Environmental Engineering Reference
In-Depth Information
Such a TCM expertise is owned by the companies who obtained certification from regulatory
authorities. In some situations, refiner has no choice but use the services of these companies.
They include the certified owners of TSDFs operating under RCRA regulations. It might be
desirable that this process is conducted in a close cooperation with refiner who must be ready
to respond timely whenever necessary, i.e., a change in regulatory acts. The costs of these
services have been continuously increasing. Therefore, the final decision on the fate of spent
catalysts should only be made after all available options were carefully
considered.
Significant efforts have been made to bring the storage and disposal of spent catalysts under
control
[311]
. In spite of these efforts, there might still be cases of irresponsible dumping of
spent catalysts. This was supported by the survey conducted by the API in 1982. The survey
concluded that only 70% of all spent non-regenerable catalysts were sent either to metal
reclaimers or were disposed of in commercial landfills
[312-314]
. It is probable that the
remainder of spent catalysts was disposed of on unauthorized sites. It is not certain that all
such sites were subsequently cleaned to ensure environmental compliance. It is hoped that
sufficient time has passed to realize that today that unauthorized dumping of spent catalysts
defies any logic.
Spent catalyst wastes could be disposed of into a landfill only if it could be proven with
certainty that both landfill facility and spent catalysts meet non-hazardous criteria. Thus,
landfill does not remove or destroy any hazardous materials that may pose long-term health
and environmental hazards unless they are properly managed. According to RCRA, not only
the approved dump-site owner is liable, but also the owner of the buried hazardous waste. This
environmental responsibility and/or liability continues for the life of the dump-site as well as
during the postclosure period until it is proven that the site no longer poses any danger to the
environment.
Historically, in 1982, commercial landfills were operating under the RCRA interim status
permits. However, the RCRA amendments issued in 1984 required all interim status facilities
to meet ground water and insurance requirements. For a continued operation, minimum
technology of a double liner and leachate collection system was required to be installed by
1988. In this regard, some refineries responded by replacing all surface impoundments with
the above ground tankage
[315]
. After closure, the spent catalyst and contaminated soil were
removed and the impoundment filled with an uncontaminated material. In view of the potential
future liabilities, such costly approach was deemed to be necessary, particularly in regard with
the re-authorization of the RCRA, which requires that most of the surface impoundments are
either retrofitted or closed. Originally, the concept of joint liability required that if something
went wrong with an unsecured landfill within 20 years of disposal (e.g., ground water
contamination), the company would be asked to cover cost of the entire clean-up
[316]
.
However, subsequently, this concept was modified and replaced with the unlimited liability.
