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

WASTE ANALYSIS PLAN
1 PURPOSE AND SCOPE
The purpose of this Waste Analysis Plan (WAP) is to establish necessary methodologies,
analytical techniques, and overall procedures that will be followed at the proposed Precious
Metals Recovery LLC (PMR) Dry Hills Facility, a dedicated Treatment and Storage Facility
(TSF) for mercury and mercury-bearing materials. This will ensure that adequate information is
available to manage Resource Conservation and Recovery Act (RCRA) hazardous waste safely,
and in accordance with the regulatory requirements. This plan also anticipates that the
proposed TSF will treat and store mercury-bearing wastes that it generates, or will send such
wastes to an off-site licensed treatment, storage, and disposal facility.
This WAP establishes the following:
Procedures for determining what waste streams will be acceptable for management at
the proposed TSF, and for notifying the waste generator of the waste that will be
accepted by the proposed TSF.
Procedures for characterizing wastes and establishing appropriate management
strategies.
Frequency and methods for sampling and analyzing waste.
Parameters for which each waste will be analyzed.
Rationale for the selection of these parameters.
Methods to ensure compliance with the land disposal restrictions.
This WAP is supported by SW-846 and ASTM Methods. The methods are incorporated by
reference (see Section 35.0). Select methods are included in Appendices 2-C and 2-D,
respectively. These methods will be followed for compliance with the RCRA permit. These
procedures may be updated as appropriate without prior NDEP approval.
2 IDENTIFICATION OF WASTES TO BE MANAGED
Wastes Generated Off-Site
The proposed TSF will accept wastes for storage and treatment in a three primary forms:
elemental mercury, calomel slurry, and spent activated carbon. The proposed TSF can
accept wastes with waste code D009.
Waste Analysis Plan App 2A-Page 1
JBR Environmental Consultants, Inc. March 2013