New EPA rule will affect spent catalyst management.

Cesar Trevino has been Criterion's vice-president, sales, since the company's formation in 1988. He is responsible for marketing Criterion's entire product line of nonproprietary catalysts in the Americas, Europe, the Middle East, and Africa. Prior to joining the company, Trevino worked for Shell Oil Co. for 25 years in various capacities.

He began his career with Shell in 1963 as a technician in its research and development laboratories and assumed several positions, eventually becoming the coordinator for all catalysts used in Shell processes. In 1974, he became involved in catalyst sales, then progressed to product management.

Trevino holds a BS in chemistry from the University of Texas at Austin.

A new U.S. Environmental Protection Agency (EPA) rule, effective Feb. 8, 1999, will change the disposal requirements for managing spent hydrotreating and hydrorefining catalysts.

As the world's largest supplier of hydrotreating catalysts, Criterion Catalyst Co. LP is concerned about regulations that impact catalyst use by its customers. Therefore, Criterion has been closely following the development of this new rule and has prepared this summary which represents its best understanding of how the new rule will impact refiners' spent catalyst management practices.

The impact of the rule can vary depending on individual circumstances, and thus all refiners are urged to study the rule carefully to determine how it applies to their specific operations.

Spent catalyst rule

Under current EPA regulations, a generator of spent hydrotreating and hydrorefining catalysts is not required to classify spent catalysts as hazardous waste unless the catalyst being classified exhibits a hazardous characteristic (for example, benzene concentration exceeding the toxicity characterisitic leaching procedure (TCLP) limit, excessive reactive sulfides, etc.).

In 1989, however, the Environmental Defense Fund (EDF) filed a lawsuit alleging that the EPA had failed to meet the statutory mandates under RCRA to determine if certain wastes, including some spent catalysts generated by the petroleum refining industry, should be "listed" hazardous wastes. If the EPA determines that a spent catalyst should be a "listed" hazardous waste, it must be managed as a hazardous waste whether or not the catalyst exhibits any hazardous characteristics.

To settle this lawsuit, the EDF and the EPA entered into a June 1991 consent decree in which the EPA agreed to publish a final listing determination for 14 petroleum refining process wastes. Under the consent decree, the EPA was mandated to finalize a listing determination by Oct. 31, 1996; however, this …