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

In the event a waste generator’s waste generating process changes, the proposed TSF will be
given advanced notice of the intended change. The waste will be analyzed after the change
occurs and prior to the first shipment being delivered to the proposed TSF.
The proposed TSF will use the following resources to characterize the waste streams treated and
managed at the facility:
MSDS.
Waste generator process knowledge.
Laboratory analytical results.
DOT Emergency Response Guide.
DOT hazard classification and supporting test data.
Table 4 below is based on the cube root basis found in ASTM Method D140-70. Due to the
small load size, this selection of samples is reasonable.
Table 4: Frequency of Analysis
Average Monthly Drum Number Aliquots Selected
1 1
2 to 8 2
9 to 27 3
28 to 64 4
Frequency of Analysis for Elemental Mercury, Calomel, and Spent Activated
Carbon
The chemical composition of the recovered elemental mercury is well known and consistent.
While these waste streams are not routinely analyzed prior to being treated, the proposed TSF
will review all waste streams on an annual basis or any time the waste generating process
changes.
Frequency of Analysis for Routine Wastes
The processes at the proposed TSF will generate routine waste streams (e.g., residues from
retorted filter cake). These waste streams will be evaluated initially at the beginning of
operations, and annually updated to verify accuracy. The waste characterization will also be
Waste Analysis Plan App 2A-Page 14
JBR Environmental Consultants, Inc. March 2013