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

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TSF, associated hazards, places where facility personnel would normally be working, entrances<br />

to roads inside the proposed TSF, and possible evacuation routes.<br />

40 CFR 264.37(a)(2) & 264.37(a)(3)<br />

Primary emergency authority will be provided by a trained EMT on-site at the proposed TSF.<br />

Secondary response will come from the Cortez Mine or local authorities, whichever can respond<br />

first.<br />

40 CFR 264.37(a)(4)<br />

Local hospitals will be made familiar with the properties of the hazardous waste stored at the<br />

proposed TSF and the types of injuries or illnesses which could result during its operation.<br />

40 CFR 264.37(b)<br />

Documentation will be kept if state or local authorities decline to participate with the<br />

Preparedness and Prevention Plan.<br />

5.3 Non-Critical Alarms Communications Strategy<br />

Non-critical alarms will be classified as those alarms for which human intervention will be<br />

required, but the alarm will not be related to a condition that in any way would threaten the<br />

safety of on-site personnel or the public (e.g., operational alarms that do not impact<br />

containment).<br />

The PCS will include monitoring and annunciation of process and environmental non-critical<br />

conditions. These conditions will be evaluated, and should they fall outside the specification<br />

limits, an alarm will be generated and annunciated via the operator HMI screens. Alarms are<br />

designed to require operator acknowledgement prior to resetting. HMI screens will be accessible<br />

via the proposed TSF’s Control Room.<br />

The Data Historian and Operational Systems will also be utilized as part of the alarm<br />

management strategy. All events including alarms, warnings, and notification events are<br />

designed to be recorded within the Data Historian for auditing and reporting, as well as for root<br />

cause analysis. Early warning events are designed to be generated wherever possible in order to<br />

minimize risk to personnel, equipment, and the environment.<br />

Events, depending on priority, will be communicated to personnel using a variety of<br />

mechanisms. These mechanisms could include a combination of portal visualization, automated<br />

emails, and automated report generation.<br />

5.4 Critical Alarms Communications Strategy<br />

Critical alarms will be classified as those alarms that have the potential to threaten on-site<br />

personnel, public safety, or the safety of the proposed TSF itself. All critical alarms will involve<br />

24-hour monitoring and notification. Access to critical alarm information will be provided to<br />

facility personnel (whether on-site or off-site), and PMR’s continuous-service monitoring parties.<br />

PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 69<br />

JBR Environmental Consultants, Inc. | HATCH March 2013

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