ENV-17-10 F037 and Refinery Sewer Inspection and Maintenance Programs

Description:

This paper provides a review of U.S. Environmental Protection Agency (EPA) refinery waste designation of F037 for primary oil/water/solids separation sludge, points of generation, characterization, and applicability criteria. Refinery wastewater sewer integrity inspection and maintenance programs are also discussed, providing a programmatic strategy for maintaining compliance in a systematic, fiscally predictable manner. For sewer programs, this paper presents implications of the F037 designation for refinery primary oil/water/solids separation sludge and discusses data gathering and analysis, inspection and repair methodologies and the impact on reporting and other remedial obligations on soil removed from a sewer repair project.