EPA
Untied States
Environmental Protection
Agency
Office o<
Solid Waste and
Emergency Response
Directive: 9347.3-02FS
July 1989
Superfund LDR Guide #2
Complying With the California
List Restrictions Under Land
Disposal Restrictions (LDRs)
The Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA)
include specific restrictions on the land disposal of RCRA hazardous wastes. California list wastes are a distinct
category of RCRA hazardous wastes that are restricted under the land disposal restrictions (LDRs). This guide
defines the California list wastes, summarizes their respective restrictions, and discusses their potential overlap with
other LDR treatment standards. More detailed guidance on California list waste restrictions and Superfund
compliance with the LDRs is being prepared by the Office of Solid Waste and Emergency Response (OSWER).
DEFINITION OF CALIFORNIA LIST WASTES
To be classified as a California list waste, three
conditions must be met:
(1) The waste must be a RCRA listed or characteristic
waste:
(2) The waste must be a liquid (It, it fails method
9095 Paint Filter Liquids Test {PFLT]), except for
Halogcnatcd Organic Compounds fHOCs). which
may be liquid or non-liquid; and
(3) The waste must exceed statutory prohibition levels
for specified constituents.
The types of wastes that may be California list
wastes arc: free cyanides, certain metals, corrosive
wastes, PCBs, and HOCs. (HOCs are compounds
containing carbon and a halogen, such as fluorine,
chlorine, bromine, iodine, and astatine, in their
molecular formula). The Agency has limited the
restricted HOCs to approximately 100 HOCs listed in
Appendix III to 40 CFR Part 268. These restricted
HOCs include solvents, pesticides, PCBs, and dioxins.
These hazardous wastes are referred to as
California list wastes because the State of California
developed regulations to restrict the land disposal of
wastes containing these constituents, and Congress
subsequently incorporated these provisions into the
1984 HSWA amendments to RCRA. Even if LDR
treatment standards have not been promulgated for
certain RCRA wastes (e.g. Third Third wastes), these
wastes may be subject to California list restrictions.
If the Agency has promulgated a treatment standard
for a California list hazardous waste, the waste must
attain that treatment standard before land disposal If
the Agency has not set a treatment standard, the waste
must be treated to below the prohibition level (or
rendered non-liquid if a non-HOC waste) before it
may be land disposed.
CALIFORNIA LIST LDR RESTRICTIONS
The Agency has promulgated treatment standards
for PCB-containing wastes and Hoc-containing wastes
(except for dilute HOC wastewaters). The treatment
standards for PCBs and some HOCs became effective
on July 8, 1987.
The Agency has not set treatment standards for
the remaining California list wastes. Instead, the
Agency codified the statutory prohibition levels for
corrosive wastes and dilute HOC wastewaters and
allowed the hard hammer provisions to take effect for
free cyanides and California list0 metals. The
prohibitions on these wastes became effective on July
8, 1987. The effects of these restrictions are the same:
prohibiting the land disposal of these washes above the
prohibition levels.
Based on a finding of inadequate treatment capacity,
EPA granted a nationwide extension to the effective
date for treating California list HOC wastes until July
8, 1989. The Agency subsequently rescinded the
variance, and the restriction for HOC wastes became
effective November 8, 1988. The Agency also granted
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an extension of the effective date for HOC-confaining
Soil and debris Wastes until July 8, 1989, for soil and
debris wastes ot from CERCLA/RCRA corrective
actions, and until November 8, 1990, for soil and debris
wastes frQ CERCLkfRCRA corrective actions.
California list wastes granted a national capacity
variance from the treatment standards may be disposed
of in a landfill or surface impoundment only if the
receiving unit complies with minimum technology
requirements (Sec Superfund LDR Guide #3). The
prohibition leveLs, treatment standards, and effective
dates for the California list wastes are presented in
Highlight 1.
OVERLAP W FH OilIER TREAThIENT STANDARDS
As noted earlier, wastes dust be RCRA listed or
characteristic wastes to be California list wastes.
Therefore, California list wastes may also be restricted
as solvent- or dioxin-containing wastes or as scheduled
wastes. For wastes covered by more than one LDR
standard, the LDR rc trictipns for the more s eciflc
waste stream generally take precedence . once thc
standard is promulgated. For emmpl; FUO6 non-
wastcwaters may be restricted under the California List
rule because the waste is a liquid and may contain
nickel above the statutory prohibition leveL The FUO6
treatment standard, which is expressed a.s a
concentration level, however, takes precedence over the
California list restriction (i.e., codified prohibition
level).
The Agency has determined that soft hammer
wastes and wastes for which national capacity variances
have been granted remain subject to California list
hibitions (i.e., if either of thnsc waste types is
subject to a California list treatment standard or
statutory prohibition level, that treatment standard ot
statutory level must be met before the waste can be
Land disposed). If a California list treatment standard
is promulgated for a soft hanwier waste, the more
stringent of the restrictions apply. For c mp1e, if a
non-liquid soft hammer waste contains 1,100 mg/kg
total HOCs, the waste must meet the California list
trealment standard of incineration or burning in a
boiler or industrial furnace before land disposaL If a
liquId soft hammer waste containc 510 mg/i lead (for
which no California list treatment standard exists), the
soft hammer restrictions apply. If treatment is not
available, the waste must at least be treated below the
prohibition level (i.e., 500 mg/I) or rendered non-liquid
and can only be disposed of in a surface impoundment
or landfill if the receiving unit meets minimum
technology requirements or has an equivalent waiver.
California
List Prohibition Level Trnataent Standard Effective Date
Constituent
Highlight 1 - PROHIB ON LEVELS AND TREATMENT STANDARDS
Free Cyanides
FOR CALIFORNIA LIST WASTES
1000 /1
Metals
Arsenic
Cadniun
Qir iun Vt
Lead
Mercury
Nickel
Se Len
The 1.L iun
NONE -- hard b .r
500 /L
100 nxJl
500 nsJl
500 nsJl
20 n /1
13’, 8/L
100 naJl
130 n /l
NONE -- hard h er
July 8 1987
Corrosives
JuLy 8. 1987
p s
500 p
pB < 2.0
50 p
NONE -- Codifi.d
prohibition Levels
50 p end < 500 p
July 8, 1987
50 ppe
INCINmATION as speci-
fied wider TSCA.
99.9999! DR.E
Ba enar ,ed Organic Co ounds (nra)
DiI.ute Wastewatet
(<10,000 og/kg)
July 8, 1987
INCINmATICN ca T (AL
DESTRUCItON in Boiler,
99.9999! ORE
1000 cig/kE
Hon-Dilute Wastewaters
and Non-Liquids
JuLy 8, 1987
Non-R AICrnCta Sot I.
end Debris
1000 551k8
HONE -- Codified
prohibition levels
Rc tAJcrnaA Soil and
Debris
1000 cigfkg
July 8, 1987
1t(CIN AttON 99 991 ORE
Nov 8, 1988
tNC1N AT1ON 99 99! ORE
JuLy 8, 1989
1000 w 6 fk INC1N ATIOt( 99.99! ORE
Nov. 8, 1990
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