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

3.0 SECURITY PLAN – 40 CFR 270.14(b)(4)
Security and control procedures to be implemented at the proposed TSF will comply with the
security requirements found in 40 CFR 264.14, as adopted by NDEP. The manager of the
proposed TSF, or the manager’s designee, will be responsible for the facility’s security.
Unauthorized personnel will be physically restricted from entering the proposed TSF’s property
and the proposed TSF Building by the three barriers discussed in Section 1.7. Additional security
measures will be accomplished by surveillance, entry controls, and warning signs.
3.1 Facility Surveillance – 40 CFR 264.14(b)(1)
Among other things, after-hours security will be provided by locking the proposed TSF’s access
gates. Surveillance cameras will be monitored after normal business hours by security personnel
at the Cortez Mine. Initially, the facility is expected to operate eight hours per day, five days per
week. However, working hours are subject to change based on the proposed TSF’s operational
demand. Facility employees who may be working after hours will be supplied with an outside
phone and a radio to contact the emergency coordinator or the Eureka County Sheriff, if
necessary. Deviation from established security measures will be brought to the attention of the
proposed TSF’s Manager for corrective action upon discovery.
The proposed TSF is surrounded by a 100-foot-wide gravel perimeter for wildfire protection.
The 10-foot-tall privacy berm provides an additional wildfire protection barrier. Surveillance
cameras will monitor the property inside and outside of the privacy berm as deemed necessary
by the proposed TSF’s Manager.
3.2 Barrier and Means to Control Entry – 40 CFR 264.14(a) & 264.14(b)(2)
Unauthorized access to the proposed TSF will be minimized by means of physical exclusion
barriers as described in Section 1.7. The integrity of the outer perimeter fence will be evaluated
monthly via physical inspection. Any noted problems will be documented and corrected in a
timely fashion.
Controlled access to the RCRA area will be through a main security pass gate, which will be
located northeast of the proposed TSF Building. This main security pass gate serves as the main
entrance for facility workers, authorized visitors, service providers, delivery traffic, and waste
transporters. This gate will generally remain open during normal working hours and will be
monitored by the proposed TSF’s security personnel. All gates will be closed and locked at the
end of each workday and will remain closed during non-working hours.
All deliveries to the proposed TSF will be scheduled; thus, all deliveries will be expected by the
proposed TSF’s security personnel. Unscheduled delivery traffic to the proposed TSF will be
turned away. Incoming delivery traffic will approach the facility westbound on the main access
road, and will be directed by posted signs to the main security gate for further instructions.
Transport operators (i.e., vehicle drivers) of waste and non-waste deliveries to the proposed TSF
will be directed to the receiving bay, where they will be required to register with security
PMR RCRA Permit Application, Dry Hills Facility Page 65
JBR Environmental Consultants, Inc. | HATCH March 2013