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Ll <br />C <br />Oil Exploration and Production Wastes Initiative Discussion of Results - <br />r <br />E&P wastes are not subject to regulation as hazardous waste Federally or in <br />California. <br />Based on the data summarized in Table 9, drilling waste generated during water- <br />based drilling and aggregated with cement was not found to be hazardous. This <br />conclusion is also made evident by the statistical calculations performed on <br />transformed data, summarized in Table 10, which indicate that UCL was lower <br />than RT for all applicable tests. <br />Drilling waste samples displayed elevated pH values, however not sufficient to <br />exceed the RT value for the pH test, and therefore not sufficient to be classified <br />as corrosive. pH values ranged from 8.7 to 11.5, approaching the RT value of <br />12.5. The alkalinity of the waste is attributed to the presence of cement used to <br />aggregate the aqueous phase of the drilling waste. One concern regarding this <br />practice was that cement, due to its alkaline properties, may act as a buffer <br />during the acidic conditions of the extraction test in the laboratory and mask the <br />true characteristics of the waste, especially its metal constituents. <br />Data generated by the analysis of oily sludge are summarized in Table 11. Based <br />on statistical interpretation of transformed data summarized in Table 12, oily <br />sludge was not determined to be a hazardous wastestream overall. Although <br />several individual samples met the characteristic for hazardous waste by <br />exceeding established RTs, the sample population as a whole had UCL values <br />lower than RT values for all applicable tests. However, oily sludge shows higher <br />potential than other sampled E&P wastes for exhibiting hazardous waste <br />characteristics not covered by the exemption, with ten out of a total of thirty-six <br />samples found to be hazardous. Four oily sludge samples collected at facility no. <br />4 met the ignitability characteristic for hazardous waste by failing the flash point <br />test; four samples collected at facility no. 3 met the toxicity characteristic for <br />hazardous waste by exceeding the Total Threshold Limit Concentration (TTLC) <br />for lead; and two samples collected at facility no.1 met the reactivity <br />characteristic for hazardous waste by exceeding the U.S. EPA guidance <br />threshold value for releasable sulfides. These findings are discussed in more <br />detail as follows. <br />Statewide Com liance Division MaX 2002 <br />-37- <br />