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PA G E 2 in California and would be used as an ingredient for an industrial process in California,the more stringent requirements of the HWCA must be considered. While this material is also not a listed hazardous waste under the HWCA, some batches could conceivably exceed the toxicity characteristic because it exceeds the more stringent California solubility test (i.e., the Soluble Threshold Limit Concentration or STLC) and could thus potentially be a "non-RCRA" or "California-only" hazardous waste. However,under the HWCA (specifically, California Health & Safety Code Section 25143.2 (b) and (d)),recyclable material which is used as an ingredient in an industrial process to make a product and is managed in accordance with certain regulatory requirements (California Health & Safety Code Section 25143.9 and 25143.10) is specifically excluded from classification as a regulated California "waste." Therefore, this material is neither a "waste" under California law nor regulated under RCRA. In order to qualify for this particular exclusion, several relevant conditions must be met. First,it must not be a RCRA hazardous waste. Second, it must not be treated except by filtering, screening, sorting, sieving, grinding,physical or gravity separation under specified conditions,pH adjustment, or viscosity adjustments. Third, any air emissions from the treatment of the material (through filtering, screening, sorting, sieving, grinding,physical or gravity separation under specified conditions,pH adjustment, or viscosity adjustments using only these treatment methodologies) must not contain constituents that are regulated hazardous wastes and are in compliance with applicable air pollution regulatory requirements. It is our understanding that the KIS ARM meets these conditions. The HWCA also requires the generator to comply with certain handling for this excluded recyclable material as per California HSC 25143.9 and California HSC 25143.10 and record-keeping,reporting and documentation requirements pursuant to California HSC 25143.2 (d) and 25143.2(f). KIS meets these requirements After the Portland cement exits the cement kiln, the requirements depend on whether the product is placed on the land. Recyclable materials (e.g., ARM) used as an ingredient in the manufacture of a product that is placed on the land must be managed as hazardous waste unless excluded under California HSC (as described above) and Title 22 California Code of Regulations (CCR) Section 66266.21 (b)(5). Since the ultimate product