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

Outside of working hours, a notification system will be in place using the communications
infrastructure. A backup communications strategy will be provided via UHF radio. Off-site
security personnel will summon emergency assistance as necessary.
5.5 Required Equipment
40 CFR 264.32(a) & 264.32(b)
The required communication devices that will be used at the proposed TSF are portable radios
and telephones. These devices will be maintained in proper working order thereby allowing
facility workers to report emergencies and receive immediate emergency instructions per 40 CFR
264.32, 264.34, and 264.52(e). Installed alarm systems, mercury spill response kits, and a
suitable quantity of chemical absorbent will be provided at appropriate locations throughout the
proposed TSF.
40 CFR 264.32(c) & 264.32(d)
The proposed TSF is designed not be conducive to fire:
The facility walls are designed to be made from concrete, which does not combust.
Mercury has a fire hazard rating of zero.
Pallets, spill-trays, and shelving will be non-flammable.
The roof will have a metal liner.
Equipment within the proposed TSF may be electric. Incompatible materials will not be stored in
common areas. As first responders, facility personnel will be trained to appropriately respond to
fires and other emergency situations. Fire extinguishers will be available in the lunch room,
office area, and plant spaces. Provisions for handheld fire extinguishers will be in addition to the
fire suppression system, which will also be located in these areas.
Facility communications or alarm systems, fire protection equipment, spill control equipment,
and decontamination equipment, where required, will be tested and maintained as necessary to
assure its proper operation during emergency situations. Fire suppression equipment will be
tested monthly and flow tested annually. Fire extinguishers will be inspected monthly and
pressure tested annually.
40 CFR 264.34(a) & 264.34(b)
Employees will have easy access to an internal alarm or communication device at all times,
especially when handling mercury or mercury-bearing materials. Employees will be trained to
follow the posted evacuation routes and to assemble in the designated gathering areas. These
areas will be identified at various locations throughout the proposed TSF Building.
There will always be at least two employees on-site during normal working hours.
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PMR RCRA Permit Application, Dry Hills Facility Page 71
JBR Environmental Consultants, Inc. | HATCH March 2013