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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 • . . • ~.' -"[{~;' - "~