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days, the NDEP Administrator will be informed in writing and provided with a copy of the<br />

manifest.<br />

After the initial inspection and manifest confirmation, a forklift will transport the pallets from the<br />

truck to a designated receiving area. Once inside, the containers and pallets will undergo a more<br />

thorough inspection for leaks, cracks, dents, beading, corrosion, and seal integrity. Mercury<br />

vapor levels will be monitored in the receiving area while these actions are being performed.<br />

In the unlikely event mercury vapor is discovered above the threshold (i.e., OSHA limit), or a<br />

container is found to be compromised:<br />

For containers holding elemental mercury, the damaged container will be placed in a<br />

custom designed drum specifically designated for this purpose (see Section 22).<br />

For containers holding spent activated carbon, the contents of the damaged drum will be<br />

emptied into a designated clean drum and transported to the retort area to be retorted.<br />

The empty damaged drum will also be retorted.<br />

For containers holding calomel, the calomel slurry will typically be contained within<br />

secondary containment (e.g., overpacks, spill trays, or other appropriate containment).<br />

Calomel will then be pumped into a clean drum. At the automated feed preparation<br />

station, the calomel (in the clean drum) will be suctioned out and will enter the treatment<br />

process. Both the breached drum and secondary containment vessel will be triple rinsed<br />

at the calomel feed preparation area.<br />

As part of the receiving process, a portion of the received material arriving at site will be<br />

fingerprinted before processing and storage. Fingerprinting will consist of random sampling and<br />

testing of the material (see Section 9). Test criteria will be dependent on the material being<br />

received, but may include some or all of the following: a physical description, elemental mercury<br />

purity, specific gravity, and pH. Testing of samples will be performed in a laboratory room<br />

within the proposed TSF’s process area.<br />

Pigs will be removed from their skids and transported by forklift to the storage area. Section 22<br />

of this document and the General Arrangement Drawings (provided in Appendix 1-A) present<br />

details on elemental mercury storage.<br />

Small quantities of elemental mercury may also be received at the proposed TSF in 76-pound<br />

flasks. These flasks will be staged at a dedicated elemental mercury transfer station where their<br />

contents will be emptied into pigs. (The mercury storage area is designed to store pigs.) The<br />

transfer station will be located in the process area, and will be equipped with spill containment<br />

and ventilation to prevent mercury or mercury vapors from escaping. A sketch of the elemental<br />

mercury transfer station is shown in Figure 1.2-1.<br />

PMR <strong>RCRA</strong> <strong>Permit</strong> <strong>Application</strong>, <strong>Dry</strong> <strong>Hills</strong> Facility Page 16<br />

JBR Environmental Consultants, Inc. | HATCH March 2013

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