Precious Metals Recovery LLC RCRA Permit Application Dry Hills ...
Precious Metals Recovery LLC RCRA Permit Application Dry Hills ... Precious Metals Recovery LLC RCRA Permit Application Dry Hills ...
15.0 CLOSURE ESTIMATES – 40 CFR 270.14(b)(15) 15.1 Closure Estimate Program CostPro, a program developed by RS Means for the EPA, was used to estimate the cost of clean closure for the proposed TSF. 15.2 Closure Estimate – 40 CFR 264.142 An initial evaluation of the cost to clean close the facility has been completed. A copy of the CostPro data is provided in Appendix 15-A. When the RCRA permit application for the proposed TSF is determined to be complete, an updated CostPro data file will be provided to NDEP for review. The closure cost estimate will be reevaluated before the issuance of the permit. 15.2.1 Closure Cost Estimate Methodology The largest determining factor in calculating the closure cost estimate is the quantity of mercury destined for disposal. Since the quantity of mercury destined for disposal can vary depending on the stored hazardous waste arrangement allowed by the FSSMP (see Section 1.2.1), a conservative methodology for calculating the closure cost estimate has been developed. This methodology is described as follows: While the FSSMP may allow for any number of various arrangements, there are three different arrangements that maximize the foreseeable inventory for each different type of stored hazardous waste; that is to say, one arrangement maximizes the quantity of stored elemental mercury, another maximizes the quantity of stored calomel, and the third arrangement maximizes the quantity of stored spent activated carbon. A closure cost estimate was calculated for each of these three arrangements. In order to provide the most conservative estimate, the most expensive arrangement (i.e., the arrangement that maximizes the quantity of stored elemental mercury) has been selected as the basis for the final closure cost estimate. A summary of the closure cost estimate for each of these three arrangements is discussed in Section 15.2.3. 15.2.2 Closure Cost Estimate Summary The closure cost estimate is divided in sections for each type of permitted unit or area. The container storage section of the estimate includes: the site-wide line items for removal of equipment; transportation and disposal of the equipment; transportation and disposal of the building, and foundation; grading the site; and seeding the site. The container storage section also includes the standard line items specific to the storage area, which include: removal, transportation, and disposal of the stored waste; demolition of the PMR RCRA Permit Application, Dry Hills Facility Page 94 JBR Environmental Consultants, Inc. | HATCH March 2013
storage area (e.g., storage racks), decontamination of the area (dry sweep), and sampling and analysis for the area. Since CostPro does not include a “miscellaneous units” section, closure of the retort system is found in the “boiler and industrial furnace” section. This section includes costs for removing any waste residue present, decontamination of the two units by conducting a 72-hour “burn,” disassembly and removal of the two units and the associated equipment (e.g., dust collector, ductwork, etc.), and sampling and analysis of the equipment and area. Transportation and disposal costs of the equipment are included in the container section and are not duplicated in this section. The tank section of the estimate includes all storage and processing tanks at the proposed TSF. It also encompasses the filter press and the packed tower SO2 scrubber. These units did not readily fit in other sections. The tank section includes removal of waste from the tank systems, followed by a purge and flush. This section also includes the standard line items specific to the tanks, which include: removal, transportation, and disposal of the stored waste; demolition of the tank secondary containment, decontamination of the area, and sampling and analysis of the area. Engineering and Contingency Rates The closure cost estimate program adds a percentage to the subtotal to account for contingencies and engineering oversight required for a third party to accomplish the work. The engineering oversight cost is estimated at 7% and the contingency is estimated at 20% of the total. 15.2.3 Closure Cost Estimate Values As discussed in Section 15.2.1, three different closure cost estimates were calculated based on the three different arrangements that maximize the different types of stored hazardous waste allowed by the FSSMP. These arrangements are presented in Table 15.2-1. Table 15.2-1: Arrangements of Maximum Foreseeable Stored Hazardous Waste Inventory Quantity Maximum Foreseeable Stored Hazardous Waste Inventory Arrangement 1 Arrangement 2 Arrangement 3 Number of pigs 1024 16 16 Number of drums of 76 330 4 calomel Number of drums of spent activated carbon 60 4 346 Summaries of the closure cost estimates for Arrangement 1, Arrangement 2, and Arrangement 3 are presented in Table 15.2-2. PMR RCRA Permit Application, Dry Hills Facility Page 95 JBR Environmental Consultants, Inc. | HATCH March 2013
- Page 95 and 96: will be supplied in accordance with
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storage area (e.g., storage racks), decontamination of the area (dry sweep), and sampling and<br />
analysis for the area.<br />
Since CostPro does not include a “miscellaneous units” section, closure of the retort system is<br />
found in the “boiler and industrial furnace” section. This section includes costs for removing any<br />
waste residue present, decontamination of the two units by conducting a 72-hour “burn,”<br />
disassembly and removal of the two units and the associated equipment (e.g., dust collector,<br />
ductwork, etc.), and sampling and analysis of the equipment and area. Transportation and<br />
disposal costs of the equipment are included in the container section and are not duplicated in<br />
this section.<br />
The tank section of the estimate includes all storage and processing tanks at the proposed TSF. It<br />
also encompasses the filter press and the packed tower SO2 scrubber. These units did not readily<br />
fit in other sections. The tank section includes removal of waste from the tank systems, followed<br />
by a purge and flush. This section also includes the standard line items specific to the tanks,<br />
which include: removal, transportation, and disposal of the stored waste; demolition of the tank<br />
secondary containment, decontamination of the area, and sampling and analysis of the area.<br />
Engineering and Contingency Rates<br />
The closure cost estimate program adds a percentage to the subtotal to account for contingencies<br />
and engineering oversight required for a third party to accomplish the work. The engineering<br />
oversight cost is estimated at 7% and the contingency is estimated at 20% of the total.<br />
15.2.3 Closure Cost Estimate Values<br />
As discussed in Section 15.2.1, three different closure cost estimates were calculated based on<br />
the three different arrangements that maximize the different types of stored hazardous waste<br />
allowed by the FSSMP. These arrangements are presented in Table 15.2-1.<br />
Table 15.2-1: Arrangements of Maximum Foreseeable Stored Hazardous Waste Inventory<br />
Quantity<br />
Maximum Foreseeable Stored Hazardous Waste Inventory<br />
Arrangement 1 Arrangement 2 Arrangement 3<br />
Number of pigs 1024 16 16<br />
Number of drums of<br />
76 330 4<br />
calomel<br />
Number of drums of spent<br />
activated carbon<br />
60 4 346<br />
Summaries of the closure cost estimates for Arrangement 1, Arrangement 2, and Arrangement 3<br />
are presented in Table 15.2-2.<br />
PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 95<br />
JBR Environmental Consultants, Inc. | HATCH March 2013