Any chemists that can point us in the right direction to make our case? Koraks?
Well, I'm not a chemist, and I don't have the definitive answer on how much silver there is in today's materials. AFAIK 5-10g/m
2 is still a reasonable ballpark figure. Maybe
@ADOX Fotoimpex could confirm whether this is the case.
I can see how the absolute silver load might be part of an argumentation
if your argument is going to rely on a reasoning like this: "assuming we were to dump
all of the silver we process down the drain, and relate that to our total effluent (from flushing toilets as well etc.), we'd still remain below the permissible limits set by the regulator." You could then follow that up by "of course we don't do that and only a fraction ends up in the sewer, so logically we remain far below the permissible limits." IDK if the numbers work out that way; you can do the math based on your film & paper consumption/usage patterns, your water use (which evidently goes down the drain for the most part) and what data you can find on permissible discharge of silver.
A few things don't work to your advantage, however. Firstly, as I recall, you're in Europe (Norway if memory serves?) and I expect that the permissible limits to silver discharge are really, really. low. Secondly, I suspect that you'll qualify as a business, not a consumer/household, which may (likely) make you end up in a more strict legal regime. Thirdly, the question is how much credence local policy bodies will grant to essentially a layperson and their private opinion/analysis.
I think in your place, my approach would be a two-staged approach. First, try to figure out why you're being targeted. Environmental authorities have little interest in tiny little fish like the local amateur darkroom club. They're only likely to become nasty if someone has suggested/forced them to do so. Perhaps someone filed a complaint or tipped off the authorities and they feel pressured to act on this. You may be able to find out what's really going on and then see if you can deal with the cause. In cases like these, it's not unheard of that the authorities end up being reasonable if you can point out how/why the original complaint/tip was nonsensical and perhaps based on ulterior motives. They might simply drop the case once they recognize that it's just "angry Pete complaining about the photo guys after having made life hard on the local pub owner, the petting zoo volunteers, a supermarket because of the car park issue, etc." Figuring out what's going on starts by having a dialog with the authorities that goes beyond the immediate (supposed) issue of discharge and explores the context in which you're being targeted. A meeting and/or some phone calls tend to work well (as opposed to emails, letters etc.)
If that route fails and the authorities keep on the pressure, I'd to try and network my way towards a legal professional who is aware of how to deal with legislators running amok and becoming unreasonable (which IMO is what we're seeing here). They might be able to work out with/for you whether the environmental agency has the legal pretext to target you to begin with, and if so, what that basis is and how it might be argued against. It's possible that in this process, you'll have to rely on an expert assessment. In that case, it's of course going to matter what the expert says, but first and foremost who they are (i.e. do they have an academic title, an active research position at a recognized institutes, and some kind of credentials that make them a credible party). So even if it comes to that, what you, me or anyone else on Photrio says really isn't going to matter all that much, except maybe give some direction in which to look for an argumentation.
I'm sorry to hear that you're in this position. I'm afraid that the present legislative/administrative climate doesn't favor the kind of things we do, regardless if we're being sensible about what we do and how we do it. The fact that we work with "chemicals, oooooohhhhhh, baaaaad stuff!" poises you/us for an uphill battle to begin with. Public sentiments and overall ignorance sadly don't help much, either.