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A number of wastes commonly generated at refineries are hazardous under RCRA. The largest number of different RCRA hazardous wastes are generated during wastewater treatment prior to discharge. These could include:

  • API separator sludge (K051);
  • Slop oil emulsion solids (K049);
  • Other primary oil-water separator sludge, barscreen debris (F037);
  • Characteristic wastes containing chromium (D007) or lead (D008);
  • Dissolved air flotation floats (K048); and
  • All other sludge, floats and used filter bags (F038)

Other potential refinery wastes regulated under RCRA include:

  • Those generated from cleaning of heat exchanger bundles (K050);
  • Desalter mud (F037);
  • Laboratory wastes (F003, F005, D001, etc.);
  • Spent alkylation sulfuric acid (D002, except when used to produce virgin sulfuric acid, 40 CFR 261.4(a)(7)) and leaded tank bottom corrosion solids (K052);
  • Waste paint materials (D001); and
  • Wastes containing benzene (D018).

Spent process catalysts are occasionally RCRA characteristic hazardous wastes for reactivity due to benzene (D018) or for toxicity due to sulfur on the catalyst surface (D003).