United States	Office of	Directive: 9347.3-02FS
Environmental Protection	Solid Waste and	July 1989
Agency	Emergency Response
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 (i.e., it fails method 9095
Paint Filter Liquids Test [PFLT]), except for
Haloeenated Organic Compounds (HOCs). 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
are: 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.
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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 list
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 wastes 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-containing soil
and debris wastes until July 8, 1989, for soil and debris
wastes not from CERCLA/RCRA corrective actions, and
until November 8, 1990, for soil and debris wastes from
CERCLA/RCRA 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 (See Superfund LDR
Guide #3). The prohibition levels, treatment standards, and
effective dates for the California list wastes are presented in
Highlight 1.
OVERLAP WITH OTHER TREATMENT STANDARDS
As noted earlier, wastes must 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
restrictions for the more specific waste stream generally take
precedence, once the standard is promulgated. For example,
F006 non-wastewaters may be restricted under the California
list rule because the waste is a liquid and may contain nickel
above the statutory prohibition level. The F006
treatment standard, which is expressed as 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 prohibitions
(i.e., if either of these waste types is subject to a California
list treatment standard or statutory prohibition level, that
treatment standard or statutory level must be met before the
waste can be land disposed). If a California list treatment
standard is promulgated for a soft hammer waste, the more
stringent of the restrictions apply. For example, if a
non-liquid soft hammer waste contains 1,100 mg/kg total
HOCs, the waste must meet the California list treatment
standard of incineration or burning in a boiler or industrial
furnace before land disposal. If a liquid soft hammer waste
contains 510 mg/1 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/1) 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.
Highlight 1 - PROHIBITION LEVELS AND TREATMENT STANDARDS
FOR CALIFORNIA LIST WASTE
California List
Constituent
Prohibition
Level
Treatment Standard
Effective Date
Free Cyanides
Metals
Arsenic
Cadmium
Chromium VI
Lead
Mercury
Nickel
Selenium
Thallium
Corrosives
PCBs
> 500 ppm
> 50 ppm and < 500 ppm
1000 mg/1
500	mg/1
100	mg/1
500	mg/1
500	mg/1
20	mg/1
134	mg/1
100	mg/1
130	mg/1
pH < 2.0
50 ppm
50 ppm
Halogenated Organic Compounds (BOCs)
Dilute Wastewaters	1000 mg/kg
(<10,000 mg/kg)
Non-Dilute Wastewaters	1000 mg/kg
and Non-Liguids
Non-RCRA/CERCLA Soil	1000 mg/kg
and Debris
RCRA/CERCLA Soil and
Debris
NONE -- hard hammer
NONE -- hard hammer
1000 mg/kg
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NONE — Codified
prohibition levels
INCINERATION as
specified under TSCA,
99.9999% DRE
INCINERATION OR THERMAL
DESTRUCTION in Boiler,
99.9999% DRE
NONE — Codified
prohibition levels
INCINERATION 99.99% DRE
INCINERATION 99.99% DRE
INCINERATION 99.99% DRE
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July 8, 1987
July 8, 1987
July 8,	1987
July 8,	1987
July 8,	1987
July 8,	1987
Nov. 8,	1988
July 8,	1989
Nov. 8,	1990

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