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RCRA Box 321 

Prepped by Ryan Dugan 

Document Number: 

229) OGRC-S0023 

Docket Number: 

F-93-OGRC-FFFFF 

Printed 5/8/2007 3:36:32 PM Sheet 229 of 259 
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OWc- S0033 

American Petroleum Institute 

1220 I Street, Northwest 

Washington, D.C. 20005 

202-682-8000 

Tim Sampson 9 

Production Department 

202/682-8057 

January 7, 1991 

Mr. Robert Tonetti 

Office of Solid Waste 

Waste Management Division 

Environmental Protection Agency 

Mail Stop OS-323W 

Washington, D.C. 20460 

Dear Mr. Tonetti: 

Several weeks ago you requested that the American Petroleum 

Institute (API) supply EPA with information on production wastes 

that are representative of wastes "reclaimed" at crude oil 

reclaiming facilities. In response to your request, API is 

pleased to provide results of analysis of tank bottoms and vessel 

solids from oil production operations to use in your assessment 

of crude oil reclaiming operations. 

Because of concerns over possible Toxicity Characteristics (TC) 

rule compliance issues, many of these reclaiming operations are 

no longer in business. This has resulted, unfortunately, in one 

less disposal option for oil producers and a loss in recoverable 

crude oil resources. 

Crude oil reclaiming operations exist to reclaim crude oil from 

E&P vessels, produced water and/or produced water skimmings, oil 

contaminated soils/produced sand, and to blend off-spec crude 

with higher gravity crude for the purpose of producing salable 

petroleum. The operations perform reclamation through a 

combination of gravity separation and/or thermal treatment to 

temperatures on the order of 150-200 degrees Fahrenheit. An 

emulsion breaking surfactant may be used to improve oil/water 

separation. Such surfactants also are typically used in other 

E&P operations. 

Reclaiming operations usually generate two waste streams. One 

stream is water, which qualitatively should resemble produced 

water, and the second stream is the untreatable water/solids 

(formation solids, surface soil, or production system corrosion 

byproducts)/petroleum emulsion which remains when reclamation 

processing is complete. The waste water stream is usually 

disposed through downhole injection, via a permitted Class II 

well, and/or is discharged to a lined pit for evaporation. The 

solids waste stream is typically discarded or stored for further 

An equal opportunity employer 
PJ 

Mr. Robert Tonetti 

January 7, 1991 

Page two 

processing in a lined surface impoundment, or, is discarded at a 

permitted disposal facility. 

The reclaimer waste streams have not been sampled by API. 

However, API to date has analyzed seventeen waste streams that 

hypothetically could serve as a feedstock to the crude oil 

reclaiming operation. Attachment 1 is the full analytical data 

suite performed by ENSECO Rocky Mountain Analytical Laboratories. 

Figure 1 shows a frequency distribution for TCLP benzene levels 

in the crude oil tank bottoms directly from tanks, prior to any 

weathering. 

If we can assist you further on this issue or if you have 

additional questions on the data, please let me know. 

Sincerely, 

Attachments 

/fl