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 ...
1 CONTINGENCY PLAN The purpose of this Contingency Plan is to establish procedures to minimize hazards to human health and the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or constituents to air, soil, or surface water. This Contingency Plan has been prepared in compliance with the requirements of the Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities found in 40 CFR Part 264. This Plan is consistent with the Emergency Response Plan as required by the Nevada Chemical Accident Prevention Program (CAPP). This Contingency Plan is for a proposed Treatment and Storage Facility (TSF), to be owned by Precious Metals Recovery LLC (PMR), which will treat, store, and manage mercury and mercury-bearing materials as describe in Section 1 of the Part B RCRA Permit Application. PMR will maintain this Contingency Plan on-site at all times and carry out this plan in the event of an actual emergency. There will be a primary emergency coordinator available at all times who will be responsible for implementing and coordinating all emergency response measures and making response decisions. This qualified person will either be the proposed TSF’s Manager or a designated operator. The emergency coordinator will either be present at the facility or on call and able to respond within a short amount of time. The emergency coordinator will be thoroughly familiar with the contents of this Contingency Plan and will have absolute authority to commit all available company resources as necessary to respond to an emergency situation. The emergency coordinator will be the designated point-of-contact for local, county, and state authorities. The list of personnel authorized to be an emergency coordinator is found in Appendix 6-B. In accordance with 40 CFR 264.54, the Contingency Plan will be reviewed and amended when the applicable regulations or facility permits are revised: to improve responses to an emergency; if there are changes to the facility; if the list of emergency coordinators changes; or the list of emergency equipment changes. 2 POTENTIAL HAZARDS Potential emergency situations have been identified in Table 1. Mitigating steps that have been identified are listed along with each potential emergency. Although mercury is not a flammable material and will be treated and stored in a facility that will be constructed of non-flammable concrete blocks, the volatility of mercury during a fire is of concern. For this reason, the proposed TSF is designed to minimize a fire hazard by limiting fuel sources and isolating ignition sources. The potential for fire will be mitigated through the engineered design of the facility to the highest level practical. Contingency Plan App 6A-Page 1 JBR Environmental Consultants, Inc. March 2013
Potential Emergency Condition Fire, general building hazards Mercury spill or release from container Calomel spill or release from container Release of material to air Alternate Procedures Table 1: Contingency Provisions Hazards Contingency Provision Volatilize mercury Contact or volatilize mercury Contact mercury; contact sulfur Concrete block building, separated storage areas, fire suppression system. On-site emergency response team. Area around building bermed to contain fire and potential emissions. Spill response team trained to evacuate as needed and to contain and collect released material for proper management. Spill response materials and personnel protective equipment (PPE) located in high risk areas. Minimal traffic and deliveries scheduled for day shift only. Spill response team trained to evacuate as needed and to contain and collect released material for proper management. Spill response materials and PPE located in high risk areas. Minimal traffic and deliveries scheduled for day shift only. Operations occur inside concrete building. Building under negative pressure relative Ventilation system filters all air from inside the proposed TSF prior to exhausting to atmosphere. Cleanup procedures minimize volatilization. All operations personnel trained as hazardous waste operator (HAZWOPER) responders and mercury handlers. In the event the emergency coordinator is not available or is en-route to the proposed TSF, the following procedures along with this Contingency Plan will be implemented. Personnel arriving first at the scene of the incident will communicate with the security office at the Cortez mine (775-468-4000) and will help restrict access to the area until the emergency coordinator arrives at the scene of the incident. The emergency coordinator will terminate the incident and initiate recovery operations, which include those short term and long-term activities that return all systems to normal conditions. Facility operators will be qualified to act in this capacity due to their training and familiarity with the following: Types of hazardous materials and hazardous wastes on-site. Locations and characteristics of all hazardous materials and hazardous wastes handled on-site. Contingency Plan App 6A-Page 2 JBR Environmental Consultants, Inc. March 2013
- Page 367 and 368: Designation: D4978 − 95 (Reapprov
- Page 369 and 370: FIG. 1 Method B, Sulfide Test Appar
- Page 371 and 372: TABLE 1 Determination of Bias, Pycn
- Page 373 and 374: for four known specific gravity lev
- Page 375 and 376: 21.7.1 To check the precision of sa
- Page 377 and 378: Designation: D4981 − 08 Standard
- Page 379 and 380: Designation: D5058 − 12 Standard
- Page 381 and 382: 11.6.1 Compare the temperature here
- Page 383 and 384: APPENDIX 2-E Characterization Data
- Page 385 and 386: 5. Fire-fighting measures General I
- Page 387 and 388: Carcinogenicity: CAS# 10112‐91‐
- Page 393 and 394: Combined Hazen Solution Analysis pH
- Page 395 and 396: irritation and possible burns. May
- Page 397 and 398: OSHA Vacated PELs: Mercury: 0.05 mg
- Page 399 and 400: Chemical waste generators must dete
- Page 401 and 402: APPENDIX 4-A Inspection Plan
- Page 403 and 404: 1 INSPECTION PLAN This Inspection P
- Page 405 and 406: Inspections are intended to detect
- Page 407 and 408: Boilers and Industrial Furnaces Ins
- Page 409 and 410: PMR Daily Inspection Form #1 Date:
- Page 411 and 412: PMR Daily Inspection Form #2 Date:
- Page 413 and 414: PMR Weekly Inspection Form #3 Date:
- Page 415 and 416: damage or vandalism. Other Inspecti
- Page 417: TABLE OF CONTENTS 1 CONTINGENCY PLA
- Page 421 and 422: Other duties of the emergency coord
- Page 423 and 424: Determine proper storage and placem
- Page 425 and 426: Neoprene boots - protect feet. Res
- Page 427 and 428: Fire Extinguishers. Absorbent pads
- Page 429 and 430: Table 2: Coordinating Agency Contac
- Page 431 and 432: Stay low in smoke filled areas. Co
- Page 433 and 434: the area or the National Response C
- Page 435 and 436: Description of the spilled material
- Page 437 and 438: APPENDIX 6-B Emergency Coordinators
- Page 439: Ambulance EXTERNAL CONTACTS Name Ti
1 CONTINGENCY PLAN<br />
The purpose of this Contingency Plan is to establish procedures to minimize hazards to human<br />
health and the environment from fires, explosions, or any unplanned sudden or non-sudden<br />
release of hazardous waste or constituents to air, soil, or surface water. This Contingency Plan<br />
has been prepared in compliance with the requirements of the Standards for Owners and<br />
Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities found in 40 CFR Part<br />
264. This Plan is consistent with the Emergency Response Plan as required by the Nevada<br />
Chemical Accident Prevention Program (CAPP).<br />
This Contingency Plan is for a proposed Treatment and Storage Facility (TSF), to be owned by<br />
<strong>Precious</strong> <strong>Metals</strong> <strong>Recovery</strong> <strong>LLC</strong> (PMR), which will treat, store, and manage mercury and<br />
mercury-bearing materials as describe in Section 1 of the Part B <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>.<br />
PMR will maintain this Contingency Plan on-site at all times and carry out this plan in the event<br />
of an actual emergency. There will be a primary emergency coordinator available at all times<br />
who will be responsible for implementing and coordinating all emergency response measures<br />
and making response decisions. This qualified person will either be the proposed TSF’s Manager<br />
or a designated operator. The emergency coordinator will either be present at the facility or on<br />
call and able to respond within a short amount of time. The emergency coordinator will be<br />
thoroughly familiar with the contents of this Contingency Plan and will have absolute authority<br />
to commit all available company resources as necessary to respond to an emergency situation.<br />
The emergency coordinator will be the designated point-of-contact for local, county, and state<br />
authorities. The list of personnel authorized to be an emergency coordinator is found in<br />
Appendix 6-B.<br />
In accordance with 40 CFR 264.54, the Contingency Plan will be reviewed and amended when<br />
the applicable regulations or facility permits are revised: to improve responses to an emergency;<br />
if there are changes to the facility; if the list of emergency coordinators changes; or the list of<br />
emergency equipment changes.<br />
2 POTENTIAL HAZARDS<br />
Potential emergency situations have been identified in Table 1. Mitigating steps that have been<br />
identified are listed along with each potential emergency.<br />
Although mercury is not a flammable material and will be treated and stored in a facility that will<br />
be constructed of non-flammable concrete blocks, the volatility of mercury during a fire is of<br />
concern. For this reason, the proposed TSF is designed to minimize a fire hazard by limiting fuel<br />
sources and isolating ignition sources. The potential for fire will be mitigated through the<br />
engineered design of the facility to the highest level practical.<br />
Contingency Plan App 6A-Page 1<br />
JBR Environmental Consultants, Inc. March 2013