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The data generated during this initiative are evaluated in terms of the four <br />hazardous waste criteria outlined in 40 CFR, Section 261.10 et seq., and 22 CCR <br />Sections 66261.20 et seq., namely, ignitability, corrosivity, reactivity, and toxicity. <br />SignAlcantly, the StaWs toxicity dwacteristic incorporates the E&P exemption, <br />as discussed in the Regulatory Background section this document. Thus, E&P <br />wastes that exhibit the toxicity characteristic for hazardous waste based solely on <br />TCLP remain exempted from regulation as hazardous wastes under State law. <br />The exemption does not apply in California if toxicity of the waste is established <br />under criteria other than TCLP, or the waste is hazardous by a hazardous waste <br />characteristic other than toxicity. <br />SCID selected parameters of study for E&P wastes that would be indicative of the <br />wastes' hazardous charectensfts. The flash poJint is molilcobve of a wastes <br />ignitability. The pH test is indicative of a waste's convsWity. Measums of the <br />waste's toxicity were obtained by peftrming tests for aquatic toxicity bioassay, <br />BTX, VOCs, SVOCs, TPH, and metals. Reactivity was assessed by measuring <br />the amount of hydrogen sulfide gas produced by acid digestion of sulfides <br />present in the waste. <br />22 CCR, Sections 66261.21 et seq. establish RT values for the following tests: <br />pH; aquatic toxicity; flash point; and metals. With few exceptions, the regulations <br />,to not list specific RT values for most volatile and semi -volatile organic <br />compounds. Such an exception is benzene, with an established RT value of 0.5 <br />mg/l, when extracted by TCLP. <br />The following is a discussion of results obtained as they relate to the four criteria <br />for hazardous waste identification mentioned above. <br />Based on the data summarized in Table 7, produced water was not found to be <br />hazardous for the characteristics of ignitability, corrosivity, reactivity, or toxicity. <br />That conclusion is supported by the statistical calculations of transformed data <br />for produced water listed in Table 8. For tests with an established RT value, the <br />UCL value was calculated and compared to RT. The UCL is lower than RT for all <br />applicable tests performed on produced water, which indicates that the produced <br />water is not hazardous. <br />IFNI Col i M71 ZT. =-a ir <br />I ZZIV I KTr-! 1 1110 0 a <br />Statewide Compliangg Divisjop <br />Mjy 2002 <br />391-M <br />