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 ...
22.4 Number of Containers – 40 CFR 264.171, 264.172, & 264.175 While actual production rates are expected to be less, each year, until a National Repository is available, up to 190 pigs of elemental mercury may be added to storage at the proposed TSF. Assuming maximum production rates are sustained, the proposed TSF will reach its maximum elemental mercury storage capacity in less than 5 ½ years, unless a National Repository begins to accept elemental mercury during that time. 55-gallon HDPE drums will be stored in the calomel storage area. As designed, and during normal operations, the number of calomel drums in storage is not expected to exceed 76. However, as described in Section 1.2.1, the FSSMP may allow for calomel to be stored in other plant spaces. In the event the proposed TSF experiences a greater than normal influx of calomel, additional floor space can be made available, which would allow up to a total of 330 containers to be stored. 55-gallon steel drums of spent activated carbon will be stored in the spent activated carbon storage area. As designed, and during normal operations, the number of spent activated carbon drums in storage is not expected to exceed 60. However, as described in Section 1.2.1, the FSSMP may allow for spent activated carbon to be stored in other plant spaces. In the event the proposed TSF experiences a greater than normal influx of spent activated carbon, additional floor space can be made available, which would allow up to a total of 346 containers to be stored. 55-gallon steel drums containing waste generated from activities at the proposed TSF will be stored in the general storage area. As designed, and during normal operations, the number of stored drums containing this type of waste is not expected to exceed 10. However, as described in Section 1.2.1, the FSSMP may allow for this type of waste to be stored in other plant spaces. In the event the proposed TSF experiences an unexpected increase in production, additional floor space can be made available, which would allow up to a total of 346 containers to be stored. Note: this material is not expected to contain liquids, and it is assumed that in order for 346 containers to be stored, a minimal inventory of all other wastes would have to be kept. 22.4.1 Containers with Free Liquids Two types of stored materials are expected to contain free liquids: elemental mercury and calomel. Details on the containers for these free liquids are provided in Section 22.1. Containers with liquids will be stored in storage areas where secondary containment, described in Section 22.5, will be provided. 22.4.2 Aisle Spacing to Allow for Inspection – 40 CFR 264.174 In order to facilitate proper inspection of containers pursuant to 40 CFR 264.174, containers containing hazardous waste will be easily visible from all directions. The aisle spacing for the proposed TSF has been designed to accommodate this consideration. Mounted inspection mirrors may be implemented to assist visibility. PMR RCRA Permit Application, Dry Hills Facility Page 110 JBR Environmental Consultants, Inc. | HATCH March 2013
22.5 Description of Secondary Containment – 40 CFR 264.175 & 270.15(a) The containment system for areas where liquid hazardous waste is designated to be stored will be designed to have sufficient capacity to contain 10% of the total volume of liquid stored or 100% of the volume of the largest container, whichever is greater. The secondary containment system at the proposed TSF will consist of spill trays, bunded areas, sumps, and trenches. Secondary containment for elemental mercury will be provided by spill trays. Each spill tray is designed to provide secondary containment for a group of eight pigs. The spill tray as depicted in Appendix 1-A, is designed to contain 2,200 lbs of elemental mercury, which is the volume of one pig, and is greater than 10% of the combined volume of eight pigs. A sample calculation is presented as Appendix 22-B. An additional layer of secondary containment will be provided in the elemental storage area by the building envelope, which consists of a combination of epoxy coated concrete walls, floors, curbs, and trenches. The epoxy enamel coating on these surfaces is designed to prevent absorption of mercury. See Drainage Arrangement H340940-0000-50-015-0008 provided in Appendix 1-A. Containment volume calculations are included in Appendix 22-B. The largest type of container that is expected to be stored in the plant spaces will be the drums that contain calomel, which each have a maximum volume of 55 gallons; therefore, the secondary containment volume in the plant spaces is designed to contain 10% of the total expected volume of elemental mercury and calomel that can be stored. At maximum capacity, the total volume of these combined liquids is estimated to be 32,300 gallons. The building envelope of the proposed TSF (i.e., the volume of the bunded area), is designed to provide a secondary containment volume of 95,750 gallons, which is significantly larger than 3,230 gallons (i.e., 10% of the estimated total volume of liquids to be stored in this area). 22.6 Description of Containment System – 40 CFR 270.15 & 264.175(b)(3) Spent activated carbon containers and calomel containers will be stored in a common storage area. Containers that do not contain free liquids need not be considered in this calculation. For the purpose of calculating necessary containment volume, containers of spent activated carbon will not be included in the inventory of containers with free liquids. 22.6.1 Floor Design – 40 CFR 264.175(b)(1) The floor in the container storage areas is designed to be free of cracks or gaps and will be sufficiently impervious to contain leaks or spills until the collected material is detected and removed. The floor will be inspected in accordance with the Inspection Plan (see Appendix 4-A). Consideration of precipitation and run-on volumes for the storage area will not be applicable for the proposed TSF, because the storage areas will be located inside the proposed TSF Building. No precipitation is expected to enter or collect in the container storage areas. PMR RCRA Permit Application, Dry Hills Facility Page 111 JBR Environmental Consultants, Inc. | HATCH March 2013
- Page 111 and 112: Process Waste Solution A discrete p
- Page 113 and 114: ii. The sampling person removes a s
- Page 115 and 116: 2.9 Screening for Ignitable, Reacti
- Page 117 and 118: 3.0 SECURITY PLAN - 40 CFR 270.14(b
- Page 119 and 120: 4.0 INSPECTION PLAN - 40 CFR 270.14
- Page 121 and 122: TSF, associated hazards, places whe
- Page 123 and 124: Outside of working hours, a notific
- Page 125 and 126: Damaged containers will be placed i
- Page 127 and 128: 7.0 PREVENTION AND SAFETY PROCEDURE
- Page 129 and 130: 8.0 PREVENTION OF ACCIDENTAL IGNITI
- Page 131 and 132: 10.0 TRAFFIC - 40 CFR 270.14(b)(10)
- Page 133 and 134: Delivery frequency of reagents will
- Page 135 and 136: 10.3 Traffic Control Signs Traffic
- Page 137 and 138: 11.4 Surrounding Land Use - 40 CFR
- Page 139 and 140: 12.0 PERSONNEL TRAINING PLAN - 40 C
- Page 141 and 142: that are not land based. Closure of
- Page 143 and 144: 13.4.6 Types of Off-site Waste Mana
- Page 145 and 146: 14.0 CLOSED HAZARDOUS WASTE DISPOSA
- Page 147 and 148: storage area (e.g., storage racks),
- Page 149 and 150: 16.0 POST-CLOSURE ESTIMATES - 40 CF
- Page 151 and 152: 18.0 TOPOGRAPHICAL MAP - 40 CFR 270
- Page 153 and 154: 20.0 GROUNDWATER MONITORING - 40 CF
- Page 155 and 156: 22.0 CONTAINERS AND CONTAINMENT - 4
- Page 157 and 158: Figure 22.1-2: Dedicated Transfer C
- Page 159 and 160: Larger sized HDPE drums may be used
- Page 161: 22.3.2 Labeling Containers - 40 CFR
- Page 165 and 166: will be done on the new waste strea
- Page 167 and 168: 23.0 TREATMENT AND STORAGE TANKS Me
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- Page 173 and 174: decomposed in the Decomposition Tan
- Page 175 and 176: Figure 23.1-3: Waste Solution Stora
- Page 177 and 178: The Water Storage Tank will supply
- Page 179 and 180: Tank Caustic Soda Storage Tank* Hyd
- Page 181 and 182: 23.13 Recordkeeping A recordkeeping
- Page 183 and 184: 25.0 WASTE PILES - 40 CFR 270.18 &
- Page 185 and 186: 27.0 LAND TREATMENT - 40 CFR 270.20
- Page 187 and 188: 29.0 BOILERS/INDUSTRIAL FURNACE - 4
- Page 189 and 190: 30.1.3 Retort Operating Procedures
- Page 191 and 192: of 13.5 feet long by 4.7 feet wide
- Page 193 and 194: 31.0 PROCESS VENTS - 40 CFR 270.24
- Page 195 and 196: 33.0 DRIP PADS - 40 CFR 270.26 & 26
- Page 197 and 198: 35.0 REFERENCES American Society of
- Page 199 and 200: At the PMR Dry Hills Facility Open
22.4 Number of Containers – 40 CFR 264.171, 264.172, & 264.175<br />
While actual production rates are expected to be less, each year, until a National Repository is<br />
available, up to 190 pigs of elemental mercury may be added to storage at the proposed TSF.<br />
Assuming maximum production rates are sustained, the proposed TSF will reach its maximum<br />
elemental mercury storage capacity in less than 5 ½ years, unless a National Repository begins to<br />
accept elemental mercury during that time.<br />
55-gallon HDPE drums will be stored in the calomel storage area. As designed, and during<br />
normal operations, the number of calomel drums in storage is not expected to exceed 76.<br />
However, as described in Section 1.2.1, the FSSMP may allow for calomel to be stored in other<br />
plant spaces. In the event the proposed TSF experiences a greater than normal influx of calomel,<br />
additional floor space can be made available, which would allow up to a total of 330 containers<br />
to be stored.<br />
55-gallon steel drums of spent activated carbon will be stored in the spent activated carbon<br />
storage area. As designed, and during normal operations, the number of spent activated carbon<br />
drums in storage is not expected to exceed 60. However, as described in Section 1.2.1, the<br />
FSSMP may allow for spent activated carbon to be stored in other plant spaces. In the event the<br />
proposed TSF experiences a greater than normal influx of spent activated carbon, additional floor<br />
space can be made available, which would allow up to a total of 346 containers to be stored.<br />
55-gallon steel drums containing waste generated from activities at the proposed TSF will be<br />
stored in the general storage area. As designed, and during normal operations, the number of<br />
stored drums containing this type of waste is not expected to exceed 10. However, as described<br />
in Section 1.2.1, the FSSMP may allow for this type of waste to be stored in other plant spaces.<br />
In the event the proposed TSF experiences an unexpected increase in production, additional floor<br />
space can be made available, which would allow up to a total of 346 containers to be stored.<br />
Note: this material is not expected to contain liquids, and it is assumed that in order for 346<br />
containers to be stored, a minimal inventory of all other wastes would have to be kept.<br />
22.4.1 Containers with Free Liquids<br />
Two types of stored materials are expected to contain free liquids: elemental mercury and<br />
calomel. Details on the containers for these free liquids are provided in Section 22.1.<br />
Containers with liquids will be stored in storage areas where secondary containment, described<br />
in Section 22.5, will be provided.<br />
22.4.2 Aisle Spacing to Allow for Inspection – 40 CFR 264.174<br />
In order to facilitate proper inspection of containers pursuant to 40 CFR 264.174, containers<br />
containing hazardous waste will be easily visible from all directions. The aisle spacing for the<br />
proposed TSF has been designed to accommodate this consideration. Mounted inspection mirrors<br />
may be implemented to assist visibility.<br />
PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 110<br />
JBR Environmental Consultants, Inc. | HATCH March 2013
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