P.1 

RCRA Box 321 

Prepped by Ryan Dugan 

Document Number: 

254) OGRC-S0041 .A 

Docket Number: 

F-93-OGRC-FFFFF 

Printed 5/8/2007 3:36:33 PM Sheet 254 of 259 
TRIP REPORT: 

CRUDE OIL RECLAIMERS 

IN WEST TEXAS AND NEW MEXICO 

Submitted to: 

U.S. Environmental Protection Agency 

Office of Solid Waste 

Waste Management Division, Special Waste Branch 

401 M Street, SW 

Washington, DC 20460 

November 20, 1990 

Submitted by: 

Science Applications International Corporation 

8400 Westpark Drive 

McLean, VA 22102 

EPA Contract No. 68-W0-0025 

SAIC Project No. 1-824-03-322-05 
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INTRODUCTION 

In Section 3001(b)(2)(B) of the Resource Conservation and 

Recovery Act (RCRA), the Environmental Protection Agency (EPA) 

was required to make a regulatory determination under RCRA 

Subtitle C for wastes from the exploration, development, and 

production of crude oil, natural gas, and geothermal energy. 

EPA's Regulatory Determination for Oil and Gas an Geothermal 

Exploration, Development and Production Waste (53 Federal 

Register 25454), states that among the wastes not included in the 

original exemption were "liquid and solid wastes generated by 

crude oil and tank bottom reclaimers." With the Toxicity 

Characteristic (TC) (appending 25 additional organics to the list 

of toxic constituents, including benzene) effective on September 

25, 1990, those wastes exceeding TC regulatory levels are 

classified as hazardous waste and thus require management 

according to Subtitle C criteria. 

The crude oil reclaimers have now come forward and said that 

the costs of disposal for wastes from reclaiming operations will 

dramatically increase. They claim that application of the TC to 

waste crude oil reclaimers will drive most of the them out of 

business and force industry to dispose of greatly increased 

volumes of exempt crude oil wastes on-site or at exempt 

landfills. 

The crude oil reclaimers have asked EPA to re-examine the 

original exemption and/or the applicability of the TC as it 

applies to them. As part of EPA's response to their request, 

three site visits were made. The crude oil reclaimers visited 

were: Parabo, Inc. in Eunice, New Mexico; A. A. Oilfield 

Services in Hobbs, New Mexico; and 1st Class Operations, Inc. in 

Midland, Texas•. Also visited was Drilling Muds Disposal, a 

drilling fluids disposal facility adjacent to 1st Class 

Operations. 

The following gives a list of participants at all the site 

visits, the facility location, the facility personnel present, 

the State personnel present, a facility description, and 

reclaimed crude oil production data (if available). Copies of 

the slides taken on the facility visits are available upon 

request. 

Participants in the trip were: Robert Tonetti, Environmental 

Protection Agency; Kristy Allman, Science Applications 

International Corporation; Tim Sampson, American Petroleum 

Institute; Jerry Simmons, Interstate Oil Compact Commission; and 

Neal Thurber, Amoco Corporation. 
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FACILITIES 

Location #1 (visited October 22, 1990) 

Parabo, Inc 

P.O. Box 1737 

Eunice, NM 

Facility and State Agency Participants 

David Boyer, Environmental Bureau Chief 

Oil Conservation Division, 

Energy, Mineral and Natural Resources Division, 

State of New Mexico . 

Roger Anderson 

Oil Conservation Division, 

Energy, Mineral and Natural Resources Division, 

State of New Mexico 

Jim Britton, President 

Unichem International 

Charles N. Root, Manager Personnel, Safety & Regulatory Affairs 

Unichem International 

Wayne Price 

Unichem International 

Richard Brakey, Division Manager 

Parabo, Inc. (a subsidiary of Unichem) 

Parabo Facility Process 

Parabo, Inc., a subsidiary of Unichem International, is a 

produced-brine-water disposal and crude oil reclamation facility 

(See Figure 1). The Parabo facility receives three types of 

waste; produced water, tank bottoms, and off-spec crude oil. The 

wastes are brought to the facility by the Rowland Trucking 

Company, a subsidiary of Unichem. They recover crude oil from 

exempt E&P wastes by (1) skimming the off-spec crude oil that 

separates from the produced water in the produced-water storage 

tanks and (2) separating the crude oil and basic sediment & water 

(BS&W) in a heat treatment process. Currently, they are not 

operating the heat treatment portion of the crude oil reclamation 

operation, but are still skimming the off-spec oil from the 

produced water. 

If the crude oil from the produced water contains less than 

1% BS&W, it is placed in a storage tank and then sold to the 

pipeline company as marketable crude oil. Prior to the effective 

date of the TC Rule, if the off-spec crude oil contained greater 
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Figure 1 

PARABO, INC. 

EUNICE, NM 

Produced 

Water 

Produced Water, 

Off-spec Crude Oil 

and 

Tank Bottoms 

Off-Spec Crude Oil 

and Tank Bottoms 

Crude Oil 

Storage 

Tanks 

On-site 

State Permitted 

Surface Impoundments 
P.6 

than 1% BS&W, it was piped to a heat exchanger and heated to 

between 160°F and 180°F. A chemical emulsion breaker was added 

to separate the oil, BS&W, and water. The crude oil was removed 

and stored on-site until it was sent to the pipeline as 

marketable crude oil. The BS&W was placed into an on-site 

surface impoundment, which is permitted by the State. Parabo 

disposes of produced water resulting from the skimming operation 

by placing it in one of six surface impoundments and allowing the 

water to evaporate. 

Notes of interest: 

The facility appeared to be neatly kept with no visible spills or 

leaks. 

The total of 8 unlined surface impoundments (6 produced water, 1 

drilling fluids (with considerable oil content), and 1 BS&W) is 

in a gravel quarry which is underlain by 90-400 feet of Triassic 

redbed clay. The impoundments are configured in a treatment 

train for the floatation of oil. The facility is surrounded by 

approximately 80 ground-water monitoring wells. The closest 

potable ground-water source is approximately 3 miles to the 

southwest (it is primarily used for watering of livestock). The 

ground-water surrounding the Parabo facility is highly 

mineralized saltwater, therefore unsuitable for use as drinking 

water. 

David Boyer said that due to an improperly built dike between two 

impoundments on the east side of the facility some produced water 

migration occurred into the unsaturated zone that was detected by 

the monitoring wells. With the installation of a French drain 

down to the redbed clay, Parabo is currently in the process of 

correcting the situation under the supervision of the State of 

New Mexico. David Boyer also said that the monitoring wells have 

not detected migration from the BS&W impoundment. 

The BS&W impoundment is currently holding approximately 500 

thousand barrels of BS&W waste. It is approximately 250 feet 

wide, 450 feet long and 80 feet deep. In the early 1980's, prior 

to Parabo ownership, the BS&W pit was used for tank bottom 

storage and has considerable recoverable oil. Parabo has 

contracted a company with a heater barge to recover the oil from 

the pit. Since the effective date of the TC, this operation has 

been stopped. 

Parabo did perform the TC analysis on their waste and said they 

would provide EPA with a copy of the results. 
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Location #2 (visited October 22, 1990) 

A.A. Oilfield Services, Inc. 

P.O. Box 5208 

Hobbs, NM 88241-5208 

Facility and State Agency Participants 

Barry A. Peters, Vice President 

A.A. Oilfield Services, Inc. 

David Boyer, Environmental Bureau Chief 

Oil Conservation Division, 

Energy, Mineral and Natural Resources Division, 

State of New Mexico 

Roger Anderson 

Oil Conservation Division, 

Energy, Mineral and Natural Resources Division, 

State of New Mexico 

Facility Description 

A. A. Oilfield Services is a produced-water disposal and 

crude oil reclamation facility with an on-site permitted Class II 

underground-injection well (see Figure 2). Prior to September 

25, 1990, A. A. reclaimed crude oil from off-spec crude oil, 

stock tank bottoms and by skimming crude oil from produced brine 

water. The incoming off-spec crude oil and tank bottoms were 

stored in 1000-barrel storage tanks until placed in the heat 

exchanger. The off-spec crude oil or tank bottom, with a BS&W 

quantity above 1%, was placed in one of two 500-barrel heat 

exchangers where the temperature was raised to approximately 

180°F, allowing for the separation of crude oil, produced water 

and BS&W. The crude oil was then placed into one of four 1000-

barrel storage tanks and sold as marketable crude oil to the 

pipeline. The produced water was placed into one of two 1000-

barrel storage tanks to later be injected into their Class II UIC 

well. The BS&W was then sent to a State permitted disposal 

facility, such as the Parabo facility. 

Notes of interest: 

The facility appeared to be neatly kept with no visible leaks or 

spills. The reclamation area was on a pad of crushed stone.. 

During the site visit, a truck was off-loading produced water. 

Due to the type of storage facility the produced water was taken 

from, the water was screened into a half submerged underground 

storage tank, to remove any large particles such as sticks or 

leaves. The produced water was then pumped into one of two 1000-

barrel storage tanks prior to underground injection. 
Figure 2 

A.A. OILFIELD SERVICES, INC 

HOBBS, NM 

P.8 

\r" 

Produced 

Water 

On-site 

State Permitted 

Underground 

Injection Well 

Produced Water, 

Off-spec Crude Oil 

and 

Tank Bottoms 

Off-Spec Crude Oil 

and Tank Bottoms 

Yes 

Heat 

Exchanger 

- . 

BS&W 

Crude Oil 

Crude Oil 

Storage 

Tanks 

Off-site 

State Permitted 

Surface Impoundment 
P.9 

A.A. has not performed a TC analysis of their waste. 

Production Data (barrels) 

Waste Produced 

Year 

1984 

1985 

1986 

1987 

1988 

1989 

Produced Water 

575,125 

705,501 

608,633 

554,028 

444,267 

564,426 

1990(8 mos.) 351.560 

Total 3,803,540 

BS&W 

10,125 

12,420 

10,715 

9,753 

7,821 

9,936 

6.189 

66,959 

Total 

585,250 

717,921 

619,348 

563,781 

452,088 

574,362 

357.749 

3,870,499 

Recovered Oil 

4,337 

5,075 

3,966 

4,035 

4,450 

4,896 

6.244 

33,003 

Note: Production data were provided by Barry Peters in a letter 

to Robert Hall, U.S. EPA. 

Location #3 (visited October 23, 1990) 

1

st Class Operations, Inc. 

Odessa Reclamation #1 

3223 Franklin 

Midland, TX 79701 

Facility and State Agency Participants 

Dub Huckabee, President 

1

st Class Operations, Inc. (a subsidiary of Cub Enterprises) 

Ron Huckabee, President 

Cub Enterprises 

Paul M. Bohannon, Attorney 

Porter & Clements 

Charles Ross, Assistant District Director 

Oil and Gas Division, Texas Railroad Commission 

State of Texas 

Facility Description 

The 1st Class Operations Facility reclaims crude oil 

strictly from stock oil tank bottoms (see Figure 3). The offspec crude oil is put in their heat exchanger and the temperature 

is brought to approximately 180°F. Fractions of crude oil, 

produced water, and BS&W separate, and the crude oil 

(approximately 4 percent BS&W) is removed and placed in one of 
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Figure 3 

1

ST

 CLASS OPERATIONS, INC. 

MIDLAND, TX 

Off-spec Crude Oil 

and 

Tank Bottoms 

Off-Spec Crude Oil 

and Tank Bottoms 

Crude Oil 

Storage 

Tanks 

Off-site 

State Permitted 

Surface Impoundment 
p. 11 

from the heat exchanger and placed in one of two 1000-barrel 

storage tanks for later disposal at an off-site State-permitted 

produced water disposal facility. The remaining BS&W is removed 

and taken to a State permitted land disposal facility for nonhazardous waste. 

Notes of interest: 

The facility appeared to be neatly kept with no visible spills or 

leaks. 

Dub Huckabee stated that since the effective date of the TC, and 

the loss of potential revenue resulting from the increase in"the 

price of crude oil, they have lost $55 to $60 thousand due to the 

closure of their facility. He also said that they did not 

perform the TC analysis on their wastes. 

Due to the low gravity of crude oil 1st Class has produced, they 

sold it to a producer of high gravity crude oil, who mixed the 

two grades to produce a marketable grade, and sold it to the. 

pipeline. 

Production Data (barrels) 

1990 

(8 mos.) 

Total 

Amount of Total 

Waste Treated 

16,665 

Calculated 

Produced BS&W 

6,647 

Calculated 

Reclaimed Oil 

10,018 

Note: Production data were provided by Geraghty & Miller, Inc. 

Location #4 (visited October 23, 1990) 

Drilling Fluids Management, Inc. 

Canyon Street 

Midland, TX 79701 

Facility and State Agency Participants 

Dub Huckabee, President 

1

st Class Operations, Inc. (a subsidiary of Cub Enterprises) 

Ron Huckabee, President 

Cub Enterprises 

Paul M. Bohannon, Attorney 

Porter & Clements 

Charles" Ross, Assistant District Director 

Oil and Gas Division, Texas Railroad Commission 

State of Texas 
P.12 

Facility Description 

Drilling Muds Disposal (DMD) is a State permitted drilling 

fluids disposal facility. They do not reclaim crude oil. The 

muds are brought in by truck and placed into one section of the 

lined surface impoundment. There is one lined surface 

impoundment divided by 5 unlined earthen berms (creating six 

sections) configured in a treatment train. After the muds are 

placed into the surface impoundment, a company-patented treatment 

technique is used; a biological stimulant is mixed with the waste 

in the impoundment. 

Notes of Interest: 

The facility appeared to be neatly kept with no visible spills or 

leaks. There were no visible tears in the surface impoundment 

liner. 

DMD is currently in the process of closing the first bermed 

section of the surface impoundment. 

DMD is permitted to dispose of BS&W from tank bottoms, although 

it was not clear to what extent they are being disposed of 

onsite. They are also permitted to accept contaminated soils. 

While at the facility, a truck carrying contaminated soils was 

off-loading. 

There is some joint ownership of DMD with 1st Class Operations. 

These two facilities are immediately adjacent to one another. 

CONCLUSION 

As of September 25, 1990, the effective date of the TC, the 

three crude oil reclamation facilities visited had voluntarily 

shutdown. Both State representatives said that most of the crude 

oil reclaimers were still operating, not because they meet the TC 

criteria, but due to the fact that they are unaware of the 

regulation. The State of Texas said that in the following weeks 

they were planning to begin enforcement proceedings against these 

reclaimers. 

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