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Oil Exploration and Production Wastes Initiative Executive Summa�y <br />W ..W.0 <br />EXECUTIVE SUMMARY <br />The Oil Exploration and Production (E&P) Wastes Initiative described in this <br />document was a field research project conducted by the Department of Toxic <br />Substances Control, Hazardous Waste Management Program, Statewide <br />Compliance Division, during the year 2000/2001, and was funded by a grant from <br />the U.S. EPA. The scope of the project was to characterize E&P wastes, and <br />based on the findings, determine if the wastes are being managed properly in <br />California. SCD collected and analyzed eighty-two waste samples, not including <br />field blank samples. The wastestrearns represented by the samples were: <br />produced water; drilling waste; oily sludge; and foam treatment waste (a type of <br />workover waste). The parameters of analysis were: pH; flash point; total reactive <br />sulfides; aquatic toxicity; total petroleum hydrocarbons; metals; benzene, <br />toluene, xylenes; volatile organic compounds; and semi -volatile organic <br />compounds. <br />Currently, E&P wastes are managed as non -hazardous solid wastes under <br />Federal law, pursuant to the E&P exemption codified in Title 40 Code of Fe•- <br />-• r <br />eegulations (40 CFR), Section 261.4(b)(5), and included, with limitations, in Tift <br />22 California Code of Regulations (22 CCR) Sections 66261.4(b)(2) and <br />66261.24(a)(1). The exemption applies in California if the waste displays the <br />toxicity characteristic for hazardous waste based solely on the Toxicity <br />Characteristic Leaching Procedure (TCLP), as provided under 22 CCR, Section <br />66261.24. <br />Overall, the wastestrearns sampled were not found to be hazardous based on <br />the data obtained and the statistical interpretation of that data; however, isolated <br />cases are discussed where the E&P wastes displayed California hazardous <br />waste characteristics. The study concludes that some E&P wastes may exhibit <br />California hazardous waste characteristics not covered under the Federal <br />exemption, and should be managed as hazardous wastes under State law. <br />Guidance is given to the generators to properly characterize E&P wastes and <br />dispose of those wastes in accordance with all applicable State and Federal laws <br />and regulations. <br />Statewide Qpmpliance Division Micy., 202 <br />