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17J L] Oil Exploration and Production Wastes Initiative Discussion of Results -- regulatory guidance value for releasable sulfides, as summarized in Table 15. Table 15: Sludge Samples Exceeding Regulatory Threshold for Sulfides Does the E&P exemption apply/? No, because the hazardous waste determination was based on the reactivity characteristic for hazardous waste, not toxicity. Toxicily characteristic of oily sludges Toxicity of the waste samples was assessed through VOCs, SVOCs, TPH, BTX, aquatic toxicity bioassay, and metals analyses. As was the case with produced water, VOCs were found at elevated concentrations in oily sludges. SVOCs and some chlorinated organic compounds were also present in low concentrations. The presence of chlorinated organic compounds may be an indication that solvents or other fluids that did not originate in the natural formation became part the wastestream. Such fluids are covered by the E&P exemption, according to guidance provided by the U.S. EPA, as long as they become part of the production stream and are co-produced with the oil, as discussed in the Regulatory Background section of this document. Both produced water and oily sludges had elevated VOCs and SVOCs concentrations which would generally be sufficient to render them hazardous under the toxicity characteristic for hazardous waste summarized in 22 CCR, Section 66261.24(a). However, a hazardous waste determination is not appropriate in this case because in California, E&P wastes remain exempt from regulation as hazardous when toxicity is determined based solely on TCLP. The State regulations also establish Total Threshold Limit Concentration (TTLC) and Soluble Total Limit Concentration (STLC) values, which, if exceeded by the constituents in a waste, render that waste hazardous under State law. STLC and TTLC values were obtained for metals and compared to standards outlined in 22 CCR Section 66261.24(a)(2). Four samples out of thirty-five met the criteria for hazardous waste by exceeding the TTLC value for lead. The four oily sludge samples were collected from a pump cellar trough at facility Statewide Com liance Division Ma 2002 -39-