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 ...

23.07.2013 Views

may then be transported off-site for disposal. The polyethylene drums used for calomel transport will be triple rinsed during calomel feed preparation; the cleaned drums can then be returned to the waste generator for reuse. 22.2 Waste Acceptance – 40 CFR 270.14(b)(3) & 264.13 22.2.1 Waste Acceptance Process The detailed waste acceptance process is presented in the WAP, Appendix 2-A. Containers are expected to be filled, closed, and labeled by the waste generator before being shipped to the proposed TSF. Containers will be accepted at the proposed TSF only when the waste is: compatible with the container, has been authorized in accordance with the proposed TSF’s operating permit, and the container has a visible label identifying the contents. In general, waste acceptance at the proposed TSF will be in accordance with the following: Calomel, spent activated carbon, mercury-bearing waste, and elemental mercury will arrive at the proposed TSF in containers, with accompanying manifests. The containers will be visually evaluated and unloaded. The containers will be staged in the receiving and inspection area. Containers will be randomly selected and fingerprinted in accordance with the WAP (see Appendix 2-A). If a discrepancy is discovered, the containers will be flagged and placed in a designated staging area until the discrepancy is resolved. If the waste is consistent with the profile and manifest, the waste will be received at the proposed TSF and directed to the appropriate storage area. 22.3 Management of Containers – 40 CFR 264.35 & 264.173 When not in use (e.g., being actively processed, inspected, transferred, etc.) containers will normally be stored on steel racks. An aisle space between racks of three feet or greater will be maintained. This aisle width will be sufficient to allow for the unobstructed movement of personnel, forklifts, spill control equipment, and decontamination equipment to any area of the plant spaces in an emergency. Sufficient access exists for inspection, emergency response, and fire protection equipment. 22.3.1 Closed Containers In storage, the normal condition for containers at the proposed TSF is closed. Containers that contain hazardous waste will be opened only to remove or add waste, or during treatment. PMR RCRA Permit Application, Dry Hills Facility Page 108 JBR Environmental Consultants, Inc. | HATCH March 2013

22.3.2 Labeling Containers – 40 CFR 262.30 through 262.32 All containers will be labeled prior to being transported. Transportation will be in accordance with the applicable US DOT regulations. Containers of elemental mercury intended for storage will be marked with the words, “Elemental Mercury.” Calomel containers intended for processing will be marked with the word, “Calomel.” Containers of spent activated carbon intended to be processed will be marked with the words, “Spent Activated Carbon.” In addition, the proposed TSF will only accept mercury and mercury-bearing materials from waste generators with the appropriate labels and markings on each container. Each container will be required to display the appropriate marking per NFPA Section 704, including a hazardous waste marking as follows: “HAZARDOUS WASTE – Federal Law Prohibits Improper Disposal. If found, contact the nearest police, or public safety authority, or the U.S. Environmental Protection Agency.” The waste generator’s name and complete address will be required to be clearly legible on the marking. Each label will also include the EPA Hazardous Waste Code(s) (e.g., D009). 22.3.3 Satellite Wastes Accumulated in the Plant Spaces of the Proposed TSF – NAC 444.8671 Satellites wastes, such as miscellaneous articles that may have been contaminated with mercury (e.g., PPE, gloves, tools, rags, paper, etc.), are expected to be accumulated in the plant spaces. Containers, specifically designated to collect satellite wastes will be located in close proximity to areas where these wastes are expected to be generated; these containers will be identified with labels indicating they contain hazardous waste, and in accordance with NAC 444.8671. 22.3.4 Waste and Container Compatibility – 40 CFR 264.172 The selected containers that are expected to be used at the proposed TSF will be compatible with the hazardous waste(s) they are intended to contain. 22.3.5 Inspections – 40 CFR 264.174 The storage areas are shown in general arrangement drawings provided in Appendix 1-A, and all containers stored in these areas will be inspected in accordance the Inspection Plan as described in Appendix 4-A. 22.3.6 Storage – 40 CFR 264.177(c) See Section 1.3 for details on elemental mercury storage. PMR RCRA Permit Application, Dry Hills Facility Page 109 JBR Environmental Consultants, Inc. | HATCH March 2013

22.3.2 Labeling Containers – 40 CFR 262.30 through 262.32<br />

All containers will be labeled prior to being transported. Transportation will be in accordance<br />

with the applicable US DOT regulations.<br />

Containers of elemental mercury intended for storage will be marked with the words, “Elemental<br />

Mercury.” Calomel containers intended for processing will be marked with the word, “Calomel.”<br />

Containers of spent activated carbon intended to be processed will be marked with the words,<br />

“Spent Activated Carbon.”<br />

In addition, the proposed TSF will only accept mercury and mercury-bearing materials from<br />

waste generators with the appropriate labels and markings on each container. Each container will<br />

be required to display the appropriate marking per NFPA Section 704, including a hazardous<br />

waste marking as follows:<br />

“HAZARDOUS WASTE – Federal Law Prohibits Improper Disposal. If found, contact the<br />

nearest police, or public safety authority, or the U.S. Environmental Protection Agency.”<br />

The waste generator’s name and complete address will be required to be clearly legible on the<br />

marking.<br />

Each label will also include the EPA Hazardous Waste Code(s) (e.g., D009).<br />

22.3.3 Satellite Wastes Accumulated in the Plant Spaces of the Proposed TSF –<br />

NAC 444.8671<br />

Satellites wastes, such as miscellaneous articles that may have been contaminated with mercury<br />

(e.g., PPE, gloves, tools, rags, paper, etc.), are expected to be accumulated in the plant spaces.<br />

Containers, specifically designated to collect satellite wastes will be located in close proximity to<br />

areas where these wastes are expected to be generated; these containers will be identified with<br />

labels indicating they contain hazardous waste, and in accordance with NAC 444.8671.<br />

22.3.4 Waste and Container Compatibility – 40 CFR 264.172<br />

The selected containers that are expected to be used at the proposed TSF will be compatible with<br />

the hazardous waste(s) they are intended to contain.<br />

22.3.5 Inspections – 40 CFR 264.174<br />

The storage areas are shown in general arrangement drawings provided in Appendix 1-A, and all<br />

containers stored in these areas will be inspected in accordance the Inspection Plan as described<br />

in Appendix 4-A.<br />

22.3.6 Storage – 40 CFR 264.177(c)<br />

See Section 1.3 for details on elemental mercury storage.<br />

PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 109<br />

JBR Environmental Consultants, Inc. | HATCH March 2013

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