Management of Refinery Waste

However, before a refinery can determine if its waste is hazardous, it must determine that the waste is indeed a solid waste. In 40 CFR 261.2, the definition of solid waste can be found. If a waste material is considered a solid waste, it may be a hazardous waste in accordance with 40 CFR 261.3. There are two ways to determine whether a waste is hazardous. These are to see if the waste is listed in the regulations or to test the waste to see if it exhibits one of the characteristics (40 CFR 261). 

There are four lists of hazardous wastes in the regulations wastes from nonspecific sources (F list), wastes from specific sources (K list), acutely toxic wastes (P list), and toxic wastes (U list) there are also the four characteristics mentioned before ignitability, corrosivity, reactivity, and extraction procedure toxicity. Certain waste materials are excluded from regulation under the RCRA. The various definitions and situations that allow waste to be exempted can be confusing and difficult to interpret. One such case is the interpretation of the mixture and derived-from rules. According to the mixture rule, mixtures of solid waste and listed hazardous wastes are, by definition, considered hazardous. Similarly, the derived-from rule defines solid waste resulting from the management of hazardous waste to be hazardous (40 CFR 261.3a and 40 CFR 261.1c). 

There are five specific listed hazardous wastes (K list) generated in refineries, K048 to K052. Additional listed wastes, those from nonspecific sources (F list) and those from the commercial chemical product lists (P and U), may also be generated at refineries. Because of the mixture and derived-from rules, special care must be taken to ensure that hazardous wastes do not contaminate nonhazardous waste. Under the mixture rule, adding one drop of hazardous waste in a container of nonhazardous materials makes the entire container contents a hazardous waste. 

As an example of the problems such mixing can cause, consider the case with API separator sludge that is a listed hazardous waste (K051). The wastewater from a properly operating API separator is not hazardous unless it exhibits one of the characteristics of a hazardous waste. That is, the derived-from rule does not apply to the wastewater. However, if the API separator is not functioning 

This wastewater is often cleaned further by other treatment systems (filters, impoundments, etc.). The solids separating in these systems continue to be API separator sludge, a listed hazardous waste. Therefore, all downstream wastewater treatment systems are receiving and treating a hazardous waste and are considered hazardous waste mauagement units subject to regulation. 

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