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Oil Ex loration and Production Wastes Initiative I I I Discussion of Results 2. "The potential presence of chlorinated compounds in some ESOP wastes y or may not be an issue, depending on the constituent. Many chlorinated compounds regulated under the TCLP and as such would fall under the limited tf3. "As noted in the report, a substantial percentage of produced water is beneficially reused in enhanced oil recovery operations. Produced water that is discharged to surface waters, POTWs or otherwise applied to land (e.g., discharged to evaporation ponds) is regulated by the regional water quality control boards, local POTWs or other state or local agencies, and must meet applicable discharge limits prior to disposal. We are not aware of any situation in which VOCs or SVOC in produced water have posed an environmental concern." 4. "Drilling t are nonhazardous even prior to aggregation with cement for purposes of stabilization. Confirming to are available". 5."Over the years, WSPA has been extensively involved in the development of regulatory requirements applicable to roadmix operations. As you are aware, DTSC along with other Cal -EPA agencies participated in a Task Force study entitled "Cal/EPA Exploration and Production Regulatory Task Force, Beneficial Reuse of Nonhazardous Oil -Field Road Mix Clarification of Regulatory Issues, March 1999". A formal Ca PA report was issued in March 1999. The Task Force reviewed many aspects of the Beneficial Reuse of Nonhazardous Oilfield Road mix materials. The Report cited that guidelines developed by the Industry which clearly recognize the hydrocarbon -containing materials for use in oilfield road mix must be characterized "nonhazardous". The study shows that, depending on circumstances of production, certain E&P wastestreams may exhibit hazardous waste characteristics not covered under the E&P exemption. Although exempted from regulation as hazardous wastes at the Federal level, those E&P wastes are subject to regulation as hazardous in California and cannot be managed as non -hazardous under the Federal E&P exemption. DTSC should emphasize that oil production facilities, as potential generators of hazardous wastes, must ensure proper disposal of their wastes, in accordance with standards for waste characterization set forth in 22 CCR, Section 66262.11, as well as meet other standards applicable to generators of hazardous wastes provided under 22 CCR Section 66262.10 et seq. Chart 1 is a flow diagram depicting one approach to achieving proper management of E&P wastes in California. Statewide Compliance Division _May 2002 -43-