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

9.0 MANIFEST SYSTEM, RECORDKEEPING, AND REPORTING – 40
CFR 264 Subpart E
Recordkeeping and reporting will be required for the following areas:
Health and safety.
Facility security.
Process monitoring.
Waste acceptance.
Inspection.
Container storage management.
Waste management.
Training.
The recordkeeping and reporting that will be incorporated into the operation of the proposed TSF
will be handled through the Operational Systems (Level 3 Systems) and Business Systems
(Level 4 Systems) as discussed in Section 1.5.2 and Section 5.
The recordkeeping and reporting will be based on the following:
Electronic recordkeeping and reporting will be used wherever possible.
The electronic recordkeeping systems will be able to store and print out high-quality
images including handwritten signatures (when necessary).
Recordkeeping and reporting for which electronic recording means are unavailable
will be done manually. Manual records will further be scanned and included in the
electronic recordkeeping and reporting system as appropriate.
Data collection for the population of records and reports will be automated using the
PCSs (Level 0, 1, 2) wherever possible.
In the event data collection for the population of records and reports cannot be
automated, tools will be provided to facility workers that will streamline data
collection and reduce the potential for erroneous data. These instruments will be able
to incorporate electronic signatures and provide date/time stamps as appropriate.
Procedures will be in place to ensure that all required data is captured (i.e., SOPs).
Records and reports will be available for inspectors.
The operating record will be stored on-site for a minimum of three years.
Hazardous waste training records will be kept on-site a minimum of three years.
PMR RCRA Permit Application, Dry Hills Facility Page 78
JBR Environmental Consultants, Inc. | HATCH March 2013