Environmental and Safety Aspects of Spent Hydroprocessing Catalysts - Spent Hydroprocessing Catalysts - page 96

which are removed from expanded and/or ebullated bed reactors, e.g., H-Oil and LC-Fining
reactors, which according to refining terminology, are classified as typical hydrocracking
reactors, although in these systems, the removal of impurities occurs in parallel with
hydrocracking. Also, hydrorefining is generally considered as the last step before
specifications of commercial fuel are attained. Therefore, it may be conducted under less
severe conditions than hydrotreating. This suggests that there may be some inconsistencies
between the terminology used by regulatory authorities and petroleum refiners. To reconcile
the language discrepancies, it may be concluded that all catalysts removed from all
commercial hydroprocessing operations have to be classified as hazardous wastes.
Some definitions of solid waste by EPA under RCRA may be subjected to interpretation. For
example, refining industry represented by API has been considering solid waste as the material
that is being discarded by virtue of being disposed of, abandoned or thrown away, rather than
being recycled [302] . Therefore, the material that is being recycled (e.g., regenerable spent
catalysts) should not be classified as solid waste contrary to the spent non-reusable catalysts
that are being sent for disposal. Such exclusion of spent hydroprocessing catalysts from
hazardous listing is necessary to provide a cost-effective management option for recycling.
This may also encourage recycling option over disposal.
For transportation purpose, the waste is categorized in three different lists, i.e., green, amber,
and red [303] . The green list covers non-hazardous waste that is only subject to normal
commercial transactions. The “amber” list covers wastes that exhibit hazardous characteristics
or contain hazardous components. In the case of transportation, such waste requires
notification to all authorities and parties involved. Also, a tracking document is required for
the movement of waste listed as “amber”. The “red” list hazardous wastes require the same
notification as the “amber” list wastes. However, for such wastes, a written consent is required
from all concerned authorities before the transport can take place.
5.1.2 Transportation of Spent Catalysts
In OECD countries, the Chief Executive Officer of the company is legally responsible for all
environmental issues including transportation and disposal of waste [304] . It is believed that
directors and other lower levels officers in the company may also play certain role in these
actions through the laws of joint and several responsibilities.
The shipment of spent hydroprocessing catalysts is regulated by the Transportation of
Dangerous Goods Act (TDGA). In addition, the Basel Convention prohibits the international
shipment of hazardous waste between developed and developing countries [311] . In the US,
such shipments are regulated by EPA regulations that require a waste receiving country to
certify its willingness to accept hazardous waste. In the European Community (EC), the
transportation of hazardous waste including spent catalysts is controlled by two different