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

2.9 Screening for Ignitable, Reactive, or Incompatible Wastes
No ignitability testing on accepted liquid/slurry materials will be necessary, because neither
elemental mercury nor calomel is ignitable. Ignitibility characteristics may be present for the
“containers of debris” generated on-site if shop rags are used for cleaning and maintenance. This
characteristic will be evaluated when applicable, based on the proposed TSF’s “waste generator
knowledge.”
Based on the characteristics for the types of activated carbon used by the waste generators, it is
not expected that spent activated carbon with an ignition point below 482° F will be encountered
(see Appendix 2-E).
2.9.1 Ignitable Wastes
As discussed in Section 2.9, the waste that will be treated at the proposed TSF is not expected to
be ignitable.
2.9.2 Reactive Wastes
The waste that will be treated at the proposed TSF is not expected to be reactive with water. No
materials generated in the process or operations of the proposed TSF are anticipated to be
reactive.
2.9.3 Incompatible Wastes
A chart of materials that may be incompatible with the waste that will be treated at the proposed
TSF is presented in Appendix 2-B. Compatibility with the primary waste streams will be
evaluated before a new reagent or waste stream is introduced to the proposed TSF.
2.10 Bulk Liquids and Containerized Liquids – 40 CFR 264.13(b)(6), 264.314,
& 270.14(b)(3)
This section is not applicable, because the proposed TSF will not generate bulk liquids for
disposal in a landfill. Elemental mercury will be stored in containers (pigs). It is anticipated that
elemental mercury will be transferred to a National Repository once one becomes available.
2.11 Requirements for Incinerators – 40 CFR 264.13(b)(6), & 270.14(b)(3)
This section is not applicable, because the proposed TSF does not include an incinerator unit nor
will the proposed TSF transport waste to an off-site facility for treatment by incineration.
PMR RCRA Permit Application, Dry Hills Facility Page 63
JBR Environmental Consultants, Inc. | HATCH March 2013