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

Spent Activated Carbon
The chemical composition of the spent activated carbon is known and consistent. As discussed
above, the proposed TSF will use waste generator knowledge to characterize this material. While
these waste streams will not be routinely analyzed prior to being treated, the proposed TSF will
review all waste streams on an annual basis or any time the waste generating process changes.
It is known that some spent activated carbon may have economically recoverable amounts of
precious metals (e.g., gold). After the spent activated carbon is treated for mercury removal, it
may be sent off-site for recovery of the precious metal(s).
2.7.2 Other Wastes
Satellite Waste From Plant Spaces
Small amounts of non-liquid waste will be generated as a result of the proposed TSF’s operations
in the plant spaces. Satellite waste will be comprised of wipes, rags, towels, paper goods,
disposable booties, gloves, disposable coveralls, disposable sampling devices, etc. These
materials may be contaminated with mercury or other chemicals used in the processes,
potentially making these materials hazardous wastes.
Continuous air monitoring devices and discrete sampling instruments will also generate spent
sample cartridges or other small amounts of waste. The analyses that will be conducted on-site
will generate a lab waste stream. Disposable protective clothing, gloves, spill clean-up materials,
paper cleaning materials, and wipes will be generated during routine housekeeping activities.
The cartridge filters and activated carbon used in the hygiene exhaust system may become
contaminated with mercury.
It is not anticipated that diesel waste will be generated; neither vehicle fueling nor maintenance
will occur within the proposed TSF compound.
Hygiene facilities (e.g., showers and wash basins) may contain trace amounts of mercury, and
therefore will be managed as process wastewater. Operations within the facility will be
conducted in dedicated work clothing, coveralls, and shoes, which will remain in the proposed
TSF Building. Laundry facilities will be located in the proposed TSF Building and will generate
grey water possibly containing trace amounts of mercury. The grey water will be managed as
process wastewater system.
Treatment Residues
Should treatment residues not meet LDR standards, they will be either reprocessed or
shipped off-site to an appropriately licensed treatment and disposal facility. If it is
reprocessed at the proposed TSF, the waste code on the daily assignment sheet will be
completed as though the residual solid is original with one exception: the reprocessed
treatment residue will not be tested for parameters for which LDR standards were previously
met.
PMR RCRA Permit Application, Dry Hills Facility Page 58
JBR Environmental Consultants, Inc. | HATCH March 2013