Valero staff reviewed the management of wastes resulting from fugitive spills confined to the refinery. The review revealed that although temporary accumulation preparations were made, the reliability of the temporary accumulation was questionable. Valero also found that there was at least a two hour delay in mobilizing temporary containers for large volume incidents (20 yds). Similar concerns were raised in a review of procedures during major refinery turnarounds and periodic tube bundle cleaning operations. Temporary waste storage sites increase risk due to human error, take time and effort to prepare and all residues for solid waste disposition that may have come into contact hazardous wastes could become hazardous wastes.
While it is not innovative, it is good common sense to contruct permanent tanks to handle these periodic events. Tanks were constructed with a special liner and a leachate collections system according to 40 CFR 264 Subpart J requirements. For spills, the tanks allow debris to be removed immediately to prevent further migration and avoid delays while waiting for temporary containers. Furthermore, materials used to temporarily contain hazardous waste must be disposed of as hazardous waste after use. Permanent tanks greatly reduce the risks in handling waste due to human error.
As a result of this project, Valero has been able to reduce the amount of hazardous waste generated (K050 refinery wastes) from tube bundle cleaning alone by 6 tons from 1993 to 1994. Because of the inconsistent nature of accidental spills and tube cleaning, these reductions are difficult to measure. Valero has been able to determine, for instance, that the decanting and isolating capabilities allowed Valero to reduce one stream by 1,100 tons on the first turnaround (disposal would cost approximately $276,000, a $36,000 savings of the cost of the tank construction).
Details of Reductions
Additional Information :
While there is a small return from decanting and reduced hazardous waste disposal, the major reason Valero implemented this project was to reduce the risk of a hazardous waste spill due to human error in handling wastes in a temporary storage site.