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

The principal treatment activity at the proposed TSF is the processing of mercury-bearing
materials for the recovery of elemental mercury. Recovered elemental mercury will be either
transferred for sale or to a National Repository for long-term storage and management.
Elemental mercury will also be accepted for interim storage at the proposed TSF pending the
availability of a National Repository.
Wastes Generated On-Site
Elemental mercury will be reclaimed from accepted wastes as a result of successful treatment.
Treatment residues resulting from the processes will include, but not be limited to, spent
activated carbon from carbon filters, sludge, residues, and hygiene dust collector dust.
Small amounts of waste will be generated as a result of the proposed TSF’s operations.
Housekeeping waste will be comprised of wipes, rags, towels, paper goods, booties, gloves,
disposable coveralls, disposable sampling devices, etc. These housekeeping materials may
contain mercury or other chemicals used in the processes. Continuous ambient air monitoring
devices and discrete sampling instruments will also generate spent sample cartridges or other
small amounts of waste.
The activities necessary to characterize and validate that received materials are within acceptable
limits will generate some mercury-containing waste materials (gloves, respirator cartridges,
sampling devices, wipes, paper towels, discarded sample containers, etc.). The fingerprinting
analyses conducted on-site will generate another lab waste stream.
The hygiene air ventilation system will generate spent carbon filters that may contain mercury.
No vehicle maintenance or fueling will occur at the proposed TSF.
3 WASTE CHARACTERIZATION - 40 CFR 264.13(b)
A hazardous waste determination will be made for all waste streams generated, stored, or treated
at the proposed TSF. The test methods to measure the parameters discussed throughout this
document are identified in Table 1. Whenever possible, the proposed TSF will use
established methods from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods (SW-846), US EPA, 1986 and its updates. If a method has not been established by
the EPA, an American Society for Testing and Materials (ASTM) method will be used.
When a contracted laboratory performs analyses using a method found in SW-846, and the
method is one that is certifiable by the State of Nevada, the laboratory performing the
analyses shall be certified for that method.
Waste Analysis Plan App 2A-Page 2
JBR Environmental Consultants, Inc. March 2013