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

22.7 Description of Drainage in Storage Areas – 40 CFR 270.15 & 264.175 See Drainage Arrangement H340940-0000-50-015-0008 in Appendix 1-A for details on drainage in storage areas. 22.8 Management of Accumulated Liquids – 40 CFR 270.15 & 264.175 22.8.1 Identification Inspections of the storage area will be conducted to identify the presence of liquids in the secondary containment in accordance with the Inspection Plan (see Appendix 4-A). 22.8.2 Collection and Removal – 40 CFR 270.15(a)(5) & 264.175(b)(5) In the unlikely event liquid hazardous waste inadvertently escapes its primary container, it will be collected in the curbed drainage and sump network (see Appendix 1-A). A typical sump design is presented in Appendix 1-A. A portable sump pump may then be used to remove standing liquid from the sump, and appropriate spill response measures can be taken. Depending on the type of liquid (i.e., calomel or elemental mercury), it may be added to the Decomposition Tank, retorted, or placed in a pig. 22.8.3 Analysis Liquids recovered from a collection sump will be presumed as hazardous waste, and will be managed in accordance with the proposed TSF procedures for wastes of that type. Wastes sent off-site for treatment and/or disposal will be characterized. 22.9 Management of Run-on – 40 CFR 270.15(a)(4) & 264.175(b)(4) The storage areas will be enclosed within the proposed TSF Building. The building roof and walls are designed to prevent precipitation run-on to the storage area. 22.10 Storage without Free Liquids – 40 CFR 264.175(c) 22.10.1 Spent Activated Carbon Storage Area Spent activated carbon will be stored in a shared area with calomel. A description of the area and the management practices is presented in Section 22.4. Secondary containment is included in the shared storage area, although not required for the spent activated carbon itself. 22.10.2 Demonstrate No Free Liquids – 40 CFR 270(15)(b)(1) & 264.175(c), & 264.314 Spent activated carbon is not expected to contain free liquids. Annually, the spent activated carbon will be tested for liquids using the Paint Filter Test (SW846 Method 9095B). The processes used by the waste generators that produce spent activated carbon, as well as the processes that will produce spent activated carbon at the proposed TSF, are expected to operate within known variations. Management practices will be implemented to allow advanced notice of changes to these processes. In the event a significant change occurs, a full characterization PMR RCRA Permit Application, Dry Hills Facility Page 112 JBR Environmental Consultants, Inc. | HATCH March 2013

will be done on the new waste stream. In the absence of significant change, an annual characterization of the spent activated carbon waste stream is expected to be sufficient. 22.11 Special Requirements for Ignitable, Incompatible, or Reactive Wastes – 40 CFR 270.15, 261.23, 264.176, & 264.177 22.11.1 Ignitable or Reactive Wastes – 40 CFR 261.21 & 261.23 No ignitable or reactive wastes will be accepted at the proposed TSF. No special accommodations have been incorporated into the proposed TSF design to allow acceptance of ignitable or reactive wastes. Explosives will not be accepted at the proposed TSF. Use of water throughout the proposed TSF will be minimized. The proposed TSF will not be connected to a municipal water treatment plant, and therefore, minimizes the introduction of water. Water will be transported to and from the proposed TSF. It will be a priority of the process design and operation to limit water usage. 22.11.2 Incompatible Wastes – 40 CFR 264.17(b), 264.177, & 270.15(b) The mercury and mercury-bearing materials that will be accepted by the proposed TSF are not incompatible wastes. Incoming Materials Waste generators (who send mercury and mercury-bearing materials to the proposed TSF) will be responsible for placing waste streams in appropriate containers. The proposed TSF will inspect and receive these wastes as described in Section 1.2.1. No material that is incompatible with the primary materials to be processed at the proposed TSF will be accepted. Wastes Generated at the Proposed TSF Similar wastes generated at the proposed TSF may be placed in the same container, provided that the container itself is not made from an incompatible material; incompatible wastes will not be mixed or placed in the same container. The compatibility chart (see Appendix 2-B) will be used to determine compatibility. The WAP (Appendix 2-A) presents the procedure for cleaning and reusing containers at the proposed TSF. 22.12 Air Emission Standards – 40 CFR 270.15(e), 264.179, & 264.1086 Independent of this application, the proposed TSF will pursue the applicable air permits through NDEP, Bureau of Air Quality. The proposed TSF will comply with the air emission standards established in the issued air permit. Additionally, the proposed TSF will conform to the air emission standards of Subpart CC of 40 CFR Part 264, as applicable. PMR RCRA Permit Application, Dry Hills Facility Page 113 JBR Environmental Consultants, Inc. | HATCH March 2013

will be done on the new waste stream. In the absence of significant change, an annual<br />

characterization of the spent activated carbon waste stream is expected to be sufficient.<br />

22.11 Special Requirements for Ignitable, Incompatible, or Reactive Wastes –<br />

40 CFR 270.15, 261.23, 264.176, & 264.177<br />

22.11.1 Ignitable or Reactive Wastes – 40 CFR 261.21 & 261.23<br />

No ignitable or reactive wastes will be accepted at the proposed TSF. No special<br />

accommodations have been incorporated into the proposed TSF design to allow acceptance of<br />

ignitable or reactive wastes.<br />

Explosives will not be accepted at the proposed TSF. Use of water throughout the proposed TSF<br />

will be minimized. The proposed TSF will not be connected to a municipal water treatment<br />

plant, and therefore, minimizes the introduction of water. Water will be transported to and from<br />

the proposed TSF. It will be a priority of the process design and operation to limit water usage.<br />

22.11.2 Incompatible Wastes – 40 CFR 264.17(b), 264.177, & 270.15(b)<br />

The mercury and mercury-bearing materials that will be accepted by the proposed TSF are not<br />

incompatible wastes.<br />

Incoming Materials<br />

Waste generators (who send mercury and mercury-bearing materials to the proposed TSF) will<br />

be responsible for placing waste streams in appropriate containers. The proposed TSF will<br />

inspect and receive these wastes as described in Section 1.2.1.<br />

No material that is incompatible with the primary materials to be processed at the proposed TSF<br />

will be accepted.<br />

Wastes Generated at the Proposed TSF<br />

Similar wastes generated at the proposed TSF may be placed in the same container, provided that<br />

the container itself is not made from an incompatible material; incompatible wastes will not be<br />

mixed or placed in the same container. The compatibility chart (see Appendix 2-B) will be used<br />

to determine compatibility.<br />

The WAP (Appendix 2-A) presents the procedure for cleaning and reusing containers at the<br />

proposed TSF.<br />

22.12 Air Emission Standards – 40 CFR 270.15(e), 264.179, & 264.1086<br />

Independent of this application, the proposed TSF will pursue the applicable air permits through<br />

NDEP, Bureau of Air Quality. The proposed TSF will comply with the air emission standards<br />

established in the issued air permit. Additionally, the proposed TSF will conform to the air<br />

emission standards of Subpart CC of 40 CFR Part 264, as applicable.<br />

PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 113<br />

JBR Environmental Consultants, Inc. | HATCH March 2013

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