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Precious Metals Recovery LLC RCRA Permit Application Dry Hills ...

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Sampling Containerized Waste<br />

The term “container” refers to receptacles designed for transporting materials (e.g., drums,<br />

flasks, and pigs). Sampling devices include Composite Liquid Waste Samplers (COLIWASAs),<br />

tubes, trowel, drum thieves, and tube samplers.<br />

Sampling of Tanks<br />

A representative sample of the waste will be collected from the side or bottom of each tank.<br />

Samples will be collected such that various depths in the tank will be evaluated if the<br />

material phase separates or contains multiple batches. Multiple grab samples may be<br />

composited to obtain a weighted representation of the tank contents. Sampling SOPs for<br />

each process tank will be developed and reviewed by the laboratory staff when necessary.<br />

Frozen Waste<br />

The proposed TSF will not sample waste that is frozen. The waste will be held in the truck<br />

unloading area until the waste can be sampled. A sample will then be collected as outlined<br />

in this section.<br />

2.7 Waste Characterization & Frequency of Analysis – 40 CFR 270.14(b)(2)<br />

& 264.13(b)(4)<br />

Waste characterization data can be found in Appendix 2-E.<br />

2.7.1 Routine Wastes<br />

Process Wastes<br />

The processes at the proposed TSF will generate a number of routine waste streams. These waste<br />

streams will be evaluated initially at the beginning of operations and annually updated to verify<br />

accuracy. The waste characterization will also be re-evaluated whenever the process that<br />

generated the waste changes or there is an unresolved discrepancy on a shipment.<br />

Elemental Mercury<br />

The chemical composition of the recovered elemental mercury is well known and consistent. As<br />

discussed above, the proposed TSF will use waste generator knowledge to characterize this<br />

material. Elemental mercury purity will be evaluated based on weight. While these waste streams<br />

will not be routinely analyzed prior to being stored, the proposed TSF will review all waste<br />

streams on an annual basis or any time the waste generating process changes.<br />

Calomel<br />

The chemical composition of the calomel is well known and is within the process design range.<br />

As discussed above, the proposed TSF will use waste generator knowledge to characterize this<br />

material. While this waste stream will not be routinely analyzed prior to being treated, the<br />

proposed TSF will review all waste streams on an annual basis or any time the waste generating<br />

process changes.<br />

PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 57<br />

JBR Environmental Consultants, Inc. | HATCH March 2013

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