Primary Sludge Listing

The Primary Sludge rule, effective May 2, 1991, lists primary petroleum refinery sludge, designated F037 and F038, as hazardous wastes [70]. It governs all sludges generated from the separation of oil/water/solids during the storage or primary treatment of process wastewaters and oily cooling waters. These include API separator sludge, DAF floats, and sludges from all surface impoundments prior to biological treatment. Surface impoundments that receive or generate these wastes must comply with minimum technology requirements (MTRs) within four years of the promulgation date. Examples of these MTRs are double liners, leachate collection,

Benzene Neshap
Figure 19 Bay area refinery effluent treating block flow diagram. This refinery has a complicated wastewater treatment scheme because of the toxicity characteristics rule to separate streams with higher benzene concentrations for treatment in aboveground biotreater. (From Ref. 72.)

and groundwater monitoring. Most refiners chose to reconfigure their wastewater collection and treatment systems by replacing impoundments with above-ground tanks, and by lining or enclosing process wastewater conveyance ditches. About 25 U.S. refineries practise sludge coking to dispose of oily, indigenous sludges [70]. In this process, the sludge is injected into coke drums during the quench cycle.

Benzene NESHAP

USEPA issued the NESHAP for benzene waste operations March 7, 1990, under the Clean Air Act. The compliance date was May 1992. It affects not only equipment leaks but also emissions of benzene in wastewater streams. Facilities with greater than 10 tonnes/year benzene in wastewater streams are affected. They must identify wastewater streams containing greater than 10 mg/L benzene and divert them to units that will reduce benzene to acceptable levels, that is, below 10 mg/L or by 98%. This rule affected most major refineries and olefins plants. Mobil Corp. spent $10 million on a benzene recovery project at its Chalmette, La., refinery. The refinery uses vacuum steam stripping to decrease benzene emissions by about 10 tonnes/year. One Gulf Coast petrochemical plant has also spent $10 million on a wastewater stripping facility, which reduced benzene levels from several thousand mg/L to less than 5 mg/L [70].

On March 5, 1992, USEPA delayed the effective date of the NESHAP until it clarified some confusing points raised by members of the petroleum industry. The final clarifying amendments to the benzene NESHAP were issued by USEPA on January 7, 1993 [72a].

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