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The Spent Caustic Solutions From Petroleum Refining Exclusion from Regulation as a Solid Waste 40 CFR 261.4(a)(19) excludes Spent Caustic Solutions From Petroleum Refining from regulation as a solid waste - and thus as a hazardous waste - if the conditions of the exclusion are met. This presentation briefly summarizes the requirements of this RCRA conditional exclusion from regulation.
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EXCLUSIONS FROM REGULATION AS SOLID WASTEOne presentation in a series that briefly explains the Federal exclusions from full regulation for certain materials under the Resource Conservation and Recovery Act (RCRA).
This presentation: 40 CFR 261.4(a)(19):Spent caustic solutions from petroleum
refining
40 CFR 261.4(a)(19)
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PRESENTED BY:
Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com
A different kind of training.
40 CFR 261.4(a)(19)
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40 CFR 261.4(a)
• Paragraph ‘a’ of section 261.4 identifies 26 materials excluded from regulation as a solid waste.
• If a material does not meet the definition of a solid waste, it cannot be a hazardous waste.
Solid Waste
Hazardous Waste
40 CFR 261.4(a)(19)
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What is Excluded @ 40 CFR 261.4(a)?
1) Domestic sewage.
2) Point source discharge
3) Irrigation return flow
4) Radioactive waste
5) In-situ mining
6) Pulping liquors
7) Spent sulfuric acid
8) Reclamation in
enclosed tanks
9) Spent wood preservatives
10) Coke by-product wastes
11) Splash condenser dross residue
40 CFR 261.4(a)(19)
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What is Excluded @ 40 CFR 261.4(a)?
12) Hazardous secondary materials from the petroleum refining industry
13) Excluded scrap metal
14) Shredded circuits boards
15) Pulping condensates derived from kraft mill steam strippers
16) Comparable fuels
17) Mineral processing secondary materials being recycled
18) Petrochemical recovered oil
19) Spent caustic solutions from petroleum refining
40 CFR 261.4(a)(19)
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What is Excluded @ 40 CFR 261.4(a)?
20) Hazardous secondary materials used to make zinc fertilizers
21) Zinc fertilizers made from hazardous wastes
22) Used cathode ray tubes (CRTS)
23) Hazardous secondary material generated & reclaimed w/i the US
24) Hazardous secondary material transferred to another person for reclamation
25) Hazardous secondary material exported from the US for reclamation
26) Solvent-contaminated wipes sent for cleaning & reuse
40 CFR 261.4(a)(19)
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Spent Caustic Solutions From Petroleum Refining
“Petroleum refineries use caustics to remove acidic compounds like mercaptans from liquid petroleum streams to reduce product odor and corrosivity as well as to meet product sulfur specifications. Spent liquid treating caustics from petroleum refineries are excluded from the definition of solid waste if they are used as a feedstock in the manufacture of naphthenic and cresylic acid products. EPA believes that spent caustic, when used in this manner, is a valuable commercial feedstock in the production of these particular products and is, therefore, not a solid waste.”
2011 RCRA Orientation Manual
40 CFR 261.4(a)(19)
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“The following materials are not solid wastes for the purpose of this part…”
• Spent caustic solutions.
Used to…• Treat liquid petroleum streams.
At…• A petroleum refinery.
40 CFR 261.4(a)(19)
And…
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“The following materials are not solid wastes for the purpose of this part…”
• Spent caustic solution is used as a feedstock to produce:• Cresylic acid.
Or…• Naphthenic acid.
40 CFR 261.4(a)(19)
Unless…
Cresylic Acid
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“The following materials are not solid wastes for the purpose of this part…”
• The material is placed on the land.
Or…• Accumulated speculatively as defined in §261.1(c).
40 CFR 261.4(a)(19)
More on speculative accumulation later
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More to Consider (1)…
“Spent caustic is a waste industrial caustic solution that has become exhausted and is no longer useful (or spent). Spent caustics are made of sodium hydroxide or potassium hydroxide, water, and contaminants. The contaminants have consumed the majority of the sodium (or potassium) hydroxide and thus the caustic liquor is spent…”
40 CFR 261.4(a)(19)
Wikipedia, the free encyclopedia
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More to Consider (2)…
• Learn more about Speculative Accumulation.
• USEPA information about cresylic acid.
• Check with your State as it may not recognize this Federal exclusion.
40 CFR 261.4(a)(19)
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40 CFR 261.4(a)(19) Verbatim:
(a) Materials which are not solid wastes. The following materials are not solid wastes for the purpose of this part:
(19) Spent caustic solutions from petroleum refining liquid treating processes used as a feedstock to produce cresylic or naphthenic acid unless the material is placed on the land, or accumulated speculatively as defined in §261.1(c).
40 CFR 261.4(a)(19)
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Got Questions About RCRA or HazMat Transportation?
I provide both:
RCRA Training for Hazardous Waste Personnel
And…
HazMat Employee Training
Seminar, Webinar, or Onsite
Daniels Training Services815.821.1550Info@DanielsTraining.comwww.DanielsTraining.com
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40 CFR 261.4(a)(19)
