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

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an additional 120 feet long and 40 feet wide for the receiving and inspection area). It will be divided into six areas, each with a separate ventilation system (Appendix 1-A drawing H340940- 0000-45-083-0001). These six areas are as follows: Office Area. Process Area (including the Lab). Clean Storage and Maintenance Area. Elemental Mercury Storage Area. Motor Control Center (MCC) Room. Receiving and Inspection Area (Truck Unloading Area). Note: All areas except for the Office Area are collectively referred to as the “plant spaces.” The Office Area will be a clean area and separated from the rest of the building by concrete walls. This area includes offices, a conference room, a lunch room, change rooms, and the control room. It will be situated in the northeast corner of the building. All areas of the proposed TSF where mercury and mercury-bearing materials will be treated, stored, and managed will be separated from the other areas of the building by concrete walls. The proposed TSF will house the MCC Room, which will be in close proximity to the incoming power supply lines. Electrical power is supplied to the proposed TSF by diesel generators which are located in the Utility Area (outside the proposed TSF Building). Elemental mercury will be stored in the west end of the building. Elemental mercury will be contained in pigs, and will be stored on racks equipped with spill trays (see Appendix 1-A H340940-0000-50-015-0009). All mercury and mercury-bearing materials will be stored in containers inside the building. The envelope of the proposed TSF Building proper has the following design features: Ceilings / roof coated with epoxy enamel. Exterior concrete wall panels coated with epoxy enamel. Interior concrete walls coated with epoxy enamel between office and process / storage areas. Interior concrete walls coated with epoxy enamel between process and storage areas. Interior metal walls coated with epoxy enamel within the storage area. Concrete floors within the process / storage areas coated with epoxy enamel. The epoxy enamel coating will prevent mercury vapor from being absorbed into the building materials. This is consistent with the best practice guidelines in the Mine Safety and Health PMR RCRA Permit Application, Dry Hills Facility Page 6 JBR Environmental Consultants, Inc. | HATCH March 2013
Administration (MSHA) document, Controlling Mercury Hazards in Gold Mining: A Best Practices Toolbox. An impermeable geo-membrane will be installed underneath the proposed TSF Building slab on grade as an additional level of containment. A slab seal will be maintained at all floor and wall interfaces. Hard neoprene washers will be installed where racks are bolted to the slab with conventional anchor bolts. A watertight seal may be maintained with a durable touch-up epoxy coating. The building will be designed to prevent cracks in the concrete due to thermal expansion. Cracks that do form will be re-sealed with a concrete sealer. Waterproof expansion joints in the slab will be sealed with epoxy coating after being reset with fresh mastic. Sealing of roll-up doors will be given special attention. Gaps will be eliminated to the fullest extent possible. The rubberized lower-lip on each roll-up door will be inspected regularly to ensure seal integrity. 1.1.1 Materials of Construction Foundation and Floor Slab The foundation and floor slab will be concrete reinforced with rebar on top of an impermeable membrane. The membrane barrier protecting the soil below the foundation and floor slab will be a spray-applied membrane. Liquid Boot, or a functional equivalent, is a two-component spray designed to quickly and permanently seal the soil below the building prior to construction of the floor slab. Building Structure The building will be constructed using steel columns with steel trusses supporting walls and ceilings. The interior exposed surface of structural members, concrete walls and floors will be coated with epoxy enamel. Roofing Roofing, awnings, and canopies will be pre-painted metal cladding placed over the steel trusses. The minimum thickness of the metal sheets will be 24 gauge. Roof insulation will be semi-rigid fiberglass with a thermally reflective vapor barrier. Exterior Walls and Main Partitions The exterior walls will be made from insulated, fire rated, and pre-fabricated concrete panels. All exterior walls and partitions will be fire-rated and will meet Underwriters Laboratories (UL) design requirements. The joints between panels, joints between panels and the roof, and joints between panels and the floor will be sealed with grout or flexible fill and finished with an epoxy coating. The exterior face of the panels will be covered with exterior pre-painted metal siding. The interior face of the panels will be coated with epoxy enamel. PMR RCRA Permit Application, Dry Hills Facility Page 7 JBR Environmental Consultants, Inc. | HATCH March 2013
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Precious Metals Recovery LLC RCRA P
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ITEM # REGULATIONS GENERAL DESCRIPT
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ITEM # REGULATIONS GENERAL DESCRIPT
Page 7 and 8: PMR Nevada RCRA Permit Application
Page 9 and 10: PMR Nevada RCRA Permit Application
Page 11 and 12: ITEM # REGULATIONS GENERAL DESCRIPT
Page 19 and 20: M-3 M-3 ITEM # REGULATIONS GENERAL
Page 21 and 22: OMB# 2050-0024; Expires ___________
Page 23 and 24: EPA ID Number OMB#: 2050-0024; Expi
Page 25 and 26: EPA ID Number ADDENDUM TO THE SITE
Page 33 and 34: This document is for reference purp
Page 35 and 36: A B C D E F $$W ATERMARKD$$ N 4,475
Page 37 and 38: Precious Metals Recovery LLC Dry Hi
Page 39 and 40: 3.2 Barrier and Means to Control En
Page 41 and 42: 19.0 APPROVAL OF PETITION FOR EXTEN
Page 43 and 44: LIST OF TABLES Table 1.2-1 Secondar
Page 45 and 46: Figure 23.1-1 Decomposition & Waste
Page 47 and 48: Section 10 Appendices 10-A Figures
Page 49 and 50: HVAC Heating, Ventilation, and Air
Page 51 and 52: GLOSSARY OF SELECTED TERMS [Authori
Page 53 and 54: INTRODUCTION Precious Metals Recove
Page 55 and 56: Pre-application Public Meeting - 40
Page 57: (Purity ≥ 99.5%, Directly Stored)
Page 61 and 62: Fire Doors/Emergency Exit Doors Pr
Page 63 and 64: When leaving the plant spaces, work
Page 65 and 66: Infiltration Air Office Area Pig Pi
Page 67 and 68: personnel will be trained in respon
Page 69 and 70: Figure 1.2-1: Elemental Mercury Tra
Page 71 and 72: Tanks Or Containers Carbon Drums (n
Page 73 and 74: Figure 1.2-2: Calomel Feed Preparat
Page 75 and 76: Figure 1.2-3: Filter Press and Loca
Page 77 and 78: Activated carbon is used in the air
Page 79 and 80: Figure 1.2-5: SO2 Scrubber and Loca
Page 81 and 82: Above the retort tray/drum transfer
Page 83 and 84: Figure 1.2-8: Carbon Filter and Loc
Page 85 and 86: Figure 1.2-10: Overall Ventilation
Page 87 and 88: Wash water from open sumps. Safety
Page 89 and 90: 1.3 Elemental Mercury Storage - 40
Page 91 and 92: The following items are located out
Page 93 and 94: Control System Architecture The pla
Page 95 and 96: will be supplied in accordance with
Page 97 and 98: Outdoor Material Storage A list of
Page 99 and 100: It is recognized that the fire prot
Page 101 and 102: Outdoor Areas Hydrants and hose bo
Page 103 and 104: the event of a security violation,
Page 105 and 106: 2.3 Determination of Treatment Para
Page 107 and 108: Table 2.5-2: Test Methods Parameter
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Sampling Containerized Waste The te
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Process Waste Solution A discrete p
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ii. The sampling person removes a s
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2.9 Screening for Ignitable, Reacti
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3.0 SECURITY PLAN - 40 CFR 270.14(b
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4.0 INSPECTION PLAN - 40 CFR 270.14
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TSF, associated hazards, places whe
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Outside of working hours, a notific
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Damaged containers will be placed i
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7.0 PREVENTION AND SAFETY PROCEDURE
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8.0 PREVENTION OF ACCIDENTAL IGNITI
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10.0 TRAFFIC - 40 CFR 270.14(b)(10)
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Delivery frequency of reagents will
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10.3 Traffic Control Signs Traffic
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11.4 Surrounding Land Use - 40 CFR
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12.0 PERSONNEL TRAINING PLAN - 40 C
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that are not land based. Closure of
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13.4.6 Types of Off-site Waste Mana
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14.0 CLOSED HAZARDOUS WASTE DISPOSA
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storage area (e.g., storage racks),
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16.0 POST-CLOSURE ESTIMATES - 40 CF
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18.0 TOPOGRAPHICAL MAP - 40 CFR 270
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20.0 GROUNDWATER MONITORING - 40 CF
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22.0 CONTAINERS AND CONTAINMENT - 4
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Figure 22.1-2: Dedicated Transfer C
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Larger sized HDPE drums may be used
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22.3.2 Labeling Containers - 40 CFR
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22.5 Description of Secondary Conta
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will be done on the new waste strea
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23.0 TREATMENT AND STORAGE TANKS Me
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Figure 23.0-2: HCl Tank and Locatio
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Tank Dimensions Waste Solution Stor
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decomposed in the Decomposition Tan
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Figure 23.1-3: Waste Solution Stora
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The Water Storage Tank will supply
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Tank Caustic Soda Storage Tank* Hyd
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23.13 Recordkeeping A recordkeeping
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25.0 WASTE PILES - 40 CFR 270.18 &
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27.0 LAND TREATMENT - 40 CFR 270.20
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29.0 BOILERS/INDUSTRIAL FURNACE - 4
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30.1.3 Retort Operating Procedures
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of 13.5 feet long by 4.7 feet wide
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31.0 PROCESS VENTS - 40 CFR 270.24
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33.0 DRIP PADS - 40 CFR 270.26 & 26
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35.0 REFERENCES American Society of
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At the PMR Dry Hills Facility Open
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APPENDIX I-B Open House Comments
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APPENDIX 1-A Drawings Facility draw
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A B C D EF $ $ W A TERMARKA1$$ H340
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A B C D E F $$W ATERMARKD$$ 1 2 3 4
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A B C D E F $$W ATERMARKD$$ N 4,475
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A B C D EF $ $ W A TERMARKA1$$ H340
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A B C D E F $$W ATERMARKD$$ H340940
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A B C D E F $$W ATERMARKD$$ NOTE: 1
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B A B C D E F $$W ATERMARKD$$ H3409
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APPENDIX 1-C Process Flow Diagrams
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H - 340940 Precious Metals Recovery
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APPENDIX 1-D Floor and Wall Sealant
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C8 x 11.5 EPOXY COATING ON 2" THICK
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8" THICK INSULATED PRECAST CONCRETE
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C8 x 11.5 EPOXY COATING ON 2" THICK
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2. PRODUCTS 2.1 Stonclad GS Stoncla
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APPENDIX 2-A Waste Analysis Plan
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WASTE ANALYSIS PLAN 1 PURPOSE AND S
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Table 1: Analytical Methods for the
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All wastes received will have been
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Waste will not be accepted until th
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Table 3: Waste Sampling Matrix Type
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9 LDR TREATMENT STANDARDS Waste Des
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Drummed consolidation waste will be
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eevaluated whenever the process tha
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ATTACHMENT 2-A-1 Profile Instructio
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PMR LLC 460 W. 50 North Suite 500 S
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• Is the waste pyrophoric? a See
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EPA's Chemical Compatibility Chart
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1.0 SCOPE AND APPLICATION METHOD 90
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7.2.3 Adjust the electrodes in the
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METHOD 9045D SOIL AND WASTE pH 9045
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NOTE: Combination electrodes incorp
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10.0 REFERENCES 1. National Bureau
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1.0 SCOPE AND APPLICATION METHOD 13
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4.2.2 Bottle Extraction Vessel. Whe
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4.10 Watchglass, appropriate diamet
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7.0 PROCEDURE 7.1 Preliminary Evalu
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determine whether the solid materia
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solids content of the waste sample
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material into an extractor bottle.
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sample from which no additional liq
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slowly out of the ZHE device into a
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® TEDLAR bag is used, if the extra
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150% of the expected concentration
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None of the parameters had a signif
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Table 2. Suitable Rotary Agitation
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Table 4. Suitable Filter Holders 1
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Table 6. Multi-Laboratory TCLP Meta
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Table 8. Multi-Laboratory Semi-Vola
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Figure 1. Rotary Agitation Apparatu
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METHOD 1311 (CONTINUED) TOXICITY CH
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Designation: D4979 − 08 Standard
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Designation: D4978 − 95 (Reapprov
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FIG. 1 Method B, Sulfide Test Appar
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TABLE 1 Determination of Bias, Pycn
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for four known specific gravity lev
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21.7.1 To check the precision of sa
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11.6.1 Compare the temperature here
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APPENDIX 2-E Characterization Data
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5. Fire-fighting measures General I
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Carcinogenicity: CAS# 10112‐91‐
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Combined Hazen Solution Analysis pH
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irritation and possible burns. May
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OSHA Vacated PELs: Mercury: 0.05 mg
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Chemical waste generators must dete
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APPENDIX 4-A Inspection Plan
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1 INSPECTION PLAN This Inspection P
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Inspections are intended to detect
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Boilers and Industrial Furnaces Ins
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PMR Daily Inspection Form #1 Date:
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PMR Daily Inspection Form #2 Date:
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PMR Weekly Inspection Form #3 Date:
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damage or vandalism. Other Inspecti
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TABLE OF CONTENTS 1 CONTINGENCY PLA
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Potential Emergency Condition Fire,
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Other duties of the emergency coord
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Determine proper storage and placem
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Neoprene boots - protect feet. Res
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Fire Extinguishers. Absorbent pads
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Table 2: Coordinating Agency Contac
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Stay low in smoke filled areas. Co
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the area or the National Response C
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Description of the spilled material
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APPENDIX 6-B Emergency Coordinators
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Ambulance EXTERNAL CONTACTS Name Ti
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