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

1.0 FACILITY DESCRIPTION – 40 CFR 270.14 (b)(1)
This application seeks to permit PMR’s subject Dry Hills Facility as a hazardous waste TSF
governed by a Subtitle C Permit under RCRA 40 CFR 264. Application for an EPA ID number
for this proposed TSF in accordance with 40 CFR 264.11 is included with this application. The
Part A form precedes this Part B application document, but is provided in the same submittal.
This proposed TSF will be located within the proposed TSF compound. The proposed TSF
compound will be physically bounded by a perimeter fence and berm, inside of which includes:
The proposed TSF (i.e., the RCRA area)
The proposed TSF Building (inside the RCRA area)
Utility Building
Utility Area
The proposed TSF will receive mercury and mercury-bearing materials, primarily in the form of:
calomel slurry (mercurous chloride), spent activated carbon containing mercury, and elemental
mercury from BGNA and its joint venture operations in the United States. Calomel will typically
be shipped to the facility in 55-gallon high density polyethylene (poly) drums; spent activated
carbon will be shipped to the facility in 55-gallon steel drums; and elemental mercury will be
shipped to the facility in carbon steel containers called (“pigs”), which are designed to hold one
metric tonne of elemental mercury, or 76-pound flasks shipped in 55-gallon steel drums.
Elemental mercury will be stored in pigs. The containers in which mercury and mercury-bearing
materials are transported, treated, stored, and managed are discussed in Section 22.
After MEBA goes into effect on January 1, 2013, export of elemental mercury will be prohibited.
Under MEBA, the Federal Government requires the Secretary of Energy to designate a facility
for the long-term management and storage of elemental mercury generated within the United
States. When operational, this National Mercury Repository (National Repository) will only
accept mercury in its elemental form with purity of 99.5% or greater by weight.
The primary objective of the proposed TSF will be to recover mercury in its elemental form and
store it until a National Repository becomes available. Mercury-bearing materials sent to the
proposed TSF will undergo the necessary treatment processes to recover elemental mercury to
meet the Federal purity requirement (Figure 1.0-1, below).
PMR RCRA Permit Application, Dry Hills Facility Page 4
JBR Environmental Consultants, Inc. | HATCH March 2013