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

7.0 PREVENTION AND SAFETY PROCEDURES – 40 CFR 264
Subpart C
These Preparedness and Prevention Procedures have been prepared in compliance with the
requirements of the Federal Standards for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities found in 40 CFR Part 264 Subpart C.
7.1 Design and Operation of the Facility – 40 CFR 264.31
The purpose of the proposed TSF is described in Section 1. The characteristics of the hazardous
wastes to be managed at the proposed TSF are discussed in Section 2.
The facility will be located approximately 11 miles from the nearest population center. Access
will be controlled by fencing and automatic security. The building will be specifically designed
to follow best practices for mercury managing facilities. Exposed interior wall surfaces will be
made of concrete coated with epoxy enamel, designed to prevent secondary exposure to mercury
that could result from absorption of mercury onto porous construction materials. A metal liner,
coated with epoxy enamel will seal the roof, and separate the roof insulation from the interior of
the building. Air emissions are designed to be filtered prior to discharge and all transfer,
treatment, process, and storage operations will be conducted and contained within the building
structure. The proposed TSF Building is designed to totally enclose the processing operations
and operate under negative pressure with the aforementioned ventilation system operating
continuously.
Facility workers will receive training on proper loading and unloading procedures. This training
may include: instruction on machinery operation, safety equipment, waste identification, and
processing procedures.
Equipment redundancy is built into the facility design as necessary to prevent an inadvertent
interruption of operation. Measures preventing equipment failure are described in more detail in
Section 1.
Personnel protection measures include engineering controls, administrative controls, training,
and PPE. The following will be available at the facility:
Cartridge Air Mask - There will be two types of cartridge masks, full face and half
face. They will both be equipped with fittings to which contaminant-specific
cartridges may be attached. Each employee will be issued a mask and cartridges
appropriate to their work area.
PMR RCRA Permit Application, Dry Hills Facility Page 75
JBR Environmental Consultants, Inc. | HATCH March 2013