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Oil Exploration and Production Wastes Initiative Discussion of Results should be managed as hazardous wastes in California. Because of the limited number of samples found to be hazardous, it is plausible that those hazardous characteristics of the oily sludges were largely due to factors such as facility operations and waste management practices. Foam treatment waste data was not sufficient to support statistical evaluation and a formal conclusion, because the number of samples analyzed for each test was only two. However, the extremely low concentrations of most analytes in the two samples are viewed by SCD as an indication that foam treatment waste does not exhibit any hazardous waste characteristics. The data indicate that depending on circumstances such as formation characteristics or facility operations, certain E&P wastes, such as oily sludges, may exhibit hazardous waste characteristics not covered by the exemption in California. Such wastes cannot be managed as non -hazardous under the E&P exemption, and, although exempted at the Federal level, are subject to State laws applicable to hazardous waste. It is the generator's responsibility to determine which wastestreams are hazardous in California and manage them accordingly. The study summarized in this report was conducted under the following limitations. This study was limited by its scope, which was to sample those wastestreams that are most prevalent in the oil production industry and presumably would pose the greater hazard to human health and the environment if found to be hazardous. Other, lower volume wastes associated with oil production remain of interest to DTSC due to their potential to exhibit hazardous characteristics. Another limitation occurred because sampling did not include all regions where oil production takes place in California. However, the study is diversified enough to obtain an overview of E&P wastes for DTSC's purposes. The study was designed to include oil production in both highly populated urban settings, represented by Los Angeles County, and oil production in a rural area, represented by Kern County, where urban encroachment on the oil fields is not prevalent. Limitations existed in terms of number of samples that could be analyzed by the laboratories during the sampling episodes. However, for purposes of this initiative, a sufficiently large number of samples was collected and analyzed to obtain an overview of the wastestreams of interest. Statewide Com liance Division May 2002 -41-