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

Initially, it is anticipated that more floor space will be required for storage of calomel, but as
inventory levels of elemental mercury increase, pending completion of the National Repository,
more floor space will be allocated for storage of elemental mercury. The FSSMP will be
developed and implemented upon permit approval, but prior to material receipt. The FSSMP
will be updated as necessary to govern the type and quantity of waste received.
Calomel drums will be kept in a designated temporary storage area until processed. Containment
will be in accordance with Section 22 of this document.
Drums of calomel will be transported via forklift to the process area when they are ready to enter
the treatment process. Spent activated carbon will be stored in the same area as calomel under
identical conditions. Pallets will be transferred to the process area by forklift as required for
treatment (see Appendix 1-C Process Flow Diagrams).
Management practices will prevent unauthorized personnel (e.g., delivery truck drivers) from
accessing the inner plant spaces of the proposed TSF. Typically, the inner door will be opened
only for authorized operational purposes, such as transfer of containers or maintenance. Once the
inspection and material transfer procedure is complete and the truck driver receives appropriate
documentation, the inner door will be closed.
Once the inner door is closed, the outside delivery bay door can be opened, allowing the truck
driver to exit. During normal operations, the outside delivery bay door will close after the truck
leaves and will remain closed until the next delivery (see General Arrangement Drawings
provided in Appendix 1-A).
Secondary containment will be provided. A summary of the secondary containment features for
the proposed TSF is set forth in the following Table 1.2-1.
Tanks
Or Containers
Mercury Pigs
Calomel Drums
Table 1.2-1: Secondary Containment Capacities
Maximum Working
Volume
19,456 gallons (19 gallons
per pig and max 1,024 pigs
in storage at 11 years)
4,180 gallons
(55 gallons per drum and
max 76 in storage at any
time)
Regulatory
Requirement at
Full Capacity
1,950 gallons
418 gallons
Actual Containment Provided
Each spill tray w/ 8 pigs can
hold 25 gallons (3,200 gallons
at maximum capacity [1024
pigs]),
Total designed bunded area
(i.e., the building envelope) –
95,750 gallons
Total designed bunded area (i.e., the
building envelope) – 95,750 gallons
PMR RCRA Permit Application, Dry Hills Facility Page 18
JBR Environmental Consultants, Inc. | HATCH March 2013