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11 <br />I-FiRaMS 0 - <br />P -A <br />The flash point test, outlined in 22 CCR, Section 66261.21(a)(1) was used as a <br />measure of ignitability for all samples collected. According to the regulations, <br />any liquid waste containing less than 24 percent alcohol by volume is hazardous <br />if it has a flash point of less than 140 degrees Fahrenheit. Four oily sludge <br />samples out of thirty-five collected failed this test, with a flash point value of 65 <br />degrees Fahrenheit, which renders them hazardous under California law. <br />Note: The sludge samples had sufficient liquid content for the flash point test to <br />be performed. <br />The four sludge samples were taken from a production pit at facility no. 4 in Los <br />Angeles County. The facility operator indicated that some contents of the pit, <br />namely the uppermost liquid layer would be extracted and recycled for its oil <br />content. The lower layer, consisting of sludge would be shipped offsite to a <br />commercial disposal facility. No clear separation existed between the portion of <br />waste that was recyclable and the portion that would be stored and disposed. <br />Due to the lack of separation among various phases of the waste and based on <br />the results obtained, it was concluded that the oily sludge waste contained in the <br />pit is hazardous in its entirety. Table 14 summarizes the flash point test values <br />that led to that conclusion. <br />Does the E&P exemption apply? <br />No, because the hazardous waste determination was based on the ignitability <br />characteristic for hazardous waste, not toxicity. <br />MORI __ --- •7 =0 <br />The reactivity of a waste is assessed by the releasable sulfide test. In the <br />absence of a regulatory threshold value for releasable sulfides in 22 CCR, an <br />interim guidance value was established by the U.S. EPA in the SW -846 manual, <br />Chapter 7, at 500 mg/kg hydrogen sulfide for solids and 500 mg/I for aqueous <br />waste. This guideline threshold value was exceeded by two out of thirty-five <br />sludge samples analyzed. Four sludge samples were collected from the bottom <br />of a water -holding tank (waste also known as tank bottoms) at facility no. 1 in Los <br />Angeles County. Two of the four samples collected at this site exceeded the <br />Statewide ComplJOnc-D• <br />MEM <br />