P.1 

RCRA Box 321 

Prepped by Ryan Dugan 

Document Number: 

238) OGRC-S0031 

Docket Number: 

F-93-OGRC-FFFFF 

Printed 5/8/2007 3:36:33 PM Sheet 238 of 259 
P.2 

0G.RC-S003I 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N.E.23RD STREET • P.O.BOX53127 • OKLAHOMACITY.OKLAHOMA73152-3127 

TELEPHONE: (405) 525-3556 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOW0 

Executive Director 

Address Reply to Headquarters Office 

MEMORANDUM 

October 27, 1990 

TO: Bob Tonetti 

FROM: Jerry R. Simmons, 

SUBJECT: Oil Reclamation Operations Questionnaire 

Enclosed you will find the responses received to date. I believe 

some states are confused on the definition of oil reclaiming 

operations and have included information on waste oil recycling 

programs in their states. Most of those cases are fairly obvious 

when reading through the questionnaires. If you would like for me 

to follow-up on a particular state's answers, just let me know. 

I have yet to hear from a couple of important states and have 

contacted them for their responses. Once received, I will forward 

the information to your office. 

I hope this information is useful, 

of further assistance. 

Please let me know if we can be 

JRS:bjh 

cc: Mike Fitzpatrick 

Kristy Allman 

MEMBER STATES. ALABAMA . ALASKA • ARIZONA • ARKANSAS - CALIFORNIA . COLORADO . ILLINO.S . INDIANA . KANSAS . KENTUCKY 

LOU.SIANA . MARYLAND . MICHIGAN . M.SS.SSIPPI . MONTANA • NEBRASKA . NEVADA . NEW MEXICO . NEW YORK . NORTH DAKOTA . OHIO 

OKLAHOMA • PENNSYLVANIA . SOUTH DAKOTA . TEXAS . UTAH . VIRGINIA . WEST VIRGINIA • WYOMING 

ASSOCIATES: GEORGIA . IDAHO . NORTH CAROLINA • OREGON . SOUTH CAROLINA . WASHINGTON 
P.3 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

ALABAMA 
P.4 

STATE OIL AND GAS BOARD OF ALABAMA 

420 Hackberry Lane 

P.O.BoxO 

Tuscaloosa, Alabama 35486 - 9780 

(205)349-2862 

October 24, 1990 

AL 

ERNEST A. MANCINI 

Supervisor 

Mr. Jerry R. Simmons 

Interstate Oil Compact Commission 

P.O. Box 53127 

Oklahoma City , OK 73152-3127 

OIL AND GAS BOARD 

Ralph W. Adams, Chairman 

Gaines C. McCorquodale, Member 

Matthew S. Metcalfe, Member 

Ernest A. Mancini, Secretary 

S. Marvin Rogers, Attorney 

TECHNICAL STAFF 

J. H. Masingill, Operations 

G. V. Wilson, Geology & Geophysics 

D. E. Bolin, Production & Engineering 

MOBILE OFFICE 

R. G. Hellmich, Regional Supervisor 

245-B Club Manor Drive 

Mobile, Alabama 36615 

(205)690-6308 

Re: Oil Reclamation Operations 

Dear Mr. Simmons: 

This letter is in response to your letter dated October 11, 

1990, requesting that we complete a questionnaire on the abovereferenced subject. 

Please find enclosed the completed questionnaire. The State 

Oil and Gas Board of Alabama does not regulate oil reclamation 

operations in the State. Therefore, we are unable to provide the 

requested information for most of the questions. 

If we can be of further assistance, please let us know. 

Sincerely, , 

Ernest A. Mancini 

Oil & Gas Supervisor 

Enclosure 
P.5 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEAOOUARTERSOFFICE: 900 N.E23RD STREET • P.O.BOX53127 • OKLAHOMACITY.OKLAHOMA73152-3127 

TELEPHONE: (405) 525-3556 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWD 

Executive Director 

Addreu Reply lo Headquarters Office 

MEMORANDUM 

October 11, 1990 

<&> _ # 

TO: 

FROM: 

State Oil and Gas Directors 

Jerry R. SimmonsnjAtSyf ; 

SUBJECT: Oil Reclamation Operations 

X 

4? 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to- meet the new TC rule are. the . oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

Not Known 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

Not Known 

3. Do you permit these operations? 

4. 

5. 

No 

What regulatory agency in your state has the responsibility 

for crude oi l reclamation operations? 

Alabama Depart, of Environ. Hc/trat. - ?or NPDES Discharge only 

What is the estimated volume of wastes created by reclaimers 

in your state? 

Not Knc./n 

MIMIC * STATES' ALABAMA . ALASKA . ARIZONA - ARKANSAS • CALIFORNIA . COLORAOO . ILLINOIS . INOIANA . KANSAS . KENTUCKY 

LOUISIANA • MARVLANO • MICHIOAN . MISSISSIPPI . MONTANA • NEBRASKA . NEVADA • NEW MEXICO . NEW YORK . NORTH OAKOTA . OHIO 

OKLAHOMA • PENNSYLVANIA . SOUTH OAKOTA • TEXAS . UTAH • VIRGINIA . WEST VIROINIA . WVOMINO 

ASSOCIATES. OEOROIA . IDAHO . NORTH CAROLINA • OREOON • SOUTH CAROLINA . WASHINOTON 
P.6 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

Not Known 

I 

Please respond to as many of the above questions as possible and

 N 

return to IOCC headquarters office by Friday, October 26.

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P.7 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

ARIZONA 
Jfr 

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INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N.E.23R0 STREET • P.O.BOX53127 • OKLAHOMACITY.OKLAHOMA73152-3127^. 

TELEPHONE: (405) 525-3550 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming MEMORANDUM 

Addreti Reply to Headquarter! Office 

w. TIMOTHY DOWO October 11, 1990 

Executive Director 

TO: State Oil and Gas Directors 

FROM: Jerry R. Simmons^^^/ 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste .streams required, to meet the. - new . ..TC rule are. the ..oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

T . 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

^ - _____ , _ _ c> 

3. Do you permit these operations? 

4. what regulatory/agency in your state has the responsibility 

for crude oil reclamation operations? 

5. What is the estimated volume of wastes created by reclaimers 

in your state? 

*'JMA^+*^ , 

. _ „ .«...,«..« -iLlfO.NI l . COLORADO • ILLINOIS • IN0IANA . KANSAS • KENTUCKY 

MEMBER STATES ALABAMA - ALASKA • ARIZONA • ARKANSAS • CALIFORNIA • WWK4U V 

MI-4JI44 "»' " "" " "*-** " „..„»«•, » ..vio i NEW MEXICO • NEW YORK . NORTH OAKOTA . OHIO 

LOUISIANA . MARYLAND . MICHIGAN . MISSISSIPPI • MONTANA . NEBRASKA • NEVAOA • NEW MUICI I 

OKLAHOMA • PENNSYLVANIA . SOUTH OAKOTA . TEXAS . UTAH . V.ROIN.A . WEST V.ROIN.A . WYOM.NO 

ASSOCIATES. OEORO.A . IDAHO . NORTH CAROL.NA . OREOON . SOUTH CAROLINA . WASH.NOTON 
P.9 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

Please, respond to as many of the above questions as possible and ^ 

return to IOCC headquarters office by Friday, October 26. T 

JRS:bjh 

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P.10 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

CALIFORNIA 
10/29/30 10:39 

r > ". . 

STATE Of CAUFOUNIA—t*M6 tESOUKCU AGENCY 

DEPARTMENT Of CONSERVATION 

DIVISION OF OIL AND GAS 

1416 9th STREET. ROOM 1310 

SACRAMENTO, CALIFORNIA 95614 

(916)4454646 

TOD (91*) 324-2555 

TELEFAX (916) 323-0424 

NO.001 001 

CA 

GEORGE ttUKMEJIAN. ComiKy 

P.11 

DATE: /O-^l-fQ TIME: 9.VS~ A.M. P.M. 

Total number of pages (including cover sheet): 

TO Name; 

FROM Name: 

vJ& /v</ J ; „, „1 &vl S 

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~jSo to Ae. i dL, 

'r-Zi* 

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Division of Oil and Gas, Sacramento 

Telephone/ATSS No.: ( 9/6 ) 3-\3-/7?7 

Message: fru^> yC^. ^ AA**^/y\t~4#rv*+-*^ fe- ^y^-t^AS f<vj.a\ £'rt* A_W <L, . 

l*J*l, &AJL s**ZZ'<(l tMy*^CJ*-y *TMrX*' 1*TM* <S^Jtf^*v'*-'&*'rr /Vt*<c\*L-~* jf**-1*frV-r? S . 

w Aty'A ffi; ^ '* ^ P -^ S* <*+- "* /{&r jP.~P Lc-i*^, i^iP 

Sfrb ^*~i l*M**\ /*L~ ^<**-4l7* #SVm*-~^4* 

We are transmitting on a 3M EMT 9165, If you encounter any 

difficulty during transmission, please call ^a,*4^/ 

at (916) 445-9686 or ATSS 485-S686, 

To reply by facsimile, use Telephone No. (916) 323-0424. 
10/29/90 10:3y' NU. 00 1 "002" 

P.12 

INTERSTATE OIL COMPACT COMMISSIO N 

HeADOUAftTenSOFPlCS: 90 0 N.E.23RD STREET * P.O.BOX33127 • OKLAHOMACITY.OKLAHOMA73152-3127^A: 

TELEPHONES (40S) $.S-3S$6 

MIKE SULLIVAN 

Chlirmtn 

Govtrrvor of Wyoming 

W. TIMOTHY OOWD 

btcurfva Dlrtttcr 

Mdrm Ktply ro Kttdquirlert Offkt 

MiMORAFPgM 

October ll , 1990 

TO: 

FROM: 

Stat e Oil and Gas Directors 

Jerr y R. si_u_ons_£^&/ 

SUBJECT: Oil Reclamation Ooe'ratlons 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicit y characteristi c (TC) rule went into effect. This new rul e 

require s testin g of certain wastes prior to disposal. One of the 

.waste streams required to., meet the . new. TC rul e are the .oi l 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarif y its 

position on the application of the TC rule , I would ask you to 

provide this offic e with any of the information contained in the 

following questionnaire . 

1. How many oi l reclaimers operate in your state ? 

Other t-han those using the exemptions under the Jan. 88 regulatory 

determination, probably only a few Transportable Treatnvent Units (TTO). 

2. How many barrels of crude oil do reclaimers sel l in your stat e 

annually or monthly? frfo data available. 

Most crude oil is reclaimed at the refinery site by ITU's or the refinery 

working under the Jan, 88 Regulatory determination by recycling on site. 

Do you permit thes e operations? 

Ihe Division of Oil and Gas has no authority for oil reclamation operations. 

What regulatory agency in your stat e has the responsibilit y 

for crude oi l reclamation operations? 

The California Department of Health Services. 

5. What is the estimated volume of wastes created by reclaimers 

in your state? 

3. 

4. 

MCMBCI STATE!. ALABAMA . ALASKA . AH I ION A . AftKANfA* . OALIfOdNCA - COLOBAOO . ILLINOIS . INOIANA . KAN3A1 . KENTUCKY 

.0UI1PAMA • MAI.YLAN0 • 4.10NIOAN • MIMtMIPPI • MONTANA • NiBHASKA • M«V*OA . N«W M*KieO • NIW »<3»K . NO»T>4 OAKOTA O..IQ 

OKLAHOMA - »fNN»¥LVANIA - aOutH DAKOTA . Tf»A» • U*A>« • «"*«11N!A . WM T vlfteiNl* . WYOMING 

A»soe:*Ttj. a«aa«>A • IOAMO . NBHTH IAHOLINA . WIW N • SOUTH CAKOLINA - WA»MINOTON 
xw cv ru no. •mj ISU.UUi -0*33-

P.13 

• / . » 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? Past practices were to send 

wastes to a landfill or the wastes were converted into fuels. The 

current practice is to recycle the wast on site. Wastes not recyclable 

are treated on site by TUTS. 

Please respond to as many of the above questions as possibl e and 

return to I0CC headquarters office by Friday, October 26. 

JRS:bjh 

cc: Governors and Official Representatives 

If you have any questions regarding this questionaire, please 

contact me at (916) 323-0423. Questions concerning crude oil 

reclamation operations .should be referred to Bill Staack at the 

Department of Health Services, phone no. (916) 322-6157. 

Sincerely, 

Marilu Habel 

Associate Oil and Gas Engineer 
P.14 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

COLORADO 
P.15 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERSOFFICE- 900 N.E.23RDSTREET • P.O.BOX53127 • • OKLAHOMACITY.OKLAHOMA73152-3127 

TELEPHONE: (405) 525-3556 _______________ _ 

MIKE SUUIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWD 

Executive Director 

TO: 

FROM: 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

State Oil and Gas Directors 

Jerry R. Simmonsv*^ 

Bens'* 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to- meet . the. new TC rule are the oil, 

reclaiming operations which were not part of the exemption in EPA's 

"1988 Regulatory"Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? _ ,_ : *\ 

L)SJ.<S-O,J_*IQ — FAir l-_.a*,t" ^ ar e \k&v^-k\iL£\\ 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

! "). to •_-.ro/? *jo O EL TA A X / AN U W1* O P* ~ZJDC ^ / M J 

3. Do you permit these operations? 

4. What regulatory agency in your state has the responsibility 

for crude oil- reclamation operations? 

Ph;'<; !<=> AroV SaAAre <&*<& J)^ current lavv> 

5. What is the estimated volume of wastes created by reclaimers 

in your state? " 

.

 Nio vcrOO -.J. • A .-

MIUII A STATIS: ALABAMA . ALASKA • ARIZONA . ARKANSAS • CALIFORNIA . COLORAOO . ILL!NOI» . :N0IANA . KANSAS . KENTUCKY 

L0UIS:A.N A . MARYLAND . MICHIGAN . MISS.--.-- . • MONTANA . NIBRASKA . NIVAOA • NIW MIXICO N«W YORK . NORTH OAKOTA . OHIO 

OKLAHOMA . PINNSVLVANIA . SOUTH 3AKOTA • TEXAS . JTAM . VIRGINIA - WCST VIRGINIA • WYOMING 

ASSOCIATES. GCOROIA • IDAHO • NORTH CAROLINA . 0RC0ON . SOUTH CAROLINA . WASHINGTON 
P.16 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal^ practices of the 

typical reclaimer in your state? 

htM-.t-.^o-' \I\V*T reclaimi-AC> ^per&T'^ s . 

Please respond to as many of the above questions as possible and

 N 

return to IOCC headquarters office by Friday /..October 26-.

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P.17 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

FLOMDA 
P.18 

STATE OF FLORIDA 

DEPARTMENT OF NATURAL RESOURCES 

Florida Geological Survey, 903 West Tennessee Street, Tallahassee, FL 32304-7795 

Phone: 904/488-4191 

October 22, 1990 

Mr. Jerry R. Simmons 

Interstate Oil Compact Commission 

P.O. Box 53127 

Oklahoma City, OK 73152-3127 

Dear Mr. Simmons: 

This letter is in reply to your memorandum of October 11, 1990, regarding 

oil reclamation operations. The subject memorandum is being forwarded to the 

following person who handles oil reclamation operations in the state of 

Florida: 

Ms. Betsy Galocy 

Coordinator, Used Oil Recycling 

Department of Environmental Regulation 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Sincerely, 

Ik) OSL^ _3^AJCI V 

Walter Schmidt, Ph.D. 

State Geologist and Chief 

Florida Geological Survey 

WS/ctr 

cc: Ms. Betsy Galocy 

Tom Gardner 

Executive Director 

Administration Beaches and Shores Law Enforcement Marine Resources Recreation and Parks Resource Management State Lands 

Bob Martinet Jim Smith Bob Butterworth Gerald Lewis Tom Gallagher Doyle Conner Betty Castor 

Governor Secreury of State Attorney General SuieCompooller Suie Treasurer Com mijuoner of Agriculture Commjuioner of Education 
P.19 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

INDIANA 
P.20 

/M 

INDIANA DEPARTMENT OF NATURAL RESOURCES 

Divisio n of Oi l and Gas 

Old Trails Building , Suit e 601 

309 West Washington Stree t 

Indianapolis, Indian a 46204 

(317) 232-4055 

PATRICK R. RALSTON, DIRECTOR 

Octobe r 16, 1990 

Mr. Jerr y R. Simmons 

Interstat e Oil Compact Commission 

P.O. Box 53127 

Oklahoma City, OK 73152-3127 

Dear Jerry: 

I am returning your questionnaire regarding the toxicity 

characteristic rule being enforced by the EPA. Unfortunately, 

there is very little information I could provide you on this 

subject. 

If you need the Department of Environmental Management's responses 

to these questions, I will be glad to forward them a copy of the 

questionnaire. Give me a call at (317) 232-4055 and I will hold a 

copy until I hear back from you. 

Sincerely, 

Gax^Mj Fricke 

Director of Oil and Gas 

GMF:lch 

Enclosure: 

"EQUAL OPPORTUNITY EMPLOYER" 

© 
<— 

P.21 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N.E.23RD STREET • P.O.BOX53127 • OKLAHOMACITY.OKLAHOMA73152-3127 fa{ 

TELEPHONE: (405) 525-3556 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWD 

Executive Director 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

TO: State Oil and Gas Directors 

FROM: Jerry R. Simmcns^^*,^ 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

.waste streams required to. meet the . new .TC rule are the. oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

Do you permit these operations? 

No 

What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

Indiana Department of Environmental Management 

5. What is the estimated volume of wastes created by reclaimers 

in your state? 

MEMBER STATES ALABAMA . ALASKA . ARIZONA • ARKANSAS - CALIFORNIA • COLORADO . ILLINOI S • INDIANA . KANSAS • KENTUCKY 

LOUIS.AN A • MARYLANO • MICHIGA N • MISSISSIPPI • MONTAN A • NEBRASKA . NEVADA . NEW MEXICO . NEW YORK . NORTH DAKOTA . OHIO 

OKLAHOM A . PENNSYLVANIA • SOUT H DAKOTA • TEXAS . UTAH . VIRGINIA . WEST VIRGINI A . WYOMIN G 

ASSOCIATES. GEORGIA . IDAHO . NORT H CAROLINA • OREGON . SOUTH CAROLINA . WASHINGTON 
Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

I 

Please respond to as many of the above questions as possible and " 

return to IOCC headquarters office by Friday, October 26. _ 

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P.23 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

KANSAS 
TULL" LL!4Ub-b_b-iby_ 

jov 02,90 15=50 No.005 P.02 

P.24 

Mike Hoyden 

Governor 

Keith R. Henley 

Chairman 

Rich Kowalewski 

Commissioner 

Jack Shriver 

Commissioner 

Judith McConneil 

Executive Director 

Frank A. Caro Jr. 

General Counsel 

Conservation Division 

Shftri Feist Albrecht 

Director 

00 Colorado Derby Bldg. 

202 W. 1st Street 

Wichita, KS 67202-1286 

Telephone (S16) 269-3238 

Kansas Corporation Commission 

October 29, 1990 

Mr. Jerry Simmons 

Interstate Oil Compact Commission 

P.O. Box 53127 

Oklahoma City, OK 73152-3127 

Re: I0CC Oil 

Reclamation Survey 

Dear Jerry: 

Enclosed you will find the completed survey regarding the 

regulation of oil reclaimers in the state of Kansas. I 

apologize for missing the October 26 deadline. 

I received Jack Davidson's agenda for the Council of State 

Regulatory Officials Friday. I noticed that he's scheduled 

this topic for discussion in Phoenix. I will be interested in 

reviewing how other states approach regulation 1n this area. 

Please do not hesitate to contact me if you require 

further information. 

Sincerely, 

Sharl Feist Albrecht 

Director 

SFA:nao 

cc: Gary Hulett 

Governor's Office 
1ULL. 

^ P.25 

hL-4Ub-S-D-o^2 Nov U^,yu 15*51 NO .005 P.03 

-** 

4 ff 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N.E.23RD STREET • P.O.BOX53127 • QKLAHOMAClTY,OKLAHOMA73152-3127 

TELEPHONE: (405) 5W-3556 ..., 

Addreit Reply to Hetdquirteri Office 

MIKE SULLIVAN 

Chairman 

Governor at Wyoming 

MEMORANDUM 

w. TIMOTHY DOWD October 11, 1990 

Executive Director TO: State Oil and Gas Directors 

FROM: Jerry R. Simmons^ 

SUBJECT: Oil Reclamation Operations 

•"j^S^ 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to meet the new TC rule... are the oil. 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

Approximately 40. according to Kansas Department of Revenue. 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

Unknown. 

3. Do you permit these operations? 

No. 

4 . What regulatory agency in your stat e has the responsibilit y 

for crude oi l reclamation operations? 

No state agency regulates oil reclamation operations. However, the waste 

oil purchased by reclaimers must be reported to the Kansas Dept. of Revenue. 

5. what is the estimated volume of wastes created by reclaimers 

in your state? 

Unknown. 

f!f , f 1 o •jyyij 

MIMiS R STATES. ALABAMA . ALASKA • ARUON A • ARKAN6AB . CALIFORNIA . COLORADO . ILLINOI S • INDIANA • KANSAS - KENTUCK Y 

LOUISIANA . MARYLANO . MIC44IOAN - MIS»II«IPP I . MONTANA • NEBRASKA . NtVAD A . NEW MEXICO . NI W YORK • NORTH BAKOT A . OHI O 

OKLA44044A . PINNSYLVANl A • SOUT N OAKOTA • TtXA S • UTAH - VIROINI A . WEST VIROINI A . WYOMIN O 

ASSOCIATES. QEOROIA - IOA440 . NORTH CAROLINA • OREOON . SOUTH CAROLINA - WASHINGTO N 
_ P.26 

.__ • WJ-J^-^T O TCtrv-uzrgrj 15 :;bl No .005 P.04 

Memorandum 

October 11, 1990 

Page 2 

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P.27 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

LOUISIANA 
P.28 

BUDDY ROEMER 

GOVERNOR 

DEPARTMENT OF NATURAL RESOURCES 

RON GOMEZ 

SECRETARY 

J. PATRICK BATCHELOR 

COMMISSIONER AND 

ASSISTANT SECRETARY 

October 23, 1990 

Mr. Jerry Simmons 

Interstate Oil Compact Commission 

900 N.E. 23rd Street 

Post Office Box 53127 

Oklahoma City, Oklahoma 73152-3127 

RE: OIL RECLAMATION OPERATIONS 

Dear Mr. Simmons: 

Attached is the completed questionnaire submitted with your 

letter of October 11, 1990. The study covers activities of eleven 

(11) oil reclaimers that we regulate in the State, but does not 

include reclaimers involved in reclaiming oil from holds of 

seagoing vessels and barges that transport oil into Louisiana. 

Information on the numbers of such reclaimers and volumes involved 

are unknown and thus are not included in this questionnaire. 

If I can be of further assistance, please do not hesitate to 

contact me. 

Yours very truly, 

tfs^&M^-

J. Patrick Batchelor, Commissioner 

Office of Conservation 

JPB:kcm 

Attachment 

cc : John R. Aldridge 

Director, Engineering Division 

OFFICE OF CONSERVATION P.O. BOX 94273 BATON ROUGE, LOUISIANA 70804-9275 PHONE: (504) 342-5540 

AN EQUAL OPPORTUNITY EMPLOYER 
P.29 

INTERSTAT E OI L COMPAC T C 0 M M I 

HEADQUARTERS OFFICE: 900 N.E.23RD STREET • P.O.BOXS3127 . • OKLAHOMA CITY. OKLAFT 

DATE RECEIVED 

OFFICF OF CQNSERVA7 

/ ; i!> 

HUMA7-313^3)2r 

TELEPHONE; (405) 525-3556 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWD 

Executive Director 

TO: 

FROM: 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

Stat e Oil and Gas Directors 

Jerr y R. S immonsw/£^^/ 

A*M> 2: &*> 

Pi • '•;- foi 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to meet the new TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

rEleven (11)' 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

8,87-+/MONTH 

3 . 

4 . 

3 . 

Do you permi t thes e operations ? 

YES 

What regulator y agency i n your stat e ha s th e responsibilit y 

f o r crud e oi l reclamatio n operations ? 

Department of Natural Resources, Office of Conservation 

What is th e estimate d volume of waste s create d by reclaimers 

i n your state ? 

20,000 BBLS/MONTH 

MEHIE* STATES ALASAMA . ALASKA . ARIZONA • ARKANSAS • CALIFORNIA . COLORADO . ILLINOIS - INOIANA . KANSAS . KENTUCKY 

LOUIS.ANA . MARYLANO • MICHIGAN . MISSISSIPPI . MONTANA • NISRASKA . NEVAOA . NSW MEXICO . NEW YORK • NORTH OAKOTA . OHIO 

OKLAHOMA . PENNSYLVANIA . SOUTH OAKOTA • TEXAS • UTAH . VIRGINIA . WEST VIRGINIA . WYOMING 

ASSOCIATES. OEORGIA . IOAMO . NORTH CAROLINA . OREOON . SOUTH CAROLINA . WASHINGTON 
(• Memorandum 

October 11, 1990 

Page 2 

What are the past and current disposal practice s of the 

typica l reclaimer in your state? 

Commercial facility or on-site disposal well 

I 

Please respond to as many of the above questions as possible and

 N 

return to IOCC headquarters office by Friday, October 26.

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P.31 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

MARYLAND 
William Donald Schaefer 

Governor 

STATE OF MARYLAND 

Department of the Environment 

2500 BROENING HIGHWAY BALTIMORE. MARYLAND 21224 

(301) 631- " M Martin W. Wa.sn. Jr 

Secrerarv 

October 26, 1990 

Mr. Jerry R. Simmons 

Interstate Oil Compact Commission 

P.O. Box 53127 

Oklahoma City, Oklahoma 73152-3127 

Dear Mr. Simmons: 

Your questionnaire of October 11, 1990, sent to the Maryland 

Geological Survey has been referred to me for response. We have 

answered every question on the form. Please note that some of 

the questions are not pertinent to Maryland while others are 

beyond the scope of our program. 

If you desire additional information, please contact me at 

(301) 631-3324. 

Sincerely, 

i__ >/. W-^O*^ 

Yjames W. McDairmant, Head 

Oil Control Section 

JWM:rjm 

Enclosure 

cc: Mr. Ronald Nelson 

Mr. K.A. Schwarz 
P.33 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N.E.23RD STREET • P.O.BOX53127 • OKLAHOMACITY.OKLAHOMA 73152-3127 

TELEPHONE: (405) 525-3556 ^_ _ 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMCTHY OOWD 

Exscurivt Director 

AddrtM Rtply to Hcsdqutrteri Offics 

MEMORANDUM 

October 11, 1990 

TO: State Oil and Gas Directors 

FROM: Jerry R. Sinunons_£^^--

SUBJECT: Oil Reclamation Operations 

RECEIVED 

Oa 15 1990 

MD. GEOLOGICAL SURVEY 

QEE1CE OF THE DIRECTOR 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule< went into effect. This new rule 

requires testing of certain waste's prior to disposal. One of the 

.waste streams required to- meet the new TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

~7uso , 

2. 

3. 

4. 

How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

_k ~P£r OJC i S /1/6 ) 8OLT> J ns TV A_5 3~T# •> •_£-

Do you permit thes e operations? , 

U/iB-TdlUrT Oc QPtC^/T'>vnS - STcr2*Zr6 7J2*fvSTt2- ~Xhl.;^U-^f 

What regulatory agency in your stat e has the responsibilit y 

for crude oi l reclamation operations? 

What is the estimated volume of wastes created by reclaimers 

in your state ? 

M«vi,t* STATU ALASAMA . ALASKA • AHIZONA • ARKANSAS . CALIFORNIA . COLOHAOO . ILLINOIS • INOIANA . KANSAS • <«.NTJC«» 

LOL.S.ANA . MAHTLANC • MICHIOAN . MISSISSIPPI . MONTANA • NISRASXA . NSVAOA • NSW MtXICO • NSW YOKK' • MO«TS 3««0- ' 0»'O 

OKLAHOMA • -INNSYLVANIA . SOUTH OAKOTA • TIXAS • UTAH . VI«OINIA . WCST /!»OINIA . »»OKINS 

.ASSOCIATIS. UIOHOIA . iOAHO • NORTH CA«OL:NA • OftSOON . SOUTH CA«OL.NA • WASHINOTON 
P.34 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

/£/,<-/vjTd&T /£^->. U/jr&Tg- Fbe.Ou7-oi- -S7*r7j:J>wiF'yuS<r~r^ 

Please respond to as many of the above questions as possible and 

return to IOCC headquarters office by Friday, October 26. 

JRS:bjh 

cc: Governors and Official Representatives 
P.35 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

MICHIGAN 
P.36 

STATE OP MICHIGAN 

NATVMAL RESOimCES COMMISSION 

THOMAS J. ANDenSON 

MAMkfNf 4. rT.UHAf4.TY 

eontON c OUYCH 

aLV^OO^X^TTSON JAMES J. BLANCHARD, Goverw 

SAr^^ouP^ DEPARTMENT OF NATURAL RESOURCES 

STEVENS T. MASON OUH.OING 

r>0. BOX J00J8 

LANSING. UI 4(000 

DAVIS r. MALES. 0>restor 

October 29, 1990 

Mr. Jerry R. Simmons 

Interstate Oil Compact Commission 

P. 0. Box 53127 

Oklahoma City, Oklahoma 73152-3127 

Dear Mr. Simmons: 

We can provide the following answers in response to your October 11, 1990, 

letter and questionnaire concerning Oil Reclamation Operations. 

1. How many oil reclaimers operate in your state? 

There are fifteen companies in Michigan that process used oil without 

re-refining. There are currently no re-refining plants of used oil 

located in this state. There is a proposal to build a re-refinery 

plant in River Rouge in the future. 

2. How many barrels of crude oil do reclaimers sell in your state annually 

or monthly? 

About 7 million gallons per year of Michigan used oil is recycled. 

Approximately 58 percent 1s used as a fuel oil, 27 percent goes to 

refiners and the remainder is used for nonfuel industrial purposes, 

such as cutting and honing oils. We have no records of how much of 

the product is sold within Michigan. 

3. Do you permit these operations? 

There is recommended criteria for the processing of used oil in 

Michigan, but companies are presently not controlled by a formal 

permitting process. New legislation was signed into law on June 2, 1990, 

(the Used Motor Oil Act, 1990 PA 114) which 1s expected to establish 

a permitting process when administrative rules are promulgated. Under 

Michigan's Liquid Industrial Waste Act, 1969 PA 136, as amended, 

manifests are required for all waste oil transported by all haulers 

other than the generators of the oil. 

M026 

3/se 

ci 
P.37 

Mr. Jerry R. Simmons 

Page 2 

October 29, 1990 

4. What regulatory agency in your state has the responsibility for crude 

oil reclamation operations? 

The Waste Management Division of the Department of Natural Resources 

regulates the licensing of waste haulers. As procedures for Public 

Act 114 are addressed, 1t is expected that regulatory assignments will 

be given to Department Divisions, most likely Waste Management Division 

and Environmental Response Division, 

5. What is the estimated volume of wastes created by reclaimers in your 

state? 

Waste water and sludge, or an oil slurry are the typical waste products 

of the oil reclamation process. Volume of waste is dependent upon the 

amount and quality of incoming material. There are no good estimates 

of statewide generated wastes. 

Waste water generated from one of Michigan's used oil processors is 

nearly 20,000 gallons per day. Sludge from this plant is less than 

1% of the product, producing 50 to 100 cubic yards per year. Another 

Michigan company produces about 50,000 gallons per day of waste water. 

Sludge from this plant is about 250 gallons per day, based on a 

percentage of incoming material. 

Oil slurry from one Michglan plant is 5,000 gallons per day, with 

approximately 35,000 gallons per day of waste water. 

Volume containers, drums, or smaller disposable containers are used to 

transport source waste oil. In addition to processing byproducts, a 

small amount of solid waste is generated from the offices and 

laboratories associated with the reclamation plants. 

6. What are the past and current disposal practices of the typical 

reclaimer in your state? 

Waste water is pretreated and routed to a sewer system. Sludge is 

most often landfilled and 1s used as an additive in asphalt mix. Oil 

slurry goes to fuels blending and is incinerated. Drums at one plant 

are reconditioned. Disposable containers are landfilled. Solid 

waste from offices and labs 1s landfilled by way of the normal 

household and office solid waste stream. 

We hope this information will be helpful 1n your response to the Environmental 

Protection Agency on their new toxicity characteristic rule. If you have 
P.38 

Mr. Jerry R. Simmons 

Page 3 

October 29, 1990 

additional questions regarding waste oil in Michigan, please contact 

Ms. Kim Paksi of the Department of Natural Resources Waste Management 

Division, P. 0. Box 30028, Lansing, Michigan 48909, 517-373-7895. 

Sincerely, 

cc: Ms. Kim Paksi, DNR 

Mr. Rodger Whitener, DNR 

R. Thomas Segal 1 (j """ 

Assistant Supervisor of Wells 

and Chief 

Geological Survey Division 

517-334-6923 
P.39 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

MISSOURI 
P.40 

/rfis50iA.n 

INTERSTAT E OI L COMPAC T COMMISSIO N 

Ate 

HEADQUARTERS OFFICE: 900 N. E.23RD STREET • P.O.BOX53127 

TELEPHONE: (4051 525-3556 

OKLAHOMA CITY, OKLAHOMA73152-3127 A 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWO 

Executive Director 

TO: 

FROM: 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

State Oil and Gas Directors 

Jerry R. Simmons^^^ 

SUBJECT: Oil Reclamation Operations 

.-y 

DECEIVE 

OCT 1 < 1990 

M O

 °» * Gas Cow* 

J] 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to- meet the new TC rule are the. oil, 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

2. 

3. 

4. 

How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

Do you permit these operations? 

y<?s; certificate 

What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

T*»- UlVt^ion K EnysironY*enr*l Qsakh- Wz-sie, r*Aay\tx>*~i+nT trejrsm 

What is the estimated volume of wastes created by reclaimers 

in your state? 

MEMBER STATES: ALABAMA . ALASKA . ARIZONA • ARKANSAS . CALIFORNIA • COLORADO . ILLINOIS • iNOIANA . KANSAS . KENTUCKY 

LOUISIANA • MARYLANC • V4ICHIOAN . MISSISSIPPI • MONTANA - NEBRASKA . NEVADA . NSW MEXICO . NEW YORK . NORTH OAKOTA . OH.O 

OKLAHOMA • PENNSYLVANIA • SOUTH SAKOTA • TEXAS - UTAH . VIRGINIA . WEST VIROINIA . WYOMING 

ASSOCIATES. OEOROIA . IDAHO . NORTH CAROLINA . OREOON . SOUTH CAROLINA • WASHINOTON 
P.41 

« T 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

_Ii^c>»vierafrl 

Please respond to as many of the above questions as possible and 

return to IOCC headquarters office by Friday, October 26. 

JRS:bjh 

cc: Governors and Official Representatives 

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P.42 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

NEBRASKA 
P.43 

K/GT 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERSOFFICE: 900 N.E.23RD STREET • P.O.BOX53127 • OKLAHOMACITY.OKLAHOMA73152-3127 

TELEPHONE: (405) 525-3556 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWD 

Executive Director 

TO: 

FROM: 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

State Oil and Gas Directors 

Jerry R. Simmons^ 4lf 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to. meet the new TC rule are. the oil. 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

Os?*, 

2. 

4. 

5. 

How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

Vod>?> a* *t u*a. *b3. Do you permit these operations? 

7 ^ 

What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

(V// r* 6<fc3 G^yt^i. C <»?» P » ^»»/<r*/^>, 

What is the estimated volume of wastes created by reclaimers 

in your state? 

MEMBER STATES: ALABAMA . ALASKA • ARIZONA - ARKANSAS . CALIFORNI A • COLORADO • ILLINOIS • INDIANA . KANSAS - KENTUCK Y 

LOUISIAN A . MARYLAN C • MICHIGA N - MISSISSIPPI . MONTAN A . NEBRASKA . NEVADA . NEW MEXICO . NEW YORK . NORTH DAKOTA . OHI O 

OKLAHOM A • PENNSYLVANIA . SOUTH DAKOTA • TEXAS . UTAH . VIROIN1A . WEST VIRGINIA . WYOMIN G 

ASSOCIATES. OEOROIA • IDAHO • NORTH CAROLIN A • OREGON . SOUTH CAROLINA • WASHINGTON 
. i 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

Ug.f*w J,*>MAX, J ^j _4 s> *r-*<U~t~4J'u>gyres'r S^/rJf s 

4/T.* ^acr»tai ^ Jf$x-f <cS //-J-c^-cV^r I 

Please respond to as many of the above questions as possible and

 N 

return to IOCC headquarters office by Friday, October 26.

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P.45 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

NEVADA 
/ • 

v ' 1 

1' 

BOB MILLER. Goocrnor 

Administration (702)687-4*70 STATE OF NEVADA 

AirQaallty 687-5065 ^___^ 

Mining Regulation and Rrelamatlon 687-4670 _^3_?»_t_v 

Waste Management (702) 687-5872 _5»L*^?§_ i 

Water Permits and Compliance 

Water Quality Planning 

Wastewater Treatment Services 

DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES 

DIVISION OF ENVIRONMENTAL PROTECTION 

123 W. Nye Lane 

Carson City, Nevada 89710 

P.46 

687-4670 

687-4670 

687 5870 

MEMORANDUM 

October 25, 1990 

To: Jerry R. Simmons 

From: Tim Murphy -*~\ "'''' 

Subject: Oil reclaming questionnaire 

Attached is the information that you requested on the 

questionnaire. 

If there are any questions or you need additional information 

please do not hesitate to contact me at (702) 687-5872. 

Tim Murphy 

Environmental Specialist 

Capital Complex 

123 W. Nye Lane 

Carson City, Nevada 89710 
P.47 

/\o ^ ">T 

BOB MILLER 

Governor 

STATE OF NEVADA 

DEPARTMENT OF MINERALS 

400 W. King Street, Suite 106 

Carson City, Nevada 89710 

(702) 687-5050 

Fax (702) 687-3957 

rr Las Vegas Brancrt 

4220 S. Maryland Pkwy. 

Suite 304 

Las Vegas. Nevada 89 n 9 

(702) 486-7250 

Fax (702) 486-7252 

RUSSELL A. FIELDS • 

Execur/Ve Oirecfor 

MEMORANDU M 

RECEIVED 

October 16, 1990 OCT 18 1S£0 

To: Lew Dodgion 

From: Russ Fields 

Re: IOCC Survey - Oil Reclaimers 

ENVIRONMENTAL PROTECTION* 

Attached is a questionnaire sent by the Interstate Oil 

Compact Commission. We need your help on this one! 

Would you please direct this to the appropriate bureau 

within your division and ask that the response be sent directly 

to IOCC. They say the due date is October 26. I'd appreciate a 

copy.' 

Thanks 

RF:lc 

Enclosure 

wp\RF239 
\. 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N.E.23RD STREET • P.O. BOX53127 • OKLAHOMA CITY, OKLAHOMA 73152-3127 

TELEPHONE: (.105) 525-3556 flEQEIVF'T' 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMCTHY OOWD 

Executive Director 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

OCT 1 5 1990 

Dept. of Minerals 

TO: State Oil and Gas Directors 

FROM: Jerry R. Simmon^^^^/ 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required . to. meet the new TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

3. 

4. 

5. 

How many barrels of crude oi l do reclaimers sel l in your stat e 

annually or monthly? 

Unknown-Not a regulatory requirement to report 

Do you permit thes e operations?

 ; 

No, they are permitted(water pollution control)via local entities 

What regulatory agency in your stat e has the responsibilit y 

for crude oi l reclamation operations? 

None 

What is the estimated volume of wastes created by reclaimers 

in your state? 

Unknown 

"IMSCR STATU ALASAMA . ALASKA . ARIZONA • ARKANSAS . CALIFORNIA • COLORADO . ILLINOIS) ' INOIANA . 4ANSAS . <tNTJC*Y 

L'.SIANA . MARYLANC ' M'CHlOAN . MISSISSIRRI . MONTANA - N11RA3HA . NKVAOA • NtW MEXICO • NCW YORK . NORTH SAKOT A . OHIO ' 

OKLAHOMA • RfNNlYLVANIA • SOUTH DAKOTA • TCXAS . UTAH . VIRGINIA . WSST 7IR0INIA • WVOMINO 

ASSOCIATES. aiOROlA . IDAHO • NORTH CAROLINA • ORCOON • SOUTH CAROLINA • WASHINOTON 
P.49 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practice s of the 

typica l reclaimer in your state ? 

Reclaimed oil is taken to refineries in California, seperated H-0 is 

discharged via NPDES permits or to POTWS via industria l waste permits. 

Please respond to as many of the above questions as possible and 

return to IOCC headquarters office by Friday, October 26. 

JRS:bjh 

cc: Governors and Official Representatives 
P.50 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

NEW MEXICO 
P.51 

INTERSTAT E OI L COMPAC T COM M PS SloO Um 

OKLAHO^^J^g^OMA73^ 5 2 g 1 HEADQUARTERS OFFICE: 900 N.E.23RD STREET • P.0.B0X53127 • 

TELEPHONE: (405) 525-3556 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY OOWD 

Executive Oirector 

TO: 

FROM: 

SUBJECT: 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

State Oil and Gas Directors 

Jerry R. Simmons^^^ 

Oil Reclamation Operations 

t) 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to meet the new TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

n 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

flv& ji OOO 38L///Ii 

3. 

4. 

Do you permit these operations? 

j'sS C cZcpy ct- KULSS GVCL-CSG.OJ 

What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

OIL. (2c.i5g./ZVr<hrJOK) yLS/U/3/d AJ 

5. What is the estimated volume of wastes created by reclaimers 

in your state? 

A v! £ S3o a S8i./n WO 

MCMICR STATtS ALABAMA . ALASKA . ARIZONA . ARKANSAS . CALIFORNIA • COLORADO • ILLINOIS • INOIANA . KANSAS . KtNTUCKY 

LOUISIANA . MARYLANO . MICHIGAN . MISSISSIRH . MONTANA • NEBRASKA . NCVAOA • NSW MEXICO • NIW YORK . NORTH OAKOTA . OHIO 

OKLAHOMA • PENNSYLVANIA . SOUTH OAKOTA • TEXAS . UTAH . VIRGINIA . WCST VIRGINIA . WVOMINO 

ASSOCIATES. GEORGIA . IDAHO • NORTH CAROLINA • ORtOON . SOUTH CAROLINA - WASHINGTON 
Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practice s of the 

typica l reclaimer in your state? 

2)/3POS#L. &T OCD paje/n/rrso DISPOSAL, r~/p-o/i./ry 

Cfi/jSs JJ ivS.i.L. &rZ- Su*.*&cliC Z)/3POS#L, /=*t-c.Ji-/ry) 

Please respond to as many of the above questions as possible and 

return to IOCC headquarters office by Friday, October 26. 

JRS:bjh 

cc: Governors and Official Representatives ^ 

(Rasp****. ^^J l h &%efi flodv,£*v, tifltcxb 
P.53 

Form C-117-A such authorization is automatically revoked. However, the District Supervisor may 

approve one ten (10) day extension for good cause shown. 

(d) Any operator, contractor, or party, other than a treating plant operator, who 

cleans any tank of sediment oil and removes sediment oil from any lease shall file Form C-117-B 

(Monthly Sediment Oil Disposal Statement) setting out all information required thereon. 

(e) A representative sample of sediment oil from any source shall be tested in a manner 

designed to accurately estimate the percentage of good oil expected to be recovered therefrom. 

Such test shall be performed prior to transport and prior to commingling with sediment oil from 

other leases or sources and the results recorded on the appropriate Form C-117-A. 

The Division recommends the standard centrifugal tests prescribed by API Manual of PetroleuMeasurement Standards, Chapter 10, Section 4. Other test procedures may be used if such 

procedures reliably predict the percentage of good oil to be recovered from sediment oil. 

(f) All sediment oil removed from storage shall be reported on Form C-115 (Operator's 

Monthly Report) together with the Form C-117-A (Tank Cleaning, Sediment Oil Removal, 

Transportation of Miscellaneous Hydrocarbons and Disposal Permit) permit number. 

(g) "Miscellaneous Hydrocarbons" are defined as tank bottoms occurring at pipeline 

stations, crude oil storage terminals, or refineries, pipeline break oil, catchings collected in 

traps, drips, or scrubbers by operators of gasoline plants in such plants or in the gathering 

lines serving such plants, the catchings collected in private, community, or commercial salt water 

disposal systems, or any other liquid hydrocarbon which is not lease crude or condensate. 

(h) Except in case of emergency, no miscellaneous hydrocarbons shall be delivered to a 

treating plant or other facility until Division approval is obtained on Form C-117-A (Tank 

Cleaning, Sediment Oil Removal, Transportation of Miscellaneous Hydrocarbons and Disposal Permit). 

Whenever an emergency exists which requires delivery of miscellaneous hydrocarbons to a 

treating plant or other facilities prior to approval of Form C-117-A, the transporter of such 

hydrocarbons shall notify the supervisor of the appropriate Division district office of the nature 

and extent of such emergency on the first working day following the emergency and shall file Form 

C-117-A within two working days following the emergency. For prolonged emergencies, the district 

supervisor may authorize the extended movement of miscellaneous hydrocarbons to a treating plant 

or other facilities during the period of the emergency and shall approve a Form C-117-A filed 

subsequent to the conclusion of such emergency covering the entire volume of miscellaneous 

hydrocarbons transported. 

RULE 312. TREATING PLANTS 

No treating plant shall operate except in conformity with the following provisions: 

(a) Prior to the construction of a treating plant, application in the form of an 

affidavit for treating plant permit shall be filed in duplicate with the S._ita Fe Office 

of the Division and one copy to the appropriate district office. Such application shall 

be accompanied by: 

(1) a plat showing the location of the plant in relation to 

governmental surveys (section, township and range) and to 

highways or roads giving access to the plant site; 

E-ll 
P.54 

(2) a description of the plant, type and process of treatment 

and design capacity; 

(3) a diagrammatic plan of plant layout including location of 

water wells, pits, dikes, dwellings, fences and cattle-guards 

within 1/4 mile of the site; 

(4) a description of containment dikes and pits, if any, 

with detailed information on construction and lining; 

(Note: any pits, lined pits or below grade tanks used at the 

site must meet Division requirements for ground water protection); 

(5) a demonstration that any unmerchantable solids or liquids 

resulting from operation of the facility will be disposed of at 

a Division approved site; 

(6) a demonstration that the notice requirements of Paragraph (b) 

of this rule have been met. 

(b) The applicant shall give written notice to the owners of the surface of the 

plant site and an area within one-half (1/2) mile. The applicant shall also give 

notice of his application by advertisement in a paper of general circulation published 

in the county in which the treating plant Is to be located. Both the written notice and 

published notice shall state the name of the plant operator, the nature of the proposed 

operation, the design capacity, and that any person seeking to oppose such application 

must file a protest with the Division within 20 days of the date of the notice. 

(c) Before commencing construction all treating plants shall have a surety or cash bond 

in the amount of $25,000, in a form approved by the Division, conditioned upon compliance 

with statutes of the State of New Mexico and rules of the Division, and satisfactory clean-up 

of site upon cessation of operation, in accordance with Part (i) of this Rule. If a bond has 

been secured for a commercial surface waste disposal facility permit at the location, that 

bond shall be sufficient for the treating plant portion of the facility, providing they are 

contiguous. If an adequate bond is posted by the applicant with a federal or state agency 

and the bond otherwise fulfills the requirements of this rule, the Division may consider the 

bond as satisfying the requirement of this rule. The applicant must notify the Division of 

any material change affecting the bond filed for the site and must, in any case, report the 

status of their bond annually to the Division; 

(d) The Director of the Division may issue a treating plant permit upon a finding 

that a complete and proper application has been filed and that no party has objected within 

20 days following submittal of the application. 

The permit shall be consistent with the application and appropriate requirements of 

Division rules and The Oil and Gas Act. 

The Director of the Division may set any application for a treating plant permit for 

public hearing. 

(e) Such permit shall entitle the treating plant operator to an approved Form C-104, 

Request for Allowable and Authorization to Transport Oil and Natural Gas, for the total 

amount of products secured from sediment oils and miscellaneous hydrocarbons processed by 

E-12 
P.55 

the operator. All permits shall be revocable, after notice and hearing, upon showing of 

good cause and are transferable only upon written approval of the Division Director. 

(f) No treating plant operator may accept sediment oil at or into the treating 

facility unless the same is accompanied by an approved Form C-117-A (Tank Cleaning, 

Sediment Oil Removal, Transportation of Miscellaneous Hydrocarbons and Disposal Permit). 

(g) Except as provided under Rule 311(h), no treating plant operator may accept 

tank bottoms from pipeline stations, crude oil storage terminals or refineries, pipeline 

break oil or other miscellaneous hydrocarbons for processing or mixing with recovered 

pipeline oil unless the same is accompanied by an approved Form C-117-A. 

(h) All treating plant operators shall file a monthly report which shall detail 

the net oil recovered and sold during the preceding month. See Rule 1118. 

The operator of each lease from which sediment oil is removed for reclamation shall 

be promptly notified by the treating plant operator of the amount of pipeline oil 

recovered therefrom. In the event sediment oil from two or more separate leases is to 

be commingled prior to treating, the treating plant operator shall determine the amount of 

pipeline oil attributable to each lease by testing a representative sample of the 

sediment oil from said lease in accordance with the standard centrifugal test prescribed by 

the API Manual of Petroleum Measurement Standards, Chapter 10, Section 4. Other test 

procedures may be used if such procedures reliably predict the percentage of good oil to 

be recovered from sediment oil. 

(1) To protect migratory birds, all tanks exceeding 16 feet in diameter, and exposed 

pits and ponds shall be screened, netted or covered. Upon written application by the 

operator, an exception to screening, netting or covering of a facility may be granted by the 

district supervisor upon a showing that an alternative method will protect migratory birds or 

that the facility is not hazardous to migratory birds. 

(j) Upon cessation of treating plant operations for 6 consecutive months, the 

operator will complete cleanup and restoration of the facility site within 6 months, 

unless an extension of time Is granted by the Director of the Division. Such cleanup 

shall be in accordance with a plan acceptable to the Division Director and may include 

removal or demolition of buildings, removal of all tanks, vessels, equipment or 

hardware, containment and removal of fluids and chemicals, back-filling and grading of 

pits, removal of contaminated soil, and reclamation of the general plant site area. Prior 

to release of the bond covering the plant, a representative of the Division will inspect 

the site to determine that restoration is adequate. 

(k) The Director of the Division may suspend any treating plant permit when it appears 

that such suspension is necessary to prevent waste, to protect fresh water, or to assure 

compliance with Division rules or orders. 

RULE 313. EMULSION, BASIC SEDIMENTS, AND TANK BOTTOMS 

Wells producing oil shall be operated in such a manner as will reduce as much as practicable 

the formation of emulsion and basic sediments. These substances and tank bottoms shall not be 

allowed to pollute fresh waters or cause surface damage. If tank bottoms are removed to surface 

pits, the pits shall be fenced and the fence shall be kept in good repair. To protect migratory 

birds, all tanks exceeding 16 feet in diameter, and exposed pits and ponds shall be screened, 

E-13 
P.56 

<* 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

NEW YORK 
0CT-31-199B 10*13 FROM TO 

P.57 

P. 02 

HY 

New York State Department of Environmental Conservation 

Division of Mineral Resources • Room 202 

50 Wolf Road, Albany, Now York 12233-6500 

Telephone: (518)457-3682 

Thomas C. Jorling 

Commlsslonsr 

October 30,1990 

Mr. Jerry R. Simmons 

IOCC 

P.O. Box 53127 

Oklahoma City, OK 73152 

Re: Oil Reclamation Operations 

Dear Jerry: 

Your request of October 11 asked for information on oil reclamation operations within 

New York State. To the best of my knowledge no crude oil reclaimers operate within New York. 

New York does, however, regulate waste ofl facilities and the transportation of waste oil. 

If a crude oil reclamation operation were to locate in New York the following divisions of this 

agency would review the proposed operation. 

D__3_-Q 

Solid Waste 

Air 

Hazardous Substance Regulation 

Water 

waste facility 

waste facility 

waste transport 

bulk storage 

Approximately 15 facilities are currently permitted to store or reprocess .waste oil within 

New York. No volumes of waste generated are available at this time. 

Please call if you have a question about this response. 

Sincerely yours, 

Sandra F. Brennan 

Director 

Bureau of Oil and Gas Regulation 

'-#--
P.58 

iUt.C i _ L * - U'".' ~ z> _ *5 - 3 J ' j . Oct 15.-" j 9 .04 No.002 P. 05 

INTERSTATE OIL COMPAC T COMMISSIO N 

HEAOQUARTeRSOfFlce: 900 N.e.23RD STREET • P.0.80X53127 • 

TBLtPHONI, (403) 525-U54 

OKLAHOMACITY, OKLAHOMA **3152-3127 

MIKI SULLIVAN 

Chairman 

Oovsrnor of Wyoming 

W. TIMOTHY OOWO 

ExtKutlvt Dlrsctor 

AddftM Fttply to H»»dquiM»r» Offlcs 

MEMORANDUM 

October 11, 1990 

State Oil and Gas Directors 

Jerry R. Simmons 

TO; 

FROM: 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule wont into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the' 

waste streams required to meet the hew TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

Do you permit these operations? 

4. What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

What is the estimated volume of wastes created by reclaimers 

in your state? 

MtMSl R STATIS ALAIAMA . ALAS KA . ARISONA . ARKANSAS . CALIFORNIA . COLORADO . ILLINOIS . INOIANA . KANSAS . KSNTUOIV 

LOUISIANA . MARYLAND . M.CMISAN . .NIMIMIPP I • MONTANA . NtSRASKA • NSVAOA . NIW MCXtCO • NSW YORK . NORTH BAKOTA . OHIO 

OKLAHOMA . RfNNSVLVANIA . SOUTH DAKOTA . TCKAS . UTAH . VIROINIA . WS.ST VIROINIA . WVOMINO 

ASSOCUTSSl OSOROIA • IOAHO • NORTH CAROLINA • ORIOON • SOUTH CAROLINA • WASHINGTON 
Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

Please respond to as £55 '"%% ^«.V ^

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cc: Governors and Official Representatives 

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P.60 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

NORTH CAROLINA 
P.61 

JP K- ^ 4 ^ <£*&/* NlCx 

INTERSTAT E OI L COMPAC T CO M MISSfe N 

73152-3T2 ' HEADQUARTERS OFFICE: 900 N.E.23RD STREET o P.O.BOX53127 o 

TELEPHONE: (405) 525-3556 

OKLAHOMA CITY. OKLAH' 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY 0OWD 

Executive Director 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

w Cf 

TO: State Oil and Gas Directors 

FROM: Jerry R. Sirnmons^^fv/ 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to- meet the new.. TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. * " ./ r 

1. How many oil reclaimers operate in your state? 

How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

Do you permit these operations? 

What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

What is the estimated volume of wastes created by reclaimers 

in your state? 

MEMBER STATES ALABAMA • ALASKA . ARIZONA . ARKANSAS • CALIFORNI A . COLORADO - ILLINOI S • INOIANA . KANSAS . KENTUCKY 

lOU-SIAN A . MARYLANO • MICHIGA N . MISSISSIPPI . MONTAN A • NEBRASKA - NEVADA - NEW MEXICO . NEW YORK . NORTH OAKOTA . OHI O 

OKLAHOM A • PENNSYLVANI A • SOUT H OAKOTA • TEXAS . UTAH . VIROINI A . WEST VIROINI A . WYOMIN G 

ASSOCIATES. GEORGIA • IDAHO • NORTH CAROLINA • OREGON . SOUT H CAROLIN A . WASHINGTO N 
J* «--

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

I 

Please respond to as many of the above questions as possible and

 N 

return to IOCC headquarters office by Friday, October 26.

 T 

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JRS:bjh

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cc: Governors and Official Representatives 

0 

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P.63 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

NORTH DAKOTA 
P.64 

/-rNORTH DAKOTA INDUSTRIAL COMMISSION 

Wesley U Norton 

CHIEF ENFORCEMENTOFFKER 

F E.Wilborn 

DEPUTY ENFORCEMENT OFFICER 

Clarence G Carlson 

GEOLOGIST 

o IL AND GAS DIVISIO N 

MD 

Charles Koch 

ENGINEERING DEPT 

Doren Dannewitz 

FIELD SUPERVISOR 

Glenn Wollan 

RECLAMATION SUP. 

October 23, 1990 

Mr. Jerry Simmons 

Interstate Oil Compact Commission 

P.O. Box 53127 

Oklahoma City, OK 73152-3127 

Dear Mr. Simmons: 

RE: Oil Reclamation Operations 

The following information is in response to the questionnaire regarding 

oil reclamation operations. 

1. There are two oil reclaiming operations in North Dakota. 

2. Approximately 13,000 barrels of crude was sold from the two oil 

reclaimers in 1989. 

3. These reclaiming operations are permitted, on a case by case basis, 

by order of the North Dakota Industrial Commission after proper 

notice and hearing. 

4. The Oil and Gas Division, North Dakota Industrial Commission, is 

the regulatory agency in North Dakota that is responsible for crude 

oil reclamation operations. 

5. Based on the first seven months of 1990, the two oil reclaimers in 

North Dakota create, as a waste stream, approximately 800 barrels 

of residual crude and 1200 barrels of water per year. 

6. Of the two oil reclaiming plants in our state, one plant sells its 

residual waste crude as road oil. The second reclaiming plant has 

recently installed a filter press system to process oil. The waste 

filtrate from the filter press is a dry-hard-residue which is 

• i »Sf BOULEVARD. BISMARCK NORTH DAKOTA 58505 PHONE (701) 224-2969 FAX (701) 224-3682 
P.65 

Mr. Simmons 

Page 2 

October 23, 1990 

hauled to an approved disposal site. This filter system 

substantially reduces the amount of generated waste. Before the 

filter system was installed, residual waste crude (liquid) was 

hauled to an approved disposal site. 

If you have any other questions regarding oil reclamation operations in 

our state, feel free to contact me. 

Sincerely, 

2,kLfi#^ 

Wesley w. Norton 

Chief Enforcement Officer 

WDN/th 
P.66 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

OKLAHOMA 
TEL: 405-525-359: Nov 05,90 

' — — '"-'• — l_ W _'_J . >J._I — w' 

12:35 No .006 P.02 

«i_u rvc 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N.E.23RD STREET • P.O.BOX53187 • 

TfUPHONE: (405) Hi.at 

OKLAHOMACITY. OKLAHOMA 73162-31 »7 

MIKt SUUIVAN 

Chiirnwn 

Qovttnot at Wyoming 

W. TIMOTHY DOWD 

Ixtcv'lv* Director 

TO: 

PROM: 

Addr«ii Kiply te Httdqulrttn O'liee 

MEMORANDUM 

October li, 1990 

State Oil and Gas Directors 

Jerry R. Simmon•^-S^ s / 

^ OCT 12 W> 

OFF»C€ OF 

DEPUTY DIR6CT0R 

O&QC0 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicit y characteristi c (TC) rule went into effect. This new rule 

requires testing of certai n wastes prior to disposal. One of the 

waste streams required t o meet the new TC rule are the oi l ... 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide th e EPA with information t o clarif y it s 

position on th t application of the TC rule , I would ask you t o 

provide thia offic e with any of the information contained in the 

following questionnaire. 

1. How many oi l reclaimers operate in your state? 

137 licensed.reclaimer** __ _ 

2. How many barrels of crude oi l do reclaimers eel l in your stat e 

annually or monthly? 

1,680,000 barrels annua]]y or 140,000 barrels monthly (estimate) 

3. Do you permit these operations? No. The Cross Production Section 

of the Oklahoma Tax Commission has permitting authority. Contact Patrick Boggs 

at UQS) 521-3233 for_permitting information. 

4. What regulatory agency in your stat e has the responsibilit y 

for crude oi l reclamation operations? Gross Production Section 

of the Oklahoma Tax Commission and the Oil & Gas Conservation Division of the 

Oklahoma Corporation Commission. 

5. What is the estimated volume of wastes create d by reclaimers 

in your state ? 

Unknown at this time. 

WtMICO. »T»T«| .Lit*" . • ALASKA • AU'lONA . »«KAMA» • CAtl'ORN'A . COLORADO • l«,llNO'l . INDIA** • KA44»A§ . »*KTJCKV 

LOUI#;A« « . -AOH.4N0 . MICMIHA N . »iifSi66i«>ei . MONTAN A . NCt(U»*A . mv»C 4 . NEW Mine t • MCw vo»K . NORT H OA*OT A . o-. o 

0"<LA4«>MA • "JNMaYLVANIA . *OUTk4 OAHOfA . tCXAf . UTA44 . <l*aihl« • 4Vt«T (l*tiM 4 . *VOMINO 

AtlOeiATIt 91QXIIIA . IDAHO . NOAT44 CAROLINA . ORISON • •OUT4< CAROLINA • WAtHINOTO* 
P.68 

^ i I _M4(jbrbf:b-^by2 „ .1°

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 __.

9 ( L^ * 2 :35 N°-*-°°t_. p • °3 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? ?h* saltwater is disposed of in 

a class II well, which the Oil & Gas Conservation Division has jurisdiction. 

Any botton sediment or waete is usually applied to lease or county roads 

with coordinating and permitting efforts conducted by the OCC, as.well as 

the Ccunty Commissioners in the specific county of where the waste is to be appl: 

Please respond to as many of the above questions as possible and 

return to IOCC headquarters office by Friday, October 26. 

jRS:bjh 

cc: Governors and Official Representatives 

y<,cK Connor -70 - ^ -
P.69 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

PENNSYLVANIA 
XX ?A 

PENNSYLVANIA 

COMMONWEALTH OF PENNSYLVANIA 

DEPARTMENT OF ENVIRONMENTAL RESOURCES 

Post Office Box 2357 

Harrisburg, Pennsylvania 17120 

Bureau of Oil & Gas Management 

October 16, 1990 

717-787-4817 

Mr. Jerry R. Simmons 

Interstate Oil Compact Commission 

P.O. Box 53127 

Oklahoma City, OK 73152-3127 

Dear Jerry: 

I'd like to take this opportunity to respond to your 

recent questionnaire regarding oil reclamation operations. I 

will respond to your questions in the order in which they 

appeared in your letter. 

1. How many oil reclaimers operate in your state? 

I am not aware of any crude oil reclaimers from 

production or separation operations. Tank bottoms and similar 

wastes from oil separation are generally disposed of on site. 

2. How many barrels of crude oil do reclaimers sell in your 

stats annually or monthly? 

As explained in item 1, above, I am not aware of any. 

3. Do you permit these operations? 

We regulate the on site disposal operations of these 

types of wastes by regulation, but do not nave oil reclaimers of 

the nature described in Pennsylvania. 

4. What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

The Department of Environmental Resources has regulatory 

authority over such operations if they were to exist. On site 

disposal of these wastes is currently regulated, as is the 

reclamation of used motor oils. 
P.71 

TT 

5. What is the estimated volume of wastes created by reclaimers 

in your state? 

None. 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

Not applicable. 

I hope the foregoing will help you in your survey. If 

you have any questions or need clarification on any of the 

issues, please call. 

i James E. Erb 

Director 
P.72 

P 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

SOUTH CAROLINA 
P.73 

P 

S^ 

g>tate nf ^nutli (Earnlina 

Office of tlje (Etaumuir 

CABROU A. CAMPBELL. JR. °FFIC 6 ° F E«CU nvE 

GOVERNOR POUCV ANO PROGRAMS 

October 24, 1990 

Mr. Jerry R. Simmons 

Interstate Oil Compact Commission 

Post Office Box 53127 

Oklahoma City, Oklahoma 73152-3127 

Dear Mr. Simmons: 

Attached you will find the completed questionnaire regarding 

South Carolina's oil reclaiming operations. 

Please do not hesitate to contact Mr. John Zemp at (803) 734-0331 

should you have any further questions regarding this matter. 

Sincerely, 

Mary Spencer^ 

Deputy Director 

Energy Programs 

/nip 
P.74 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N. E.23RD STREET • P.O.BOX53127 • OKLAHOMACITY.OKLAHOMA73152-3127^ 

TELEPHONE: (405) S2S-3SSA 

I*' 

V, 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWO 

Executive Director 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

TO: State Oil and Gas Directors 

FROM: Jerry R. Simmons^^^r 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste .streams required to., meet the new TC rule are ..the oil. 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

2 . How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

O/o fc (MOuJfO 

Do you permit these operations? 

AMmiiA/kWrX, 

What" regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

e^> *** /LeJL^utJl^ 

5. What is the estimated volume of wastes created by reclaimers 

in your state? 

UU(C/IMOA^) <p~t~c£ w ^ /rrfl HJtu. Je-6atfJ /2st- IAJ2S%C 

MEMBER STATES: ALABAMA . ALASKA • ARIZONA • ARKANSAS • CALIFORNIA • COLORADO • ILLINOI S • INOIANA • KANSAS • KENTUCK Y 

LOUISIAN A . MARYLAND • MICHIOA N . MISSISSIPPI • MONTAN A - NEBRASKA . NEVADA - NEW MEXICO - NEW YORK . NORT H OAKOTA . OHIO 

OKLAHOM A • PENNSYLVANI A • SOUTH OAKOTA . TEXAS . UTAH . VIROINI A - WEST VIROINI A . WYOMIN O 

ASSOCIATES. GEORGIA . IDAHO . NORT H CAROLINA • ORCOON . SOUTH CAROLINA . WASHINGTO N 
P.75 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

AAT *&^£*^£, /2T <&L+*~*Jlrt. cocCZz*. cdJ( sUfr^U&ify <aytee& J& £/'flier | 

Please respond to as many of the above questions as possible and

 N 

return to IOCC headquarters office by Friday, October 26.

 T 

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cc: Governors and Official Representatives

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P.76 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

SOUTH DAKOTA 
•f^BwWSp 

w 

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P.77 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERSOFFICE: 900N.E.23RDSTREET • P.O.BOX53127 • OKLAHOMACITY,OKLAHOMA73152-3127 

TELEPHONE: M05) 525-3556 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWO 

Executive Oirector 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

TO: State Oil and Gas Directors 

FROM: Jerry R. Simmons^^^^/ 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

.waste streams required to meet the new.. TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. 

2. 

How many oi 

None 

1 reclaimers operate in your state? 

How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

N/A 

3. Do you permit these operations? 

No permits issued 

What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

DWNR - if there were any 

5. What is the estimated volume of wastes created by reclaimers 

in your state? 

N/A 

.MEMBER STATES: ALABAMA . ALASKA . ARIZONA • ARKANSAS . CALIFORNIA . COLORADO . ILLINOIS • ^NOIANA . KANSAS . KENTUCKY 

LOUISIANA . MAAVLANO • MICHIGAN . MISSISSIPPI . MONTANA - NEBRASKA • NEVADA • NEW MEXICO . NEW YORK • NORTH OAKOTA . OHIO 

OKLAHOMA • PENNSYLVANIA . SOUTH OAKOTA - TEXAS . UTAH . VIROINIA - WEST VIROINIA . WYOMINO 

ASSOCIATES. SEOROIA . IDAHO . NORTH CAROLINA • OREOON • SOUTH CAROLINA • WASHINGTON 
Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

N/A 

Please respond to as many of the above questions as possible and 

return to IOCC headquarters office by Friday, October 26. 

JRS:bjh 

cc: Governors and Official Representatives 

Fred V. Steece, Supervisor 

Oil and Gas Program 

SD Department of Water and Natural Resources 

36 East Chicago 

Rapid City, SD 57701 

Completed October 19, 1990 by 

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P.79 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

TENNESSEE 
P.80 

} 

/• 

-r/0 

DIVISION OF GEOLOGY / STATE OIL AND GAS BOARD 

701 BROADWAY, ROOM B30 

TENNESSEE DEPARTMENT OF CONSERVATION 

NASHVILLE, TENNESSEE 37243-0445 

(615)742-6689 

October 25, 1990 

Jerry R. Simmons 

Interstat e Oil Compact Commission 

P.O.Box 53127 

Re: Oil Reclamation Operations In Tennessee 

Dear Mr. Simmons: 

I am responding to your letter of October 11/ 1990/ regarding the 

above. In response to the questionnaire contained in that letter/ I 

Offer the following. 

1. According to the University of Tennessee Center For Industrial 

Services, approximately 33 oil reclaimers were operating in Tennessee 

as of ©ctober, 1990. 

2. No information is available on the volume of crude oil sold by 

reclaimers in Tennessee. 

3. These operations are not specifically permitted in Tennessee/ although 

they must be registered with EPA/ unless they are already operating under 

some other program such as RCRA. 

4. No regulatory agency in Tennessee has been specifically designated to 

be responsible for crude oil reclamation operations. 

5. With no specific regulatory control, we have no way of estimating the 

volume of wastes created by reclaimers in Tennessee. 

6. We have no information about the past and current disposal practices 

of the typical reclaimer in Tennessee. 

I regret that we do not have more information to share with you in 

regard to these operations. Part of the reason for so little regulatory 

control may be that there is presently very little of this type of activity in Tennessee/ due to the relatively poor economics that have resulted 

from low crude oil prices in recent years. 
P.81 

> v 

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Page 2 

I'm sorry for the delay in getting this information to you/ but 

your letter only came across my desk a couple of days ago. 

Sincerely/ 

Ronald P. Zurawski 

Assistant Supervisor 

gm 
"-Ii 

P.82 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

TEXAS 
P.83 

RAILROAD COMMISSION OF TEXAS 

OIL AND GAS DIVISION 

KENT HANCE, Ch»lrm»n 

JOHN SHARP, Commiuioner 

JAMC8 E. QIM) NUGENT, Commiiftoner 

TX 

DAVID M. OARUCK 

Interim Director 

JAMES W.WALKER, JR. 

Director, 

Production Allocation 

(512) 463-6638 

1701 N.CONCtt ESS CAPITOL STATION - P. O. DRAWER 1Z967 AUSnN, TEXAS 7871U2967 

MEMORANDU M 

TO: 

FROM: 

DATE: 

SUBJECT: 

Jerry Mullican, Director 

UIC 

Richard Buerger, Assistant Director 

Production Allocation 

September 14, 1990 

Reclamation Reports, Form R-2 

As per your request we have audited the June, 1990 reports of 38 Reclamation Plants for receipt 

of material and deliveries of net oil 

We show that the total receipt at all facilities was 58,992 barrels of material which includes BS&W 

and ofl. Of this treated amount plus any stock on hand, some 38,045 barrels of net oil was 

delivered to authorized gatherers of crude oil. 

Some of the approximately 20,000 barrels remaining from receipts will remain in stock for 

processing/reprocessing while other material such as solids and water will be properly disposed of 

in Commission approved injection wells or regulated solid waste disposal sites. 

If you need any additional information, please advise. 

RB:mg 

cc David Garlick 

Jim Walker 

Bill Gallagher 

Richard Buerger 

An Equal Opportunity Employ 
~ rcT-29-*90'MbN 'l2:50 " ID:TX RAILROAD c6MM-UIC~TEL NO:512-463-6780 8181 P0S 

} 

INTERSTATE OIL COMPAC T COMMISSIO N 

HEADQUA«T6RSOFF.CE:90<JN.e.23RDSTfl6ET . P.0.80X53127 • OKLAHOMA C.TY, OKLAHOMA 73152-3,27 

TELEPHONE! (405) 5234S56 

AqJdrcii fteply to He»dqw«rferj Office 

AAIKE SULLIVAN 

w. TIMOTHY DOWO October 11/ 1990 

gxeeutfv* Dlraetor 

TO: State oil and Gas Directors 

FROM: Jerry R. Si_anons^^fe/ 

SUBJECT: oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

..waste -streams . required to meet .the new TC. rule. .are. the .oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination, 

i 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

A 

& 

2. HOW many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

3. Do you permit these operations? 

-V 

4. what Regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

5. What is the estimated volume of wastes created by reclaimers 

in your state? ^ 

_ • < .-^--P o^fl ^%£!*t/sr\<2-

M 

LOU 

. ,-.1 I.O.II U . COLOAAOO . lU-INOtS . INDIANA • KAN«A« . K»Nf LJCKY 

M.UI O «TAT.», ALAiA*A . ALASKA . AAltONA . A«tK*«»~» 'J*"'TM * . Kl w M „ 1 C 0 . NfW «» « . NC.TH DAKOTA . Ox.O 

LANO-A • -,NN»VLVAN. A . WUT H *»**TM - TM* ' * V^mBm , «, u t H CAWL.N A . WA.H.NOTON 

AIEOCIATIS; OEOUSIA - IOAHO . NOATM CAROLINA 9*m*»* 

OKL 
OCT-29-'90 MON 12:51 ID:TX RAILROAD COMM-UIC TEL NO:512-463-6780 B181 P03 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practice© of the 

typical reclaimer in your state? 

CMS'^3 =*-:r "**- ** y*"m***> ' f* j~*\J*~^ | 

Please respond to as many of the above questions as possible and

 N 

return to IOCC headquarters office by Friday, October 26.

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P.86 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

UTAH 
P.87 

DIV OIL iJH'i 3: MINIM'S 

Human H. B*ngr"'.T 

Ore C. H««*4-r» 

Kx«4.tj(i\. Dircvlnr 

ni*nnc R. Ni4!i»ui, Ph.D. 

Onriuan Dir*viiir 

TEL: 801-359-3 540 uc- No .003 P .02 

State of Utah 

DEPARTMENT OF NATURAL RESOURCES 

DIVISION OF OIL, GAS AND MINING 

JW West Ncrt"- T«-pi* 

3

 Tr:«e C*"ler. Suit* 3 M 

Salt L»ft Cry LHali 9418C-:203 

DOi -436-5.1*0 

UT 

October 29, 1990 

To: Jerry R. Simmons, IOCC 

From: Utah Division of Oil, Gas and Mining 

Re: Crude Oil Reclamation Operations 

There are no permitted waste crude oil treatment facilities 

currently operating in Utah. The Division does have rules in 

place (copy attached) under which such a facility could be 

approved. 

There are several commercial produced water disposal pits 

(facilities) in the State which accumulate minor volumes of waste 

crude oil. At these facilities, the crude is a nuisance and must 

be handled in order to minimize the loss of evaporation rate..The 

crude oil is cleaned and sold as a by-product to help fund the 

operation. Any waste resulting from the operation would be 

deposited in the pit until closure of the facility at which time 

it would either be hauled to a proper disposal site or stabilized 

and covered in place. 

The volume of crude recovered by these operations is not 

reported to the State. 

W taua' opDOrtk.-'itY >.mcl0y*r 
P.88 

*m>po 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HlAOOUAflTgPSOPPICE: 900N.1.23HOSTREET • RO.BCX33127 • 

m«PHCNE: (.OS) 525-3556 

OKLAHOMAOTY, OKLAHOMA T3'52-3*27 

MIKE SULLIVAN 

OMiritan 

Oevt'nor of Wyoming 

w. TIMOTHY OCWO 

lx*Cjtiv« Oir«e*gr 

TO: 

FROM: 

SUBJECT: 

Addroil Reply to H«c'qi.l/'«ri OffiC* 

October 11, 1990 

State Oil and Gas Directors 

Jerr y R. Siatmons^^ / 

Oil Reclamation Op#r^iA-< 

Wmmm 

" OCT 15 1990 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to meet the new TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

NONE 

2. 

3. 

4. 

5. 

How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

NONE 

Do you permit these operations? 

YES 

What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

DIVISION OF OIL, GAS & MINING 

What is the estimated volume of wastes created by reclaimers 

in your state? 

NONE 

"fi d l'«I M '%«•• « • AW**"* • AHIIONA . t«Kl*lM | . CAL. ran*! A . COLC-AOO . ILLlNO'» • XOIAN * • "ANSA* . .t.N-.sS'.I'ANA . UA«Vl_»-.e .* 4.1«..• ,}A4, . Ml««'«lll>»l . 4JlO»4»»WA • <•!••«»» * . >4«VACA . NtW 44t.«,0O • NtV» *0»H . NO.T„ ;»«O- » ( 

4KLAAOM. . •(MN<VLVANI« . |Oufl4 BAAOT* . '(.tA * . JTA44 . •/•«0:NIA . WffT V^KQ'NtA . WQniS a 

AliociAro a«g*.g.A . IOA*O . .IOKTM JA»OL:NA • omaoN . IOUTH CA/IOL.NA • «A*HIMOTON 
---

 ,Jr,~-' '" '*'"•' '__: Ju.-jj: w^-w uC; ^ . ."v :• • -: .-..;.-JO3 r.05 

.» .J 

Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state?

 h e 

N/A 

Please respond to as many of the above questions as possible and 

return to IOCC headquarters office by Friday, October 26? 

JRS:bjh 

cc: Governors and Official Representatives 
P.90 

R615-6 Gas Processing and Haste Crude Oil Treatment 

R615-6-1 Gas Processing Plants 

1. In accordance with Section 40-6-16 U.C.A. (1953 as amended), any 

operator of a facility or plant In which Hqueflable hydrocarbons are 

removed from natural gas, Including wet gas or caslnghead gas, and the 

remaining residue gas 1s conditioned for delivery for sale, recycling, or 

other use, shall file monthly, Form 13-A and Form 13-B. 

1.1. Reports shall be filed for all gas processing plants or facilities 

to account for the receipt, processing, and disposition of all gas by the 

plant. 

1.2. Plant operators required by contractual arrangements to allocate the 

residue gas and extracted liquids processed by the plant or facility to the 

individual producing wells, shall Identify each well connected to the plant 

or facility by API number and report the metered wet gas volumes, residue 

gas volumes returned to the field, and all allocated residue gas and natural 

gas liquid volumes. 

• 

R615-6-2 Haste Crude 011 Treatment Facilities 

1. Prior to the construction of a waste crude oil treatment facility, an 

application shall be submitted to the division describing the ownership, 

location, type, and capacity of the facility contemplated; the extent and 

location of the surface area to be disturbed, including any pit,:pond, or 

land associated with the facility; and a reclamation plan for the site. 

Approval of the application must be Issued by the division before any ground 

clearing or construction shall occur. 

2. As a condition for approval of any application, the owner or operator 

shall post a#bond In an amount determined by the division to cover 

reclamation costs for the site. Failure to post the bond shall be 

considered sufficient grounds for denial of the application. 

3. No waste crude oil treatment facility operator shall accept delivery 

of crude oil obtained from any tank, reserve pit, disposal pond or pit, or 

similar facility unless the delivery is accompanied by a run ticket, 

Invoice, receipt or similar document showing the origin and quantity of the 

crude oil. 

KEY: 01! and Gas Conservation, Gas and 011 Treatment 40-6-1 

1989 et seq. 

6-1 
P.91 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

VIRGINIA 
I 

P.92 

O. GENE DISHNER DIVISIONS 

DIRECTOR ^*m*~- ENERGY 

___. „ -.^— _ GAS AND OIL 

KATHY J. REYNOLDS ^ ^ "^ ^ 

/A 

„ „ „ —r ,mTi , TM MINED LAND RECLAMATION 

, ASSISTANT DIRECTOR J P TOS/ ^ MINERAL MINING 

/ FOR ADMINISTRATION » J M H MINERAL RESOURCES 

BENNY R. WAMPLER ("-"WalitW -' <7- MINES 

ASSISTANT DIRECTOR 

-•' FOR MINING 

COMMONWEALTH of VIRGINIA 

Department of Mines, Minerals and Energy 

The Bookbindery Building 

2201 West Broad Street 

Richmond, Virginia 23220 

(804) 367-0330 

October 24, 1990 

Mr. Jerry R. Simmons 

Interstat e Oil Compact Commission 

Post Office Box 53127 

Oklahoma City, Oklahoma 73152-3127 

Dear Mr. Simmons: 

Enclosed is our response to your survey about oil reclaimers. Acting 

on th e advic e of an officia l from the Virgini a Department of Waste 

Management, we contacted Drew Frye, who is manager of an Alexandria oi l 

recyclin g firm calle d Eastern Oil Company and a member of the National Oil 

Recyclers' Association. Mr. Frye said he knows of no company in Virgini a 

reclaiming crude oi l sludges a t this time. He added that he believes he 

would know of any such company if i t existed because of his familiarity with 

the recycling industry here. As you can see from our response, there is no 

program in Virginia for permitting oil reclaimers. Please le t me know if 

you have further questions. 

Sincerely, 

0. Gene Dishner 

Enclosure 

An Equal Opportunity Employer 
I 

P.93 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERS OFFICE: 900 N.E23RD STREET • P.O.BOX53127 • 

TELEPHONE: (405) 525-3556 

OKLAHOMACITY, OKLAHOMA 73152-3127 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWD 

Executive Director 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

TO: 

FROM: 

State Oil and Gas Directors 

Jerry R. Simmons^^^/ 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to . meet the new-, TC rule are .the... oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

None that we can identify. 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

3. 

4. 

N/A 

Do you permit these operations? 

Only as part of the on-site activitie s of an oi l production operation. 

What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

None. 

What is the estimated volume of wastes created by reclaimers 

in your state? 

N/A 

M1M9CR STATES: ALABAMA . ALASKA . ARIZONA . ARKANSAS . CALIFORNIA - COLORAOO . ILLINOIS - INOIANA . KANSAS . KENTUCKY 

LOUISIANA . MARYLAND . MICHIOAN . MISSISSIPPI . MONTANA • NEBRASKA . NEVADA . NEW MEXICO . NEW YORK . NORTH OAKOTA . OHIO 

OKLAHOMA - PENNSYLVANIA • SOUTH 3AKOTA • TEXAS . UTAH . VIROINIA . WEST VIROINIA - WYOMING 

ASSOCIATES: OIOROIA . IDAHO . NORTH CAROLINA • OREOON . SOUTH CAROLINA . WASHINOTON 
Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices of the 

typical reclaimer in your state? 

N/A 

Please respond to as many of the above questions as possible and 

return to IOCC headquarters office by Friday, October 26. 

JRS:bjh 

cc: Governors and Official Representatives 

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P.95 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

WEST VIRGINIA 
P.96 

) U/ i/:/^mi^ 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERSOFFICE: 900 N. E.23RDSTREET • P.O.BOX53127 • OKLAHOMACITY,OKLAHOMA73152-3127 £ 

TELEPHONE: (405) 525-3556 

(TV 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY DOWD 

Executive Director 

TO: 

FROM: 

Address Reply to Headquarters Office 

MEMORANDUM 

October 11, 1990 

State Oil and Gas Directors 

Jerry R. Simmons^,^/^/^ 

/ 

SUBJECT: Oil Reclamation Operations 

OCT 1 5 93 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste, streams required to meet the new...TC rule are., the oil. 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many oil reclaimers operate in your state? 

2. How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

<S> 

3. Do you permit these operations? 

/UO 

4. What regulatory agency in your state has the responsibility 

for crude oil reclamation operations? 

rZvt~ t 7~<Z 

5. What is the estimated volume of wastes created by reclaimers 

in your state? 

Ayk 

MEMBER STATES ALABAMA • ALASKA . ARIZONA . ARKANSAS • CALIFORNI A - COLORADO . ILLINOIS . INDIAN A . KANSAS . KENTUCK Y 

LOUISIAN A . MARYLAN D . MICHIGA N • MISSISSIPPI • MONTAN A . NEBRASKA . NEVADA . NEW MEXICO . NEW YORK . NORTH OAKOTA . OHI O 

OKLAHOM A • PENNSYLVANI A . SOUTH OAKOTA - TEXAS . UTAH - VIROINI A . WEST VIROINI A . WYOMIN O 

ASSOCIATES: OEOROIA - IDAHO . NORT H CAROLIN A • OREOON . SOUTH CAROLINA . WASHINGTO N 
J

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Memorandum 

October 11, 1990 

Page 2 

6. What are the past and current disposal practices" of the 

typical reclaimer in your state? 

/V£L 

Please respond to as many of the above questions as possible and

 N 

return to IOCC headquarters office by Friday, October 26.

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P.98 

INTERSTATE OIL COMPACT COMMISSION 

questionnaire response from 

WYOMING 
P.99 

INTERSTAT E OI L COMPAC T COMMISSIO N 

HEADQUARTERSOFFICE: 900 N.E.23RD STREET • P.O.BOXS3127 • OKLAHOMA CITY, OKLAHOMA 73152-3127^ . 

TELEPHONE: (405) 525-3556 

MIKE SULLIVAN 

Chairman 

Governor of Wyoming 

W. TIMOTHY OOWD 

Executive Director 

TO: 

FROM: 

Address Reply lo Headquarters Office 

MEMORANDUM 

October 11, 1990 

State Oil and Gas Directors 

Jerry R. Simmonnj&tvy s 

§ v r * 

s

 » -Har. 4\^v 

OCT 15 1990 

»«s«4& 

SUBJECT: Oil Reclamation Operations 

As you probably know by now, on September 25, 1990, the EPA's new 

toxicity characteristic (TC) rule went into effect. This new rule 

requires testing of certain wastes prior to disposal. One of the 

waste streams required to meet the new TC rule are the oil 

reclaiming operations which were not part of the exemption in EPA's 

1988 Regulatory Determination. 

In order to provide the EPA with information to clarify its 

position on the application of the TC rule, I would ask you to 

provide this office with any of the information contained in the 

following questionnaire. 

1. How many o 

one 

il reclaimers operate in your state? 

How many barrels of crude oil do reclaimers sell in your state 

annually or monthly? 

unknown 

3 . 

4 . 

5. 

Do you permit these operations? 

no 

What regulatory agency in your stat e has the responsibility 

f o r crude oi l reclamation operations? 

The state Department of Environmental Quality has limited rules which 

would apply to the construction of a facility . 

What is the estimated volume of wastes created by reclaimers 

in your state ? 

unknown 

MEMBER STATU ALABAMA . ALASKA . ARIZONA . ARKANSAS • CALIFORNIA • COLORADO - ILLINOIS - INOIANA • KANSAS - KE.NTJCKV 

LOUISIANA - MARYLANO . MICHIGAN . MISSISSIPPI . MONTANA • NEBRASKA . NEVAOA • NEW MEXICO . .NEW YORK • NORTH OAKOTA . OHIO 

OKLAHOMA . PENNSYLVANIA . SOUTH 3AKOTA • TEXAS - UTAH • VIROINIA . WEST VIROINIA - WYOMING 

ASSOCIATES. GEORGIA . IOAHO • NORTH CAROLINA • ORIOON . SOUTH CAROLINA . WASHINOTON