California waste code 611 Dirt dug from clean-up sites and other excavations.

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Based on California Title 22 and DTSC guidance
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Hazardous contaminated soil

The contaminated soil is hazardous waste, whether from a cleanup or another excavation project.

Hazardous contaminated soil, from site clean-ups and other excavation projects. Digging alone does not make soil hazardous.

Is California code 611 hazardous waste?

Not from the code alone. The material must first be determined hazardous. California code 611 is not restricted, and a restricted code takes priority over it. A non-restricted code doesn't make a waste non-hazardous.

If the shipment needs the Uniform Hazardous Waste Manifest, enter 611 in Item 13 for the waste line. Use one California code, plus any federal RCRA codes when the waste is federally hazardous.

Waste is RCRA waste when it meets a federal listing or characteristic and no federal exclusion applies. Non-RCRA waste is hazardous under California rules only. California presumes hazardous waste is RCRA unless the generator shows it isn't, so keep that determination.

What does California code 611 cover?

This is for contaminated soil that has been determined hazardous. Its official name refers to site cleanups, but DTSC's 2024 workshop explains that 611 also covers hazardous soil from other projects, including construction. Calling soil a project or digging it up doesn't make it hazardous. It needs a hazardous listing or characteristic.

Scope clarification: DTSC 2024 code workshop
Official wording: 22 CCR division 4.5, chapter 11, Appendix XII(b)

Is excavated soil California code 611?

Code	When it fits
611	The contaminated soil is determined hazardous, whether from a cleanup or a construction project.
No hazardous waste code	No hazardous listing or characteristic remains once the soil's exclusions and test results are assessed.

The regulations don't say whether asbestos-bearing hazardous soil is 611 or 151. Confirm that overlap rather than entering 2 California codes. DTSC's 2024 proposed replacements for 611 and 181 are only proposals, so don't use them in place of the current Appendix XII list. Soil that meets only California criteria is non-RCRA, and federal hazards need their own determination.

What changes the route for California code 611?

The federal exclusion for petroleum-contaminated media from qualifying underground-storage-tank corrective action removes only D018–D043. It doesn't remove D004–D017 or any other federal hazard. A federal exclusion doesn't by itself remove California hazardous status. The 90-day non-RCRA soil accumulation route needs no free liquids, the specified impermeable surface, environmental controls, inspections and records. It isn't a blanket allowance for any soil pile.

Which wastes take California code 611?

Waste	When it’s 611
Contaminated soil	The contaminated soil is determined hazardous, whether dug for a cleanup or another project.