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 ...

23.07.2013 Views

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

(Purity ≥ 99.5%, Directly Stored) (Purity < 99.5%) Figure 1.0-1: Input and Output of Proposed TSF No liquid or non-liquid waste will be discharged from the proposed TSF to the environment. Residual wastes generated by the treatment processes at the proposed TSF will be shipped offsite to other appropriately permitted facilities for further treatment and/or disposal. A sample of the residue will tested using approved test methods (e.g., Toxicity Characteristic Leaching Procedure (TCLP)) to determine the presence of hazardous characteristics. The residues will then be transported by truck to the appropriate, licensed disposal facilities. This proposed TSF will be powered by a stand-alone electrical power generating system and will not be connected to any public or commercial power supply. Reagents, supplies, and fuels will be regularly delivered by truck to the proposed TSF and stored on-site in containers and tanks as proposed and described herein. Three dimensional visualizations of the proposed TSF (exterior and interior) are included in Appendix 1-A. 1.1 Building Design – 40 CFR 270.14(b)(1) & 264.31 The construction of the process and storage building of the proposed TSF will follow the provisions set forth in the International Building Code (IBC) (Sections 414 and 415) and the International Fire Code (Chapters 50, 54, and 60). All spaces in the proposed TSF Building wherein mercury and mercury-bearing materials are treated, stored, and managed will be maintained under negative pressure. In these spaces, the floors will be coated with epoxy enamel, and an automatic fire suppression sprinkler system will be provided, along with prescribed fire separation distances in accordance with the above mentioned codes. (See Appendix 1-A, drawings H340940-0000-50-042-0001 and H340940-0000-50-042-0002). The proposed TSF is 36 feet tall (from grade to the highest point on the storage area truss) and will have a footprint of approximately 33,600 square feet (180 feet long by 160 feet wide, with PMR RCRA Permit Application, Dry Hills Facility Page 5 JBR Environmental Consultants, Inc. | HATCH March 2013

(Purity ≥ 99.5%, Directly Stored)<br />

(Purity < 99.5%)<br />

Figure 1.0-1: Input and Output of Proposed TSF<br />

No liquid or non-liquid waste will be discharged from the proposed TSF to the environment.<br />

Residual wastes generated by the treatment processes at the proposed TSF will be shipped offsite<br />

to other appropriately permitted facilities for further treatment and/or disposal. A sample of<br />

the residue will tested using approved test methods (e.g., Toxicity Characteristic Leaching<br />

Procedure (TCLP)) to determine the presence of hazardous characteristics. The residues will then<br />

be transported by truck to the appropriate, licensed disposal facilities.<br />

This proposed TSF will be powered by a stand-alone electrical power generating system and will<br />

not be connected to any public or commercial power supply. Reagents, supplies, and fuels will<br />

be regularly delivered by truck to the proposed TSF and stored on-site in containers and tanks as<br />

proposed and described herein.<br />

Three dimensional visualizations of the proposed TSF (exterior and interior) are included in<br />

Appendix 1-A.<br />

1.1 Building Design – 40 CFR 270.14(b)(1) & 264.31<br />

The construction of the process and storage building of the proposed TSF will follow the<br />

provisions set forth in the International Building Code (IBC) (Sections 414 and 415) and the<br />

International Fire Code (Chapters 50, 54, and 60). All spaces in the proposed TSF Building<br />

wherein mercury and mercury-bearing materials are treated, stored, and managed will be<br />

maintained under negative pressure. In these spaces, the floors will be coated with epoxy enamel,<br />

and an automatic fire suppression sprinkler system will be provided, along with prescribed fire<br />

separation distances in accordance with the above mentioned codes. (See Appendix 1-A,<br />

drawings H340940-0000-50-042-0001 and H340940-0000-50-042-0002).<br />

The proposed TSF is 36 feet tall (from grade to the highest point on the storage area truss) and<br />

will have a footprint of approximately 33,600 square feet (180 feet long by 160 feet wide, with<br />

PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 5<br />

JBR Environmental Consultants, Inc. | HATCH March 2013

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