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Oil ,Exploration and Production Wastes Initiative Discussion of Results M97174MR67, =-M Field observations and information provided to DTSC by facility operators 1. VOC releases into the atmosphere from aerated production pits containing oily sludge waste are a concern. 2. Although in small amounts, the presence of chlorinated compounds in some E&P wastes raises a question regarding the extent to which the presence of such compounds would render the wastes hazardous. 3. The presence in high concentrations of VOCs and some SVOCs in produced water may pose a concern. However, produced water disposed into public works is regulated under the RWQCBs. Thus it was noted during the course of the study that produced water with high VOC levels was typically recycled in a closed system and used for waterflood, not disposed into public works. 4. The practice of using cement to aggregate drilling waste is a concern, because cement may dilute the waste by masking metal constituents in laboratory test conditions. 5. The use of oily sludge for fabrication of road mix is a concern because that practice is essentially use of waste in a manner constituting disposal by land application, as defined in 22 CCR Section 66261.2(d)(1)(A). It is not clear from this study if facilities engaged in road mix fabrication are conducting that practice in accordance with the provisions of 22 CCR Section 66266.21, which sets forth requirements for recyclable materials that are placed on the land. If standards set forth in 22 CCR Section 66266.21 for land application were not met, the waste would remain subject to full regulation under hazardous waste laws and regulations. 1. "VOC mleas" to aW=ptw* *om swat" pmduebon pft wotdd appear to be more a concern of local air quality management districts than of the Department. We also question whether any of these wastes would be present in "produefta which in most comm we actually concrete • steel tanks. Under the HWCL, residues that form in the bottom of product or raw material storage tanks of other process equipment are not subject to regulation until removed from the t" (22 CCR S 66261.4 MW - �ivision BEIM