(il -photographic Materials processing-. For
the purposes of this section .. photographic materials processing
shall lDean developinq silver-bearing film, including x-ray filllr or
ph«ographic paper.
(ii) ·Photoprocessor-.. For the purpose of
tbis section, any person vbo owns a pbOtograpbic ~aterials
processing system .. or conducts photographic zaterials processing,
including a business that does photographic materials processinq or
any person who engages in photoqraphic materials processing ..
(iii) -Spent Solutions-. For the purposes of
this section, spent solutions shall mean spent fi~er. bleach fix,
stabilizer frOG washless systems .. silver-bearing. cleaning solutions
and functionally similar solutions other than wasb.ater.
1
•
, :~-
\
\
\ ,
\
,
L~~
'\ ,-\'
•
.. -, .............. ' .. ... 'J
-.
'.
•
,-
,
I
1
1-
I
-
. --
(v) ·Washwater-.. For the purposes of tllis
sectIon ... washW"ater shall mean water th.l't has been used to rinse fix
or bleach fix from photographic film or paper.
with this
facilities
consistent
~2) Silver Removal System. Persons who ~mply
subsection (2) shall install ana operate 1n their
a silver removal system, in a manner which shall insure
compliance with the following effluent standards:
(iJ The JIIaximum allo'Wable discharge concentra
tion of silver shall be 1.0 ag/liter for photoprocessors that
subuit documentation satisfactory ~o the superintendent evidencing
utilization of one or more of the following technologies:
(A) Wasbless mini lab equipment; or
{Bl A water reclrculatiIlij systeD tl:!at
reduces washwater consumption by a ~inimum of 60%. ~ reduction
shall be based on manufacturers' lDinimum recommended wasbvater
rates; and achieveme.nt. of such reduction shall be documented by the
pbotoprocessor to the satisfaction of the superiDtendent~
«ii) The maximum allowable discharge concen
t.ration of silver shall be 0.5 mgJliter for all silver removal
facilities not covered by subsection (2)(i) of this section.
(iii) All spent solutions and vashvater that
are not sent. off site shall be treated to insure consistent
ccmpl iance with the effluent standards set forth in tl:lis subsection
(2).. Silver remcval trom washwater sball be conducted in a manner
that does not reduce the effectiveness of the treatment ot spent
solut.ions.
(iv) The pbotoprocesscr shall sample the
discharge at a frequency determined by the superintendent# based
upon the flow rate rrom the facility~ However# in no event shall
sampling be do:'le less frequently than once a month. A duplicate of
each sample collected shall be kept. for the use of city inspectors~
A sampling port shall be installed in accordance with specifica
tions set forth in the wastewater discharge permit~
(vi) EVery person owning or operating a silver
removal system shall cause such system to be serviced at least once
per year by the manuCacturer r equipment distributcr r or qualified
conSUltant who shall certify that all ~quipment in the systea is
functioning in accordance with the manufactcrer's standards for
such equipment. A record of system service shall be lDaintained at
the facility 'Where the system is located# and be available for
inspection by city inspect~rs upon request~
4
L
\ .
\ ,
•
of-
•
--1-. i:
r
o o
(vii) EVery person intending to comply 1o'ith the
provlslooS of this subsection (2), sh~ll submit a compliance plan
to the superintendent on or before April 16 1991~ The compliance
plan shall contain a description of t.be silver re:n,oval system and
any regeneration systems to be used to meet the discbarqe li.its
set forth in this subsection (2).. The compliance plan shall
include, but not be limited to. equipment specifications., vaste
vclUlrle es.timates, and proposed procedures for sampling and testinq.
No person shall commence operatinq a silver removal system after
June 30. 1991 without baving submitted a compliance plan to the
superintendent at least 45 dByS prior to commencing operation of
sucb syste •.
EVery peer-on intending to comply vi th the
prov1s~ons of this subsection (2) shall sUbmit an annual report to
the supel'intendent on or before February 1, 1992 and annually
thereafter. The annual report shall contain the following
information for the preceding calendar year:
(i) Type and descrIpt.ion of silver removal
proce9ses and any regeneration systems employed;
(ii) AmoUnt or spent solutions generated;
(iii) Mount of wasbwater generated;
(iv} Dates of equipment servicing:
(v) Description of any major cbange"s in
equipment or operation; and
{vi) All waste~ater sampling data.
(3J Off Site Disposal. Persons who comply ~ith
this subsection shall ship or cause to be shipped off site~ for
recovery or appropriate disposal, all spent solutions or shall
regenerate all spent solutions on site.
Storage, shipment and disposal of spent solutions
shall be in accordance with all state, federal and local require
ments ...
Every person ~bo complies with this subsection (3J
shall maintain, or cause to be maintained~ records that detail the
purchase date and quantity of all new fixer~ bleach-fix~ stabilizer
and functionally similar solutions kept or used by such person~
Sucb person shall also maintain, or cause to be maintained,
detailed disposal records that include the date~ type and amount of
waste solution disposed of~ the name, address and identification
number of the shipper: and the ultimate destination of each batch
of 'Waste solution shipped off site. Such person shall also
maintain, or cause to be maintained, a record of the amount of
spent solutions regenerated on site.
5
L
, ,
•
•
";-.. '
-,-
t \. , ., ,
" .
"f"
-'
r-I
-
•
->::.~---
. ~ I
o o
All records required to be kept pursuant to this
subsection sh.!;.ll be kept for a period of three years at the
photoprocessing site. and shall be available for immediate
inspection upon request therefor by city inspectors during normal
business-hours.
Beqinning: on or before February I, 19192,. and
annually tbereafter~ every photoprocessor intending to comply vith
this subsection shall submit to the superintendent a summary of the
required records .aintained by such photoprocessor relatinq to
purchase and disposition of photograPhic solutions. The summary
shall be on a fora provided by the superintendent. Along with the
sUEmary. every pbotoprocesSQr shall submit a statement certifying
that it is in compl1ance-~ith this subsection and that the required
records are available for inspection.
Photoprocessors that comply with this subsection
need not meet the silver discharge limitations set forth in
subsections (2) (i) or (ii) of this section l nor the silver
discharge limitations set forth in Section 16.09 .. 110 (m) with
resPect to the photographic materials processing portion of their
operations; provided~ bowever l that those photoprocessors generat
ing a total o~ 100 gallons or more per month of spent solutions
shall be required to ~eet the silver limitations of subsection (2}
of this section with respect to 'Wasbwater. even if all spent
solutions are shipped off site.
(b) Compliance Schedule. The dates by which compliance
'With either subsection {a)[2) or (a)()) of this section shall be
achieved shall be as follows:
{1} All photoprocessors generating: less than 20
qallons per month of spent solutions sball Ii.eet the subject.
requirements on or before september 31 1 1991.
(2) All other phot.oprocessors sllall meet the
subject requirements on or before June 30 1 1991.
SECTION 6. Section 16.09.112 is bereby added to Chapter
16.09 of the Palo Alto Municipal Code (Sewer Use Ordinance) to read
as follows:
Cl~ce..!~\lru~1~6~" t>9::" ).1.11:/.1 Requirements for Dental Facil i ties Using
~ilver Alrtalqa_JII~ Persons who use amalgams containing silver
sball install amalgam t.raps on all equipment that might carry
amalgam w~ste to the sanitary sewer system. Each trap shall be
cleaned or replaced according to manufacturer guidelines and in a
manner that prevents any captured 'Waste fl'om entering the sanitary
sewer systeD.
SECTION 1. The Council finds tha~ this is not a project
for the purposes of the California Environmental Quality Ac~.
6
"
•
-,--"'''"
,
I
I
,
,
,
\
\
\
\
K '>
•
, ' , I
'-'<-::l' I A%~ I
/~.
"
I
•
. .
o o
SECTION 8.
comme.nceaent of the
adoption ..
This ordinance shall be effective on the
thirty-first day after the date of its
INTRO!JOCED:
PASSED:
AYES:
NOES:
ABSTENTIONS:
ABSENT:
ATTEST:
City Clerk
APPROVED AS TO FORK:
senior Asst. city Attorney
APPROVED AS TO CONTENT:
~na3er Environmental compli
ance Division
APFROVED:
Mayor
City Manaqer
Director of PUblic Works
-
/ .
o 0 AtTACHMENT B
AUGUST 1990 REVISED
SILVER ORDINANCE
• OPTIONS
• HAUl SPENT FIX.
• MEET 0.5 mg(1 LIMIT, Of
• MEET WASH'WATEA CONSERVATION CRlTERIA & MEET 1.0
mg(1 LIMIT
• WAS HWATER
• FACIUTIES > 1 00 ganons//month FIX ~ TREAT
WASH'WATER
• COMPLIANCE SCHEDULE
• >20 gallons/month FIX
• <20 ganons/moofh FIX
06/30/S1
09/30/91
•
\
, '~
j
~ . ,
'. ,
. ~,-'.
.' ~ '.
'~ .
"
I ,
-
•
-rs-\'
i',., .
, :.-..
___ :-, ___ ~ ___ ~~ nsAt_g:1I!"D;t\:~ 'C1<-"
(,I:····· o
SILVER ORDINANCE SCHEDULE
Metals Advisoly Group (MAG) Meeling
DRAFT SILVER ORDINANCE
MAG Meeting
WORKSHOP -General
WORKSHOP -Haufing
WORKSHOP -Treatment
REVISED ORDINANCE
MAG Meeting
COUNCIl MEETING - F .. st Reacfmg
ORDINANCE ADOPTION
HAUUNG PROGRAM DECISION
WORKSHOPS
ORDINANCE COMPlIANCE:
>20 gallons/month
>20 ganons/month
"
03/90
05/9.0
06/00
07/90
08/~
08/00
08[90
08/90
00/90
12/90
02/91
06/91
09/91
-~; ":",,-~-:-'
.
"'~,~) j ....... , " .. -; ..
'.
: ... ~~'
•
r·~.···
.'.'
, "," ,"
" ;l
-
'" I f 1\U"lIVl~nl I v
l'ATlOl'.U ASO,.U,ON OF PHOTOCR.oI.PH1C /Jl 'F.oI. ("Tl'R£ RS. ISC
SSO M.amaro:"'«l Avem..oc:. Han-i!!oOn, Ne .. Yor" JO,lS
ftt~ l'Iatt Cbadsey
legional ~ater Qualit1
.control Plant
2501 EmbarcaderQ ,..,
Palo Alto~ CA 9430)
Tclcphonr 914 • 69S-7~3
Fax 914 .698-,609 Too 6719986
Subject: c.~abllit7 and Cost ASSe&5~Dt of Silver ~ecover7 Systecs
Dear Platt:
I a. ,leased to represent the Rational As&ociatl~n of Fhotograpble
ft4nufact~rer. (RAPM) 1~ providici your office .n~ the Pletals 1eductlou
Advisor, Group w1~ thl, assessment of the capability aod cost of currently
available silver recover, "stemsa This assessment ia provided for discus
,Ion at Jour Jo17 Iltk worksbop OD compliance to the proposed 511v~r limi
tation of 0.25 malL OD '~scbarged wastewater for pbotoprocessQrs and I-ray
fadlitIes ..
There are three b8SI~ techooloeles Dse4 to recover silver from pbotographic
and I-ray ,roces.[ng sol.tiou. today. These are electrolytic~ metallic
replacement. an~ 10u exchange. SlIver exists 1. fiz. bleach-fiz. vashwaters.
and some stab.f-l1zer-a 1'. the. fora of • silver-thios-ulfate complex ..
Ia electrolytic recover,. an e1ectrle current 1. ~sed to reduce the Bilve~
tk:fosalf4te to metallIc silver. whIch deposit5 OD the cathode 00 the cell.
It!1 silver extstl a. almost a pure metal Whicb Is then physically removed~
fix BolllltIODS are. lIud e.as!er to desllve.r than "leach-fiX solutions .... -here
the IrOD complex tend. to oxIdl:e the ,lated 5ilver~ While th~ efficiency
of avaIlable systems varies. au average recovery of 90 percent caD be expected
with combined fIx and bleach-fix 501ution&~ the cost of these sy.tems will
be between $1.000 and $4.000. depending 00 sIze. It &bo~14 be noted that some
~leach-f!xer, coatel. cbemieall whic. POISQD electrodei and should ~ot be
added to electrol,tic .llver recovery operations.
r. =etallie replacement ~ecovery. metallic iron Is oxidized wbile 6ilvet is
reduced. ~ ~et resblt is removing &llver from solutIon and replacing it
v1~ iroG. These .yst~ are commonl, refer~ea to as caxtrldges o~ buc~eLS
which are packe~ wiLk &teel ~ool. frOD filing •• o~ Iron-Impregnated resins.
TheJ caD be used for all fia an4 ~leacb-f!x ~olutro~& aod~ wb~n two or ~ore
are used ia serie.~ one can ex~ect _ recovery efficiency of 95 percent.
The cost will run betvee. f60 and '100 per cartrid8e~ depending on &!ze
and must be replaced when the efflc!eDc1 drops.
•
"-
~} :.;"
>',: .
•
".
•
\
\
\
i ,.
. ,
Ik. ~tt Chaase7
Page two,
July 9. 1990
, .
o o
Tbere Ire two basle types of ion-exchange &3stems: conventional aDd lu-~1ta
preclpi~tloa. I~-sJt. s,stems cau be c&ed for fi~. ble8eb-f[~~ and Itabi)l%e~
solation. a~d fo~ wa8bw.terl~ but must be used ia combination with el~etro
l,tie recovery. Coaventlonal systems can be u5e~ fo~ wasbwaters. le~overJ
eff!c!eoc!el range from SO percent for proces&iol solutions to, 99 percent [or
waibwaterl. COlt. for tbese systems are aroun" $l~~OOO fo£ small operation.
sDd '2S.OO0 up for De~lum to large 0Far.ticns. It sboul! be note~ that tbese
systems mar ~eqQlr. the use of additional chamieal, aDd biocidel. Ia-5it.
precipitatIon requires the ~se of strong acId. and bases wbicb may also pos~
• tbreat to, p~rsoUDel and to the t[~tment plant.
Typically. fiz and 'leaCh-fix lol.tioes v111'cont.l. between 3.000 and 10,000
mgIL of .1Iyer. If oee assumel Bn .v~rage concentratIon of 4,000 m&/L~
electro17tr~ recover, oper.tlD& at 90% efficiency will reduce tbe concentra
tion to 40 -SIL. Final trea~t wlt~ ton exchange o~eratlDg at 90 percent
effictencJ' will allo., further :re~ucUon to " milL.
When the illatIon factor of vasb and w8stewatez from the facility is added,
tbe combinatioD of an e1ectrolJtle iystem tollo~ed by two metalltc replacemeot
cartridges t. Berle. viII &11o~ • pbotoprocessln& or X-raJ facility to coo5Is
teotlJ acbieve Q.S-3.0 ~fL of s11w~r I. their effluent dl$ehar&~. The
add:l tIon of loa ~ehange will alloW' 0.1-2.0 mgll. o,r s11 vel' to be coos I SUo tly
maiutaln~d. However, none of the technologies available today will allow
C.2S mglL of total slIver to be e~nslsteot17 met.
Process wasbwater •• fte~ frx and 'leaeb-f{z 50lmtlous ViII typi~ally ~octaia
0.2-1.5 mg/l of silver. Ion ~cbange II the onl7 availahle technology to
~ffect1ve17 treat tat. wolume of solatIon at these low 51lver coccentratlocs.
Some rroces5ins macblnes will allow ~e addltiOD of • low-flow wash after the
fiz or blea~b-flx, Whieb ceD be a~dea to Bol.tiOU$ for electrolytIc and
metallic replacement recovery an~ reduce the lilver concentration i. tbe W8sb
water.
Ib~ collect~ou .nd b&u!-away ~ptiou may be via~!~ for small volume nser&~ but
woula be cost-prohibItive for larger faclI!tfel. TypIcal haul-awaJ costs
todaJ are $1.50 to IS.OO/gailoe. If the slIver conteat {a greater than 5 ~g/L,
Ca11foroi. law reqdres the solutioD to be c!e&:1goated as. hazardous waste,
whicb 11.Its the number of baulers and increase& the ~o~t. If the eltJ Is
B~!D8 to requIre thIs baul-ava, o~t!OD~ It should !ns~re £hat service 1. and
8111 be Mv&tl.bl~. Wben one cocsiderl tbe total fm~act of troc~ hauling awa,
tbese lol.t[ODS followed b, lDC[ner.tioa~ thi. option probabl, reselts i. wor$~
poll~tioD for the CalifcraIa environment thau the silver going into the bay.
•
,
t"-• t
l
~
>-~-"
-'-~~-:
,
\ ,
\
<> -.
,,.-'
. "
\
\
"
"
,-
-
..
, .
. , .
lk. Flatt Cha~se1
Page 'three
Jul,1 '. 19 90
o
"--,"~2'""" .. _'?"_ 't--"""'_' __ .--"7 ..0-..... ':: "'.~'<"_, ____ . ___ ~.:..__
o
J must .1sc polDt out ~t tndustIJ ~a. I~~eratea sufficient data to indicate
that I U vee-II nd thez: an env:lrolUlleutel nor .. beal th hs.z..,rill. atld has. p"-ti tioue4
tb~ Fe~eral EPA to remove .IIver as • regul.:e« chemIcal {rom both 4ritik1na
vater aDd waste cischargea. EPA ba. agreed with tb!. posJt!oa and publisbe~ ia
the Federal Iegilter of ~ovember 13~ 1985 (SO II 46936) • proposed rul! for
the National PrlmarJ DrltikiUl ~ater 1eSD1.tl~ns 18 whIch •• ecommende~ Maxim~
Contaminant Level {~) for .IIver wal not proposed. In sub6eQueot froposed
rulemaklng published I_ the Federal le.ghWof Play 22. 1989 (54 n 22062).
EP£ ODce agar. reiterated it. posItion of Dot proposIng a ~ximum Contaminant
Level (KCt) for Ulvet because it do« not pose. rhk to beal tlI tiC tile:
e~v!ronmeota EPA fouod that the only adver5e effect fro~ exposure to .tlv~r la
b~ul la .~&yrt •• a greying of the: ,ki. aDd internal orgaus. £fA fouDd argyria
to be: a ~o8mett~ effeet and no~ a health effecta ~£t rece~tl~ t. ~e Federal
leglcter of ftarcb 29. 1990 (55 FI 11798)~ EPA ie causlderiog the ael~tfoD of
silver fro. the list of Toxicity CharacterIstic fTC) constftuecte.
1 would urge the State of Caltforala. the reg10nal Bay .rea~ acd the citIes of
last Palo Alto~ Los Altos. ~ouDtar. Viev aDd Palo Alto to refraIn from lo~erlDg
the silver Ii.ltation. until the EPA proposal to remove s1lver from the regHlated
chemical listings II fiDallzed.
NAP! ~l!eves that taellitlea sboul' ~tllfze the best technolog1 for slIver
recovery suitable for Cherr operations. RAPM supports the requIremeDt tbat
appropriate silver recover) systems .~st ba use4 by all facilities and wonl. be
,leased to assi.t I. draftiDl recommen~atlocs for these sy5tems foe all pboto
JroeessiQi acd X-r.~ f,cll1tiel i. tbe area. Please let gS kDOV if ~e c8n be
of further a611.~ce.
S!tlc~reI11 . .--"')
for RiJ'1I
UJjll
\
\
\
\ 'I "0
\ ,
\
•
•
. \,
...
I,
I '.
I
••
.:.~
•
.1\1 I~Mr:.I"'1 u
}~Io Photolim() o
. \
July 20, 1990
Mr. Phil Sobel. Manager
Environmental Comolian<e
RegioMal water-Oual it)' Cor,tr-ol Plant
P.O. Box l02~C)
~s.o1 Embarcadero ,,{ay
Palo Alto, CA 94303
Re: Si.lver ReductiOf'l Ordinanc.e
O-ear-Mr. Sobel ..
The prop.osed sewer ordinance lS a very seriOl!s con<:ern to
Phot.ot ime.
Pho!.otiD',e is a larger than aver-age retail photofinisher 1n
t~e 100 to SOO gals/mo cete~~Yr Phototime uses RA4. C41 and
E5 ~nemistry and p~e5ently USES sin;le stage silver recovery
vnits. either electro1ytic O~ metallic dlsplacement canister
tyee 00 all machines.
The prob1ems faced by yowr office are appreciated B~d as an
E,,-..ironmental'y conscious Of"'ganization. PMototirrle ;s
committed to full comDliance 'With environmental regulations.
'We have reviewed the p.r(')yosed' ordinance I attended' the
","Of'".,shops ar>d had' <l'iscussions with P-':att Chadsey of )IOU\"'"
staff. 'We appreciate this OpCOf'"tunity to ",resent our concern
and yoor 'IIIilling-ness to listen to tiS and possibly alla .... · for
some f;exibi1ity in ~tructurin'il the fina.l vers,on of the
O<'dinarrce.
Our first and EnOst serious concern js that the proPOsed
ordinaxe llrllits of 51 lver discharge into the se .... er of 0.25
mg/l are probably 'Lmattalnab~e I;jiven. 8\(ai1ab~e technology fo,r
an operator in t~e '00 p~us ga1s/mo category.
Tnis concern is based 00 c.orwerse.ticr.s 'WE have had 'IIo'ith
reputable. eQuipment e:u~,pliers soch as Eestrr.an. Keda.r..:. DreW'.
an.d CPAC. Tney all basically agree tr,at the 0.25 1119/1 1e..,e1
can only be reached' at optimum conditions an-a cannot 'be
mair,tained' .... ithout the sen'Tces of something slJch as a full
time chel"llfst. and 1 abof' a tOf'"Y 0 " This assumes a tf"fple stage
recovery system ~lth an electrolytic wnit ~ith t~o tra;ling
metallic cH5P~acemer,t canisters. Substitution of an 1011
e~chanse u~;t for one of tne canisters ~ould not improve t~e
syste~ fer our typical b~each/fi~ -fi~ 501uti~$.
P.hoi~,1rc:
1315 S~rd SI\oQpor-og ~
P;flcl1ol%ri CAS43CC
(0::5, 32e .1'5e1'
.-";..
•
,
,
,
-.
. :~.~
'>.:i
'*"
•
.>-r· ..
-
•
,
"
/ ~~~
Photo1i~
Phi) Sobel
Page Two.
July 20. 1990
_~,.:.._, __ ~_.....:.,.,.,.-;...:_,.;..--.......:...~.,.<~ji;.J,f:1-",,5t -' a.: ;-', , ~,-~---,~ ..
o
AS near as ,.;e car"l determine. the best resu1ts that ..... e cou1d
achie'ife with tJiis type systelD ..... ould be 1.0-to 0.5 mgll silver
discharge.
The p~oposed 0.25 mg/l limit then forces user5 in Our volume
.cate~ry to ship off-site aH discharge. !n our case thet
a~~ts to 100 to 300 ga1s/mo. This represents an e~rmovs
burden in sto-rl!lge. 1"lan<:$ling. shlppin'g .. ar;.d disposal or
treatment costs .. both physically 8~d economically.
This is our prfmary concern. Our reQuest js that limits b~
established based on volume discharge rat~er than an ~cross
t"'e board limit. Here are ou'r arguments for this position;
'I. Th.e !.r-,alytic3l mod'el used to derive the 0.25 mg/l
l;~its may have !ssurnej all users will discMarge
0.25 mgll ~hile in fact a v~ry large percent of
users (say over 9D~] ""ill elect to ship all ~aste
resu~tin9 in a zero discharge. T~ese lero
d;scha~Qes shoul~ be a~ailable as a credit in t~e
mooel !9ainst the few ~5ers t~at will elect to
pursue on-site treatment ar~ dis,ctlarge.
It is ~55u~ed all s~611 users, certefnly 10 sals!~o
and pOssibly u'p to 5-0 gals/m~ o.r more tor.'ill elect to
shio ..... aste fro~ an e,:oncll",cal basis, i.e._. ccsts to
sf;ip !5 gals/mo at $5!gal are only '2~./mo. ~e 5 92:1
metallic displacement canister costs f45 with very
ouestio,..,able econotric recover)' from the refiner (our
experien~e fs ~e seleom recover our costs on
meta 11 TC car,isters).
2. Al10waxe s'hov1d be Ir.aae fc:r certain volume (10-0 to
300 galliflo) users to discf",cr-ge at UP to 1 IrIg/) b\ ... t
Ildt.h lc ... ~r ob5ect'ives 'Of s.e.y 0.5 mg/l. This mei!\r'1S
eo-uipmer-,t an.d service procedures mu€:t be dE:sig"',e:d
and follc ..... ed to achieve lowest possible level .. bt.Jt
cQmpltance w~Jd b~ ~t an in-practice ac~ievab1E
1 eve 1.
3. Vert lar-ge us~rs ~ucn as Koda1ux or hcsoitals are
not affected by any cf these eMarges.
.... Some gro .... ision or allo""an.ce should be 1'!1acfe for IJSE'rs
who have replaced _ash type Dh.otof;"nishiog e'Quipment
~ith the ~ewer. environmentally saving ~as~less
sYstems t~!t in Phototirne~s caSE. reduced ~ater
~sage by 10 gp~ or ~~.OOO 9als/mo~
~ -. \,
\
\
\ ""
\
V
.::J-.... '.". " . : .
' .. -..
---
.. 'i~! Photolil\':) 'I .... : !
! ~ --
o
Ph.' Bo~.l
Page Three
July 2(>. '990
These ~ac~ines ~ave provision to convert back to
\!lias" chemlstry~ A .... ash C;l.od~ of operation c("'o¥io-es a
S~:, di1ution f~ctcr. Cost factors are
;ns,g~ificant as the higher ~ater and $e~er COsts
are aff-set by lo~er ~ash type chem,stry costs.
Nobody ~ants to ~ b~ck to ~as~'tyoe cperaticns~ but
some ~lTo~ance s~'d be made for this
environmentally impo~tant feature.
On our part. Phototime wi1:' comn";t to ~n.sta11ing a trip'le
recovery ~ystem t~rovgh w~ich 61' bleachjfix -fiKI and other
silver beering liQuids are procEssed; to e$tablish an~
enforce eo careful monito.,.-ing ar;:j' ser~icin9" of this system:
freQuent samplin9: and a ~OOgerative posit'cn with your
office for on-9Qing compliaoce.
"'e would be pleased to ~et lI/itfi you t.o discuss any aSPects
~f these concernSr
5in-ce!'"e1y yours.
S~U·~cJ
Stephen H r Shepard ~
President
S4S: c1".g
cc ~ fIoIatt Chadsey
Joh:; Clifton. Keeb1e .. Shu:~,at
~ark Teal. Phototime
•
,
I
,
. -
.J.
!.
i '. ;,i
ff
,
" ,
,
t
I ,
f
•
o
Ouc$~&~~
J:"4C}" SHeEr
7he 8asi$ Of fie &1ve. ~ Pr¢Qrilln
~~fJeQ-~
~ About ~Iflg waste OIt-$it
e ~iJiSlrativ$ Ot..e~ ~
r~Q_ . On-Site rrea~ Cost
.-~'<ICI'l$ ~ On-Site rrea~ ~8Ilon at Orner Plants
1-2
9
'.
.'
•
f ~:>;;;.
f, <~
': ,
. ,
t J: .
", h··· .....• ·
I " " J
I
: "
o o
Questions Raised in the Public Participation Process
THE BASIS OF THE SILVER PILOT
PROGRAM
1. O. IS TllE PlANT DOING ALL IT CAN TO REDUCE SILVER IN THE
EFFLUENT?
2.
A The Plant currently removes about 85 percent of !he incoming silver.
HoNever, Po remcNe signiflCanrIy ~ woufd require instanation of "reverse
osmosls"/echno1ogf at the Plant. k;cording 10 recent sludies, the costs of
consl!ucUcn, Increased energy requirements, and Io>JC brln6 disposal
aSSOCiated with reverse osmosis woul<1 a<id alleast $20 ml71ion per year 10
Ile Pfanr$ currenl aNIUaI operating costs -wmel> <Va paSsed on 10 the
ratepayers.
O. WHAT WOULD TllE COST FOR OlSCHARGERS/RATEPAYERS BE IF
YOU ADOED REVERSE OSMOSIS TECHNOl.OGY AT THE PlANT?
A Current sewage use rates woofd /rip/e. However, we also need 10 consider
the environrnentaJ cost of disposing of an estimated 2.5 minion gaJrons par
day of IoJCic M1e, !he wasteproduct of reverse osmosis; and !he pI>enom
enaJ7y higher energy costs aSSOCiated with that Iechnofogy. Estimated
energy costs aione were $5. B million per year.
3. O. WHY SOURCE REDUCTION?
A" In light of high financial and environmflfllal costs of reverse osmosis
1a(;MoIogy, Irea!ment plan persotYIel, regulator; agencies, and environ
menlal groups agree that source conrror musI be our first choice. Source
conrror should be far less costly kJr an concerned.
4.. O. WtlAT IS YOUR BASIC RATIONAlE FOR THIS PROGRAM -TO MEET
THE FUTURE UMITS OR TO PROTECT TllE BAY FROM ALL HARMFUL
SUBSTANCES?
A BoIlJ. The PJanrs proposed sl1ver requirements are designed 10 IOO6lBay
diSCharge Omits which become eRective .., December 199 L T/lo$&
diSCharge fimils are based on national criteria kJr profecting squatic
organisms.
1
------. -··-E--~-."'-... --.,,". < .t ~_ ~ •
-. . . , <, '.,..-' :.
-
•
< , ,
I
•
--,~
\
\
\.
\
,.,. -\'
-c-.
,-'.
" "
i '.-I
i
I
~ ,j
~
•
~ . ':~"""':
.-,. ~~~~" ""-~
.l .... ' :'IIIII;~riiI~iI.lsii!lii:t, .... , :...:..' ...• '-_, ~c-. __ ., . . ,
___ ~_~..--... ___ ..... __ _.:::_,_: _______ ... .,.~.",.,_"'J!:~.'~$.~4i"'''',_ .. _/ ..... ..;...
j
1
i
1
-
s. o.
A
6. O.
A
o o
AN 80 PERCENT REDUCTION IN SIt.VER DISCHARGE WAS REOUIRED
IN LAST FAll'S REVISED STANDARDS FOR REGlILATED INDUSTRY.
THe PROPOSED ORDINANCE REDUCES THAT AMOUNT SY 75 PER
CENT. WHY IS SUCH A LARGE REDUCTION NECESSARY?
Because most indus~ were alreadt removing sliver 10 we!1 beTCIW the ()/(j
standard, fast fairs ~ in file fiI!lll resulled in only a small percentage
reducfJon in Silver diSCharged by the Plait. The current proposal should
ret:J.Jce the plant's discharge 10 th6 required level.
WHAT ABOUT THe PROPOSAL TO REMOVE SILVER FROM THE EPA
LIST OF MATERIALS REGULATED IN DRINXING WATER SUPPUES?
EPA may temO\I8 silver tom th6 list of substances regulated in driilking
water, and possi/:>Iy from its Oefinitiofl of hazarrJous wast,., However. lhis
Siluation is not relevanIlo the sewer diSCharge lim.t OOcause the sewer Omit
is based on silver's bOO efled on aquatic organisms. SJ7ver is substantially
tnC(s bOO 10 aquatic organisms than it is 10 human Oe.ngs.
7. O. ISN'T IT TRUE TlIA.T ONLY DISSOLVED SILVER IS REALLY A
PROBlEM IN THE SAY?
Dissolved {Ionic} silver is the most bOO fomJ. However. lola! silver must be
regulated because silver can chang8 ils loon as it A'avels down the sewer.
lhlough 118 Regional Water Ouafffy Control Planl. and into 118 Bay.
8. O. HOW LONG WILL IT TAKE TO ASSESS RESULTS OF THIS EFFORn
A The proposed raquitements wO/JkJ Ilecom8 fully effective in SepTember
1991. It could take as much as an additioflaf ye3f' 10 secure fuR ccmplianca
and m&asur8 the combined resulls of /he program.
AGQf(),OIA 2 09101 r90
;:..;;'
rz· I ••
! . ---
9.
o o
QUESTIONS ABOUT THE ORDINANCE
Q. 00 YOU EXPECT ALL OF THE CITIES IN THE SERVICE AREA TO
APPROVE THE SAME AMENDMENTflANGUAGE?
A. Yes. Contracrs Wllh the paMer agencies require adopIion 01 the same
standards.
10. Q. WHAT IS TliE RATIONALE BEHIND THE STAGGERED COMPUANCE
DATES?
A. Our intent is 10 achieve compliance from the largest facl7ifjes first. and
Ihereb¥ 10 recJuce polential confusioIl when large numbers of facilities
atrempllo secure contracts with vendors all at Ihe same Ome.
11. Q. W1U TREATMENT OF WASHWATER BE REOUIRED/REGULATED?
A. Traarrnent of washwaJar will be requfred lor ad. facHities choosing 10 Irea!
spent solutions on Bile. Faci1ities optjng 10 have solutions ~aufed away will
nof be required 10 treat wa~W9ter unless Il1ey are ~pping more lila'! 100
gallons per monl1>.
12. O. W1U HOME DARKROOMS BE REGULATED?
A. The proposed orrJinance coufd be used 10 regufafe large photoprocessing
operatiOns .., f9SkJences. However, we envision a pub(1C e<:kICation
prog<am, nof an enforcement program, lor sma" hobbyisrs.
13. Q. WILL THOSE WHO CONSERVE WATER BE HELD TO TliE SAME UMIT
AS EVERYONE ELSE?
A. FaCIlities using systems Vlat cIo not discharge wa~water (sucIl as
'wasfJIess' or "pIumbIess' min/labs). Of Vlat aclJieve at fe;W a 60 percent
water saving below manufac/urerS' recommendatiOns, win be aIIcNIed 10
treat 10 a higher limit 1.0 mg;1, mfead of 0.5 mg;1 TfJIs win prrM<Je an
ilcentive lor waler conservation.
14. Q. WHO W1U BE RESPONSIBLE FOR SAMPliNG?
A. Samprmg wiH nof be required lor sma" facIlities Vlat choose '" haul sperl
solutions off-Sile. Facllj(jes choosing the Irearrnent opUon will be required
10 ooI1ecl samples monthly, Of more ffequenOy lor larger facilities, and repoi!
resufrs annuaRy 10 Ihe RegiOnal Wafer Quality Centrol Plant Samples must
be analyzed by Ii Cef(jlied laboratory.
3 09101190
•
".'" -.
.. " . "".':i:' ,:..
. ~'.
-.
.::
•
".-\ . ,
\
~-c-'"
. -~. ,
-
, '
15. O.
A
16. O.
o o
SHOUl.DN'T lARGER FIRMS HAVE LOWER UMITS?
Under Ih$ proposed ordinance, larger operafions win carry ac1ditional
responsibl1ity for rem<N1ng si" .. or. All large, non-pholograplljr; industries in
0Uf service area win be required 10 meet Ih$ stricter 0.25 mg;i limit Large
phctoprocessing firms will be required 10 sample mae trequenDy and /real
washwarer 10 ensure consistent compliance.
WILL YOU WRITE IN A PROVISION FOR AVERAGING SAMPLE
RESULTS?
A We have raised the maximum limft 01 0.25 mg;l (proposed in Ih$ May 1990
draft Oidinance) 10.50 mg;1. This cIlange in the 'maximum' limft shouki
have a (X8CflcaI eIrect sfml1ar 10 $Wi/ching 10 an 'average'limit
17. O. WOUU> A RECYCLER OR TREATMENT FACIUTY TAKING SPENT
SOLUTIONS FROM OTHERS AND TREAnNG IT WITHIN THE SERVICE
AREA BE REOUIRED TO MEET THE SAME UMIT?
A SUcII facJ1ities wouki have 10 meel the 0.25 mg;l limit applied 10 the '
indus/rial sector, unless l16y met 116 definition 01 "pholoprocessor'.
18. O. WILL EACH REGUlATED BUSINESS HAVE TO SIGN SOMETHING
INDICATING LlNDERSTANDING OF THE ORDINANCE AND INTENTTO
COMPlY?
A Faa1ilies cI1COsing 10 I1eaIlh6ir wasle will be required 10 submi/ a compli.
ance plan a/Jea(f 01 the compliance clate. Theraller they must submll annuaT
tepOr1S demOnstrating compliance. FacHmes /hat cpt 10 have thair spent
solutions hauled ott sile will be required 10 submil an 8I>n(JaJ cerliflcafiofl 01
ccmpIiatlC6, including some minimal supporting clata sucll as a summaJy
01 ma/erials purchase aoo hauling records.
19. O. WHAT ARE THE MECHANISMS FOR ENFORCEMENT? WHAT WILL
THE FINE BE FOR THOSE WHO DO NOT COMPLY?
" \
A Enforcement sanctions are Ih$ same as for other parts 01 the Sewer Use
Ordinance. In Palo Mo, fix example, these sancfior>s include admInistrative
orc1ers, civil penalties up 10 $6,000 per <fay, and Criminal penaJrles. Other
ordinances in Ih$ service area are v&y sfml1ar. Hcwever, smaR buSinesses
will be wamed and gNen ample vme and assistance in complying l>efore
any enforcement action is taken.
4 09101 r80
,
\
•
, , "
•
,.
. \
" \
. \
\',
, , ,
.j"" j
/
o o
HAVE YOU CONSIDERED HAVING MIO-SIZE PHOTO LABS -THOSE
WE'VE DESCRIBED AS BEING "CAUGHT IN THE MIDDLE·, TOO BIG
TO HAUL BUT TOO SMALL TO INVEST IN A LOT OF CAPITAL
EOOPMENT -MEET A MORE EASILY OBTAINABLE UMm
A. The 0.25 mg/I stanciartJ proposed in May has been raised 10 0.5 mg,A1o
. tMx:6 /he cost of compliance lor mkl-st:!e facl7iUes. The water
COfISefYarJon anowance -/he fimit increased 10 1.0 mg/I -will also reduce
fie economic burrJen on many mid-sized labs, esp!JCially mi,"-Iabs.
21. Q. WHY IS IT NECESSARY TO HAVE SUCH A lOW UMIT1 HOW WAS
THE UMIT CALCUlATED?
A. The fimil was OOok<alcuTaled from I'he stan<iard I'he &>gionaJ Water Quality
Cofl1rol Plant must meet lor disclJarge 10 San Frandsco Bay_ New data on
/he volume of sperl so{u!ions and washwarer generated in our S8IYice area,
and subsequent recaJcutatioos, have aDowed /he proposed limit 10 be raised
lor phOtoprocessors.
22_ Q. IS THIS UMIT LOW ENOUGH TO PROTECT THE BAY? OR IS THE
PROPOSED UMIT LIKELY TO CHANGE IN THE FUTURE -AND
RENDER NEWLY PURCHASED EOOIPMENT INADEOOATE?
A. There are no guarantees ilia! /he RagfonaJ Water Quality Control Board
wool impose more s1r1ngenl slan<iards OIl I'he Plant at some point in I'he
Altura. A small safety fador has been included in caJcufaOng fNs ffmil.
h<:NIever -so IIIat some lowering 01 the Plant disclJarge stan<iardS cou1d be
loIerareci IlIthouI CIlangfng /he proposed ffmil lor phaoprocesSOfS.
AGaR:! au 5 091'01taa
1<,'.
•
•
r"1-
, -'!-
\ ...
i
-I I ,
I
-
. '. , .
-c'
o
QUESTIONS ABOUT HAULING
23. Q. IF WE GIVE OUR WASTE TO A HAULER WHO SPilLS IT OR DISPOSES
OF IT IMPROPERLY. WILL WE BE lIABLE?
A , a hauler is n&gfigenl. the "aurer would likely be required 10 pay va/"Id
claims at least up 10 the limifS of lis liability insurance (which is required by
stare and ~af law). Generators COUld be /lable, W lhere are vety lew
examples of spent photoptocessing cl>emicaJs causing environmental
problems because of a sp71 or leak. fhe environmentai impact of sl7ver is
much preatel wilen the metal is discllarged 10 surface water. It shoukJ be
noted flat generators coord conceivably be held liable for sUCh discharges,
even wilen fie discharge occurs through a sewage treatment plant.
24. Q. HOW WOULD VARIOUS HAULERS MEET PALO ALTO'S UMIT? HOW
CAN YOU GUARANTEE THAT THEY ACTUALLY WILL MEET THE
UMIT?
A mere are Cl.Xrent1y two SI?ver recfaimersjhaulers doing business il E/le
service area, and Regional Ware.. Ouality COn/ro{ staff have ilvestigaled bo(!J
of them 10 our salisfacOon I1Ja! IIleir methods 0{ trealmenl and disposal are
proper, and that they can meet our proposed Timl1s. We would likewise
ilvesligare any other companies that offer hauling and recovery serviceS
here, so flat someone who is looking for a conlraclor can check with us
before signing up. However; we cannot guaranree Ihalany ptivare business
will continue 10 operare in 8 particular way.
fhis is one leason why Pfarl staff are looking info the leasibllity of
sponsoring a hawmg and recovery service for smell generators. We Wl1I
make a decision and recommendation about sUCh a program In December.
well il adVance 0{ I1>e compliance dat. for smal1·voIume dischargers.
25. Q. WHAT WOULD THE COST OF HAUUNG BE?
A Haulers have adVised us I1Ja! Ihe cost wourd be between $2 and $6 per
ga/7on, incTu<rtng £'ansporlatior. costs, once fO(J(es are sal up in Ihe service
area. Using Ws broad estimate, a denrist using five ga1/ol1s per mooCh
woukJ pay $10 10 $30 per month. A small photoptocassor using 50 gallOns
per month woukJ pay between $100 and $300 per month. Credit would be
applied kmard these costs based on !he llITlO<KIl of sl?ver reclaimed.
26 •. Q. WILL BUSINESSES THAT ELECT HAUUNG HAVE TO HAVE
WASHWATER HAULED TOO?
A , they generate more /han 100 gaRons 01 sperl/ solutions per month Vley
must eithet" hauf or /!eat washwa!er.
6 011/01/90
•
\
•
•
\
t
\
\ ,
\
k·····
'. _ .', : ,J; ~". , .... -."-
-
/
o o
ADMINISTRATIVE QUESTIONS ABOUT
ON-SITE TREATMENT COST
27. Q. HOW MUCH W1U ON-SITE TREATMENT SYSTEMS COST?
\ .
A. 11Je cost 01 compIiatlCfl for Bffeded businesses was a major issue rajsed by
the May 1990 drall Modif",.,aDoos 10 that drat! wNch are Included in !he
current proposal will be less cosay because !he discharge Dmit has been
raised from 0.25 mgj'1 '" 0.5 mgj'1 for aJ/ pIlOtOprocessors, and up '" 1.0
mg;Ilor flose who LJtilize water conservaUon measures.
The net cost 01 meeting the proposed requirements by on·silo lfeatment will
VSIY acexxding '" the lIOIume 01 waste produced. !he nature 01 !he
phOIographk processes employed, recovery equipment presently in opera
lion, and the market price 01 silver. All fact7ilies choosing lfeatment wilf
incur monfNy seI1-monitoring costs 01 $25 '" $100, depending upon flow.
Raccrri keeping(reptxfing Orne and expense will be minimal, requiring
S&IfJIa1 hours per year, more lor the largest facJ1ilies.
SmaJ/-10 medium-size x-ray fac,lities, generating up 10 100 gaI10ns per
month. may choose 10 k7stan relatively new technDIogy wf1jch ensures low
or zero sl7ver discharge and has a Tease cost between $40 and $200 per
monl11. capfUred silver may be resold '" oIfseIleasing expenses.
Mid-size phoIoprocessing facJ1ilies generaUng between 20 and 100 ganons
per month 01 spent solUtions may augment existing systems or instaJ/ new
on-sile recovery equipmeri a! a lotar, one·time equipment cost 01 $1, 000 10
$5,000. Annual operating expense wi/! t>e offsel by !he value 01 s'7ver
retXNered. In addition, capiIal cost can be recovfJled within Iwo 10 five
years 01 instanalion. Several hours per week of operator time will be
necessery 10 ensure proper system operalion.
l.arge fac,7ities which have substantia! /reatroent SjlSlems mayor may nol
need '" upgrade curreri equipmerilO tr.eet proposed requirements. 11Je
IoIal cost'" farge facifiUes Wi71 cfepend entirely Oil SjlStem·speciflCdecisions,
II>ough cost will be propor1kJnat1y siml7ar 10 expenses incured by mir1-s/ze
facl7ities
Water CGVlSerVaOOn equipmeri (nol required by the praposaJ) is expensive
10 purchase and ins(aJ/ -estimated at $10,000 10 $40,000. However, I has
a rapkf payback periOd 01 two 10 five years, based on water and energy cost
savings and reduced sewer fees. Fix and bleach-fix regeneraOon systems
VSIY in price from $500 per year lor leasing, 10 $20,000 per year for
purchase. 11Jese systems also resun OJ dramaOc energy and chemical cost
S81Ifngs. Water and chemical recirculafjon systems also have the added
7 OIJOli'80
",
-
.. '
\, -:
o
benefjt 01 buffering U1e lac/1ity against luture energy, sewer. and waf8f rate
increaS8S. Plant sl8ff beli6V8 "at V7a capIIal outlay /01 waf8f COilSeIYation
and solution regeneration equipment will be i'l /he beSt intetest 01 many
Targe IacnltiaS, due 10 ilia reduC&:i .oIume ()I waste and ilia higher silver
discharge nmil (1.0 mg/l), wM;l\ is more easily al!ajll8ble.
28. O. WHAT IS TO STOP PEOPlE FROM DUMPING IlLEGAllY. OR
DILUTING THEIR CHEMICALS BEFORE SAMPUNG?
A. fila PIart Wl7J worlr with individual businesses 10 make sure their disposal
pa8l$ meet our relJiremenls, and we will r"'lUffs sampnll!1 at prescribed
locations. Oiscflargers who opt /01 Ilauling wm be rrJqUlred 10 retain
cIIemicaJ materials purchase reccn:Js and haUling rBCflipts 10 {XOIIe V7at
chemicals V7ay use are disposed 01 property. inspections and some cily
sampling Wl11 be ccnWcred Of course, people who want 10 cheat can find
.!I way. But we baIievtJ ilia criminal penaltIes associated with intentional
dumpfng or tamperfng wirh sampling procBsS8S are sufflCfently severe as
10 SBI1Ie as a real detrvrent.
8 09101190
-------~··-L
, ,
"
•
-
, ~ .
• •
./
" .
o o
TECHNICAL QUESTIONS ABOUT ON-SITE
TREATMENT
29. O. DOESN'T METALLIC REPlACEMENT ADO IRON TO lltE WATER?
WILL THIS BE A PROBLEM fOR TtlE REGIONAL PL.ANl1
A. Metallic replacement cartndges add the same \IOIU/1l6 01 /ron 10 the
sofurions as silver is removed. Fortunately. /ron is not a pressing ~ i7
&'Ie Bay 8CQ$)IS!em. X coufri be flat futUre scientific data will document It
problem willi /ron i7 &'Ie bay. and fNIt this leChncIogy wiD have 10 be
repleced.
30. Q. WHAT DO WE HAVE TO DO WITH TtlE SLUDGE, BRINE, RESIN, ETC~
LEFT OVER FROM niE TREATMENT PROCESS?
A. rills material is cvrrently It hazarrJoos waste. and must be treated as such
-e.g., hauled off by It 6censed hauler lor sl7ver recovery. fklwever. the
silver COOf8nI 01 such waste is very '"gil. and mosI costs win be offsat by
the value 01 recfaimed sl1ver.
31. Q. WILL THE COST 01' HAUUNG BE HIGHER FOR PEOPLE SENDING
OFF SOUTnONS LESS RICH IN SILVER? FOR EXAMPLE, SOMEONE
WHO IS AUlEADY REClAIMING SOME SILVER, BUT NOT ENOUGH
TO MEET THE NEW UMm
A. Yas, beCause the value 01&'16 sl1ver i7 the so/vtkxIs wiD be less, and thus
otrselless of Ihe cost 01 hauling.
9
, .
•
\
"
•
, ,
\
\
" ..
~
-
o
REGULATION AT OTHER PLANTS
32. O.
A
WHAT ARE THE SILVER OISCHAIIGE UMITS FACEO 8Y OTHER
,",EATMENT PUHTS AROUND THE BAY?
Notth 01 DumbaI!on, Mure effective Omils are generally Nghel b&causB
/here T$ more mixing with fresh and ocean water U1arl we have *' r.e South
Bay.
33. O. WHY DOES SUNNYVALE HAVE SO MUCH LESS SILVER IN rrs
EffLUENT?
A. The Regional Water QuaRry Control Plant S9IV9S file ~ p/IoIoproc6$sing
operation in northem CaJiforr,;3 {KodaIuxJ, fIlrea major hospitals, and
numerous ]HBy fiJCJ7ities in addWon 10 many smaner industrial, rosiness,
and academic phO/OproCeSsing operarklns. SUnnyvale does rd hav& file
same concentratiOn of hJSe aCfMries.
10 09101190
•
. . •
~.'
-"[{~;' -
"~