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

typically be provided in this area during the winter months. This area will be maintained under negative pressure, in common with the rest of the plant spaces. Process Area The HVAC system for the process area (including the laboratory area) consists of a roofmounted, air conditioning unit, air distribution ductwork, and HVAC system controls. The HVAC system will be designed to typically maintain a target indoor air temperature of 70°F or below. The process area will be maintained under negative pressure relative to the surrounding areas. Inspection Area The HVAC system for the inspection area consists of a roof-mounted, air conditioning unit, air distribution ductwork, and HVAC system controls. The HVAC system will be designed to typically maintain a target indoor air temperature of 70°F or below. The inspection area will be maintained under negative pressure, in common with the rest of the plant spaces. Truck Unloading Area The HVAC system for the truck unloading area consists of exhaust fans, air intake louvers with motorized dampers, a carbon monoxide (CO) gas detection system, and a nitrogen oxides (NOx) gas detection system, compliant with applicable workplace standards. Within the truck unloading area, it is not expected that mercury vapor will be present. The inspection procedures taking place at the truck unloading area will involve: Mercury vapor detection using a portable device. Checking the container labels. Checking the delivery manifest(s). This area is not designed for open containers containing mercury and mercury-bearing materials. Accordingly, temperature control will not be provided in the truck unloading area, but this area will be maintained under negative pressure when the bay doors are closed. 1.2 Facility Operation and Process Descriptions – 40 CFR 270.14(b)(1) & 264.31 The proposed TSF Building is specifically designed to follow the best practices for mercury managing facilities and to safely manage mercury. All loading and unloading will occur within this engineered structure. The building will be constructed of non-combustible materials to reduce fire susceptibility. Flammable materials will not be stored in the storage area. All applicable engineering and building design standards have been applied to this building. Mercury spill kits and mercury absorbent will be available in sufficient quantities to prevent any spilled mercury from being released to the environment or threatening human health. All facility PMR RCRA Permit Application, Dry Hills Facility Page 14 JBR Environmental Consultants, Inc. | HATCH March 2013

personnel will be trained in response procedures per the training plan presented in this application (see Section 12). The spent activated carbon and calomel will be transported to the proposed TSF and treated onsite to extract mercury as discussed in this section. The extracted elemental mercury along with the elemental mercury delivered to the facility will be stored on-site, pending final completion of the National Repository. The proposed TSF is designed to store 1,024 pigs of elemental mercury. This is equivalent to approximately 11 years of received and extracted elemental mercury based on current production rates. 1.2.1 Material Receiving, Handling, and Storage This section discusses the receipt, handling, and storage of elemental mercury, spent activated carbon, and calomel at the proposed TSF. The procedures discussed herein are in accordance with the US DOE Interim Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury (2009). Mercury and mercury-bearing materials will arrive by truck at the proposed TSF. Upon approval by the facility’s security personnel: Trucks will be admitted through the Perimeter Security Gate of the outer Perimeter Fence Trucks will be admitted through the Main Security Pass Gate into the proposed TSF compound Trucks will be admitted into the fenced RCRA Facility Area where the truck will prepare to park in the receiving area. The facility’s outer loading door will open and the inner bay door (located between the truck bay and the proposed TSF’s plant spaces) will remain closed. Once the truck fully enters the unloading area, the truck engine will be turned off and then the outer door will be closed. The presence of any potential mercury vapor concentrations within the trucks will be measured before any visual inspection or unloading of the containers occurs. After mercury vapor concentrations are confirmed to be within acceptable limits (OSHA limit is 0.1 milligram per cubic meter [mg/m 3 ]), facility workers will visually inspect the containers and pallets before removing them from the truck bed. This primary inspection will focus on manifest validation, evident spills, and evaluation of container and pallet integrity. Should a spill be discovered, standard facility cleanup procedures will be implemented. Refer to Section 22 for information on the acceptable types of material transport/storage containers. The proposed TSF will retain the original, signed manifest and send a signed copy back to the waste generator. Any discrepancies between the manifest and the actual material received at site will be resolved in a timely manner. Where discrepancies cannot be accounted for within 15 PMR RCRA Permit Application, Dry Hills Facility Page 15 JBR Environmental Consultants, Inc. | HATCH March 2013

typically be provided in this area during the winter months. This area will be maintained under<br />

negative pressure, in common with the rest of the plant spaces.<br />

Process Area<br />

The HVAC system for the process area (including the laboratory area) consists of a roofmounted,<br />

air conditioning unit, air distribution ductwork, and HVAC system controls. The<br />

HVAC system will be designed to typically maintain a target indoor air temperature of 70°F or<br />

below. The process area will be maintained under negative pressure relative to the surrounding<br />

areas.<br />

Inspection Area<br />

The HVAC system for the inspection area consists of a roof-mounted, air conditioning unit, air<br />

distribution ductwork, and HVAC system controls. The HVAC system will be designed to<br />

typically maintain a target indoor air temperature of 70°F or below. The inspection area will be<br />

maintained under negative pressure, in common with the rest of the plant spaces.<br />

Truck Unloading Area<br />

The HVAC system for the truck unloading area consists of exhaust fans, air intake louvers with<br />

motorized dampers, a carbon monoxide (CO) gas detection system, and a nitrogen oxides (NOx)<br />

gas detection system, compliant with applicable workplace standards.<br />

Within the truck unloading area, it is not expected that mercury vapor will be present. The<br />

inspection procedures taking place at the truck unloading area will involve:<br />

Mercury vapor detection using a portable device.<br />

Checking the container labels.<br />

Checking the delivery manifest(s).<br />

This area is not designed for open containers containing mercury and mercury-bearing materials.<br />

Accordingly, temperature control will not be provided in the truck unloading area, but this area<br />

will be maintained under negative pressure when the bay doors are closed.<br />

1.2 Facility Operation and Process Descriptions – 40 CFR 270.14(b)(1)<br />

& 264.31<br />

The proposed TSF Building is specifically designed to follow the best practices for mercury<br />

managing facilities and to safely manage mercury. All loading and unloading will occur within<br />

this engineered structure. The building will be constructed of non-combustible materials to<br />

reduce fire susceptibility. Flammable materials will not be stored in the storage area.<br />

All applicable engineering and building design standards have been applied to this building.<br />

Mercury spill kits and mercury absorbent will be available in sufficient quantities to prevent any<br />

spilled mercury from being released to the environment or threatening human health. All facility<br />

PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 14<br />

JBR Environmental Consultants, Inc. | HATCH March 2013

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