The document discusses the exclusion of spent caustic solutions from petroleum refining from regulation as a solid waste under the Resource Conservation and Recovery Act (RCRA). Specifically: - Spent caustic solutions are used to treat liquid petroleum streams at petroleum refineries to remove compounds. - The spent caustic solutions are excluded from the definition of solid waste if used as a feedstock to produce naphthenic acid or cresylic acid. - The exclusion does not apply if the material is placed on the land or accumulated speculatively.

1. @DanielsTraining 1
EXCLUSIONS FROM
REGULATION AS SOLID
WASTE
One 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)

2. 40 CFR 261.4(a)(19) @DanielsTraining 2
PRESENTED BY:
Daniels Training Services
815.821.1550
www.DanielsTraining.com
Info@DanielsTraining.com
A different kind of training.

3. 40 CFR 261.4(a)
@DanielsTraining 3
• 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)

4. 40 CFR 261.4(a)(19) @DanielsTraining 4
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

5. 40 CFR 261.4(a)(19) @DanielsTraining 5
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

6. 40 CFR 261.4(a)(19) @DanielsTraining 6
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

7. @DanielsTraining 7
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)

8. 40 CFR 261.4(a)(19) @DanielsTraining 8
“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.
And…

9. 40 CFR 261.4(a)(19) @DanielsTraining 9
“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.
Cresylic Acid
Unless…

10. 40 CFR 261.4(a)(19) @DanielsTraining 10
“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).
More on speculative accumulation later

11. 40 CFR 261.4(a)(19) @DanielsTraining 11
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…”
Wikipedia, the free encyclopedia

12. 40 CFR 261.4(a)(19) @DanielsTraining 12
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.

13. 40 CFR 261.4(a)(19) @DanielsTraining 13
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).

14. 40 CFR 261.4(a)(19)
Got Questions
About RCRA or
HazMat
Transportation?
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RCRA Training for
Hazardous Waste
Personnel
And…
HazMat Employee
Training
Seminar, Webinar, or
Onsite
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Daniels Training Services
815.821.1550
Info@DanielsTraining.com
www.DanielsTraining.com
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