Laserfiche WebLink
11 <br />E <br />no. 3 in Los Angeles County. Based on information supplied by the facility <br />operator, that waste consisted mostly of leakage of oily emulsions from the <br />pumps, mixed with drainage water from the pump cellar floor. Table 16 <br />summarizes the TTLC values for lead obtained during metals analysis. <br />Table 16: Sludge Samples Exceeding Regulatory Threshold for Lead <br />Does the E&P exemption apply? <br />No, because the E&P exemption only applies if toxicity of the waste is <br />determined based on TCLP results. In this case, toxicity was determined based <br />on TTLC, a criterion not covered by the exemption. <br />Samples of produced water, drilling waste, oily sludge, and foam treatment waste <br />were collected and analyzed for characteristics of hazardous waste, based on <br />the four hazardous waste characteristics outlined in 40 CFR, Sections 261.10 et <br />seq., and in 22 CCR, Sections 66261.20 et seq., namely ignitability, corrosivity, <br />reactivity, and toxicity. The following conclusions were reached as a result of <br />data interpretation. <br />The E&P wastestreams sampled and analyzed during this study were not found <br />to be hazardous under current Federal and State law. Although produced water <br />and oily sludges meet the Federal toxicity characteristic for hazardous waste, <br />they are exempted from regulation as hazardous pursuant to the E&P exemption. <br />However, oily sludges showed potential to display hazardous waste <br />characteristics by criteria other than TCLP, with ten out of thirty-six samples <br />displaying hazardous waste characteristics under State law. Based on the data <br />obtained, it is concluded that some oily sludges may exhibit hazardous waste <br />characteristics not covered under the E&P exemption, in which case oily sludges <br />Statewide Compliance Piyisiop May 2Q02 <br />'__ ------- ... <br />NEM <br />