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

Inspections are intended to detect potential problems in time to correct them before they result in
a release of hazardous waste constituents and/or cause harm to human health or the environment.
Units critical to the proper operation of the facility, specific inspection items, and potential
problems associated with each inspection area are referenced in the following subsections as well
as on each individual inspection form.
5 UNIT SPECIFIC INSPECTION REQUIREMENTS
Container Inspections - 40 CFR 264.174
Areas where containers are stored are inspected daily for leaking containers and for deterioration
of containers and the containment system caused by corrosion or other factors. If any of these
conditions exist, corrective activities are instituted to clean up and limit the spread of material,
and/or restore the integrity of the container or containment system. The containers and
containment system is also visually inspected for the presence of cracks and gaps that could
result in loss of containment effectiveness where appropriate. Should structural problems occur
that would allow leakage out of the unit or between compatibility segregation areas or that may
develop into a major failure, repair activity will be initiated. These findings will be documented
on the inspection form and reported to the TSF manager.
During scheduled inspections of the containment area a determination is made whether adequate
aisle space is being maintained. Individual containers are also randomly inspected to ensure
proper segregation is being maintained.
Secondary containment trays are inspected for the presence of liquids and evidence of leaks.
Spilled material is removed and the residues are managed in accordance with the Waste Analysis
Plan. Liquids discovered in the containment system are removed within 48 hours of discovery. If
necessary, amalgam or absorbent materials are utilized to absorb standing liquid for proper
disposal.
Tank System - 40 CFR 264.195
The structural condition of the tanks and their associated piping are visually inspected daily.
Tank areas and skids are inspected for indications of a leak. Inspection findings are recorded on
the inspection form along with the observed tank level. The functionalities of tank system
instruments are observed.
Surface Impoundment Inspection - 40 CFR 264.226
Not Applicable. The facility does not have any hazardous waste surface impoundments.
Inspection Plan App 4A-Page 3
JBR Environmental Consultants, Inc. March 2013