For more information, contact Kimberly Brandt at 512.329.5544.
Best Management Practices (BMP) are facility specific plans implemented by an industry sector for the purpose of controlling and reducing certain pollutants. Although not always a requirement, implementing BMPs can be a smart investment. The Silver Council and the Association of Metropolitan Sewerage Agencies (AMSA) have developed a program called the Code of Management Practice (CMP) for Silver Dischargers specifically for facilities processing radiographic and photographic film and paper to reduce and control the amount of silver discharged to local wastewater treatment plants. While several cities across the United States have already implemented this program, others are just beginning.
CMP does not rely on the concentration based discharge limits used by most wastewater treatment facilities or Publicly Owned Treatment Works (POTWs) to control the amount of silver discharged by silver users. Regardless of the amount of silver-bearing wastes generated, all facilities must comply with the same regulations when using concentration based limits. Thus, CMP presents an alternative method of controlling silver discharges. The CMP allows the facility to recover a recommended percentage of silver from their silver-bearing wastes based on the total gallons per day of photo processing effluent they generate.
CMP for Silver Dischargers has been adopted in cities across the United States, and has proven successful in reducing the amount of silver discharged, increasing the amount of silver recovered, minimizing the administrative burden on both the regulators and the silver users, and encouraging pollution prevention and water conservation efforts.
Implementation of the CMP program is being left to individual cities. They may choose to allow facilities to adopt the CMP in lieu of meeting numerical limits, or to assist in complying with numerical limits. Notices of Violation can be issued and fines assessed to facilities not complying with the CMP or numerical limit. Facilities could also face more stringent regulations including more restrictive local limits, self-monitoring, compliance monitoring, or other regulatory provisions if not in compliance.
Participation is simple. A facility must first make a category determination (Small, Medium, or Large), based on the total volume of process effluent or the total volume of silver-rich solution.
Small: Less than 1,000 gpd of total process effluent or less than 2 gpd of silver-rich solution
Medium: More than 1,000 gpd but less than 10,000 gpd of total process effluent or more than 2 gpd but less than 20 gpd of silver-rich solution
Large: More than 10,000 gpd but less than 25,000 gpd of total process effluent or more than 20 gpd of silver-rich solution
This category then dictates the percentage of silver that must be recovered from the silver-rich solution prior to discharge, and the frequency of analytical tests that must be conducted and submitted annually. Facilities may instead choose off-site management for their silver-rich solutions in which case no testing is required, and a Certification of No Discharge must be submitted annually to the wastewater treatment facility or POTW.
Zephyr has experience and can aid facilities with category determination, implementing a testing schedule, and setting up a recordkeeping system.