P.1 

RCRA Box 321 

Prepped by Ryan Dugan 

Document Number: 

218)OGRC-S0016.C 

Docket Number: 

F-93-OGRC-FFFFF 

Printed 5/8/2007 3:36:32 PM Sheet 218 of 259 
P.2 

0&RC-S<3o Mo.C 

Request by Waste Crude Oil Reclaimers 

September 18, L990 

Page -32- .. 

Appendi x B. LETTERS OF SUPPORT 
P.3 

GANDY CORPORATION 

OILHELD SERVICES 

P. O. BOX S2 7 

-_ . TATUM, NEW MEXICO 88267 

^ *> (SOS) 39S-4»9<»0 

September 17, 1990 

To Whom it may concern; Re: Plant Plant 5012 

Lea County New Mexico 

Gandy Corporation operates a reclaiming plant 5012 in Lea County New Mexico: 

We treat tank bottoms and oil spills, this is virgin crude oil and it it 

treated with heat and a small amount of oil field chemicals. 

This oil comes from the general area of the plant. 

Some oil is purchased from Oil Companies who do not have the facilities to 

treat their off spec oil, also a small amount of pipe line crude is purchased 

to blend with the crude oil to be treated to help bring the oil to a salable 

refinery product. 

The volume of products handled thru plant 5012 is as follows: 

Product on hand as of 1-1- 89 8,075 bbls 

volume brought to pLant from 1-1-89 thru 9-1-90 22,918 bbls 

Bbls sold 1-1-89 thru 9-1-90 11,624 

Water and BS disposed of from 1-1-89 thru 9-1-90 6,199 bbls 

untreated products in stock as of 9-1-90 13,170 bbls 

tbt<-/ 

—?** 

Dale Gandy, President 
P.4 

A . A , OILFIELD SERVICE, INC. 

Post Office Box 5208 Cydl A. Schollor, vtcoProitaont 

H088S, N6W MEXICO S8241-5208 8«rry A. Pctorj, Vie* •/•rcsWonf 

September id, 1990 

United States Environmental Protection Agency 

400 H Street 

Washington, D.c. 

ATTN: nr. Robert Hall 

Dear Mr. Hall: 

The oil industry Is facing many new and diverse challenges. Industry 

competitiveness In the world market as well as environmental responsibility coQtlnue to play a very Important role la the decisions that 

affect the Industries ability to meet the energy needs of the general 

public. 

W© at A.A. Oilfield Service, Inc. are concerned over the recent E.P.A. 

decision to no longer exempt wastes generated by small crude oil 

reclamation operations. The E.P.A. exemption expires September 25, 

1990. The wastes generated by crude oil reclamation are an accumulation of stock oil tank bottoms. We fail to see the difference 

between stock oil tank bottoms and reclaimed oil tank bottoms. The 

oil salvaged from stock tank bottoms la marketable and is used to 

ease America's dependence on foreign oil. If crude oil reclamation 

wastes are not exempt, these plants will be forced to close immediately. Plant closings would create a huge end immediate problem of 

accumulation of wastes at the lease site. Illegal dumping of 

these wastes In an unaccountable manner would become a very serloua 

problem. 

Environmental responsibility ia a must for all industry. It Is 

Important to the oil industry and the environment that reclaimed oil 

tank bottoms remain exempt from the E.P.A. hazardous waste guidelines. 

Sincerely, 

Berr^A. Peters, 

Vice-President 
P.5 

PARABD, INC. 

f>. O. Bn_ 1717 

KUNICK, NKW MKKCO HU I 

September 18. 1990 

i.'nited States Environmental Protection Agency 

•100 .1. Street. 

Washington, D.C. 

ATTJS: nr. Robert Hall 

Dear Mr. Hdll; 

I am very concerned about the September 25, 1990, expiration 

of the exemption for crude oil treating plants and tank bottom 

reclaimers wit*h liquid and solid wastes remaining after oil 

treatment and removal. 

Parabo, inc., located io Southeast New Mexico is a New Mexico 

Oil Conservation Division permitted salt water disposal and crude 

oil reclamation facility. We provide a service to the oil industry 

<*s well as the nation by recovering marketable crude oil from off 

spec crude oil as well as accumulated stock oil tank bottom-, 

brought to the facility from production sites located through out 

the Permian Basin. 

The treating process that is utilized is the identical process 

used at the veil head or production site. A heat exchanger is used 

co heat the off spec crude oil in an insulated treating tank. Small 

amounts of production treating chemicals are injected to enhance the 

oil and water separation process. The marketable crude oil, less 

than \% B S & V content, is transported to a crude oil pipeline 

gathering facility and shipped to a refinery. The water and heavy 

waste are then disposed into oilfield exempt production waste 

systems. 

Parabo is providing a service and facility to handle large 

volumes of off spec crude oil and B S It V to the Permian Basin, if 

this waste is considered non-exempt on September 25, 1990, then we 

will be forced to cease all treating operations due to the high 

costs associated with the disposal of the treating plant wastes. 
P.6 

PARABO, INC 

m. o. am 17»~ 

SUNICB, NKW MtDOCO MX9 1 

\ i ; 

United States Environmental Protection Agency Page 2 

Mr. Robert Hall 

This waste is the same material located at all production sites and 

should retain the oil field exemption aa present. When facilities 

like Parabo can no longer treat this material as oilfield exempt 

waste and recover marketable crude oil, the nation will be without 

an industry that is able to further reduce our 4epeudei.ee on 

imported crude oil. 

I feel it is very important to the entire oil industry that 

crude oil reclamation facilities retain the exemption for reclaimed 

crude nil tank bottoms. 

Sincerely 

PARABO, INC. 

Richard Brakey 

Division Manager 

^ 

RB/mh