TCLP

Q&A: How do I determine the characteristic of toxicity for a liquid waste?

A question May 04, 2018:

can tclp 20 x rule be used for liquid waste or is it only for solid?

My reply May 08, 2018:

Thank you for contacting me.  I will try to answer your question below.

  • Neither TCLP (Toxicity Characteristic Leachate Procedure) nor the “Rule of 20” may be used on a liquid waste for the purpose of determining the characteristic of toxicity.
  • The point of TCLP analysis is to extract a leachate from a representative solid sample of waste and determine the concentration of specified toxins in the liquid.
  • Regulated toxins are identified by USEPA in Table 1 of 40 CFR 261.24(b).  They include:
    • Arsenic (D004)
    • Lead (D008)
    • 2,4-D (D016)
    • Lindane (D013)
    • Silver (D011)
    • Toxaphene (D015)
    • 2,4,6-Trichlorophenol (D042)
    • More…

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  • The “Rule of 20” (I believe this is what the questioner meant by “20 x rule”) is a less expensive option than TCLP for analysis to determine a characteristic of toxicity for a solid.  The procedure for using the Rule of 20 on a solid sample is briefly summarized as follows:Lab personnel
    • Analyze to determine the total concentration of regulated toxin(s) in the sample.
    • The total results are then divided by 20 to determine the Maximum Theoretical Leachate Concentration (MTLC).
    • The MTLC is compared to the regulatory threshold of the toxin(s) at §261.24.
    • If the MTLC does not equal or exceed the regulatory thresholds, then the sample cannot exhibit the characteristic of Toxicity.
  • A liquid sample of a waste is analyzed directly for the total concentration of toxins.  The total results are compared directly to the regulatory thresholds to determine if it exhibits the characteristic of Toxicity.
  • To better understand the Rule of 20, Please read:  How to Determine the Toxicity Hazardous Waste Characteristic Without TCLP

I hope this helps.  Please contact me with any other questions.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services, Inc.

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Conclusion:

Analysis of a sample to determine the characteristic of Toxicity is just one step in the responsibility of a hazardous waste generator to conduct a hazardous waste determination.  Using the Rule of 20 can save you a lot of money in lab costs.  Contact me to determine if there are any other methods available to you to save money and ensure compliance.

Q&A: How Must I use TCLP to Determine the Toxicity of my Hazardous Waste?

This series of questions came from a frequent reader of my newsletter:

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Good afternoon Daniel,

I appreciate the link to your google site. I knew I could come up with a question if I thought a little bit.

(1)  The filters on the aerosol can puncturing systems – may they be discarded as regular solid waste?   According to “New Pig”, the maker of the aerosol can puncturing system that my company sells, the filters may be discarded as regular solid waste.

(2)  In your experience with Black Beauty and its use as a sandblast material for unpainted metals, does used Black Beauty usually pass TCLP?  I know this is a very subjective question and I realize the parameters involved.  Just want your opinion.

(3)   How frequently do you see the use of the SPLP test vs. the TCLP?  Is it coming into more common use?

That’s all for now – and again, no pressing issues; these are simply some questions I have dragging around in the trunk of my car!

Feel free to call if you’d rather.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

My reply was vague but helpful:

I will take a look at your questions and strive to get you an answer soon.

I did reply, a few days later:

I apologize for my delay in responding.  Please see below for my attempt to answer your questions.

1)  The filters on the aerosol can puncturing systems – may they be discarded as regular solid waste?   According to “New Pig”, the maker of the aerosol can puncturing system that my company sells, the filters may be discarded as regular solid waste.

  • New Pig is correct in its direction but may not have provided all of the necessary information.  Any material upon the point of discard becomes a solid waste per USEPA regulations.  This does not mean that it is solid as it could be a liquid, gas, or semi-solid.  The USEPA defines a solid waste at 40 CFR 261.2.  So, “yes” the filter is a solid waste when discarded.  However, the generator of a solid waste must conduct a hazardous waste determination to determine if it is a hazardous waste, what exclusions or exemptions may apply, and, if applicable, its hazardous waste codes.  This determination is the sole responsibility of the generator of the waste.  Since it is unlikely in my opinion that a spent carbon filter would be a listed hazardous waste (unless the aerosols punctured were pesticides), the generator would have to determine if it displays a characteristic:  Ignitability (unlikely), Corrosivity (unlikely), Reactivity (unlikely), or Toxicity (possible depending on what was in the cans punctured).  If the generator determines it is not a hazardous waste, then they may be disposed of as a non-hazardous waste which might – depending on state regulations – allow for disposal with common trash and garbage at a municipal solid waste facility.

(2)  In your experience with Black Beauty and its use as a sandblast material for unpainted metals, does used Black Beauty usually pass TCLP?  I know this is a very subjective question and I realize the parameters involved.  Just want your opinion.

  • Black Beauty is a coal slag blasting abrasive.  The question of whether or not it passes TCLP depends on one assumption and two criteria:
    1. Assumption:  The concern is regarding toxic levels of heavy metals.  I don’t think any other toxins will be an issue.
    2. Criteria 1:  Are there toxic levels of heavy metals in the coal slag prior to use?  I don’t think this is likely but without analytical from the supplier or some other source it is impossible to tell.
    3. Criteria 2:  Are toxic levels of heavy metals derived from the unpainted metal surface?  This is quite possible depending on the steel alloy treated.
  • Answer:  It is quite difficult to determine if a used sandblast material contains toxic levels of heavy metals without analysis.  I suggest analysis of random samples to determine if the characteristic of toxicity is present.  If several samples show no or little presence of leachable toxins, then I think the generator could with confidence state that the waste is non-hazardous.

(3)   How frequently do you see the use of the SPLP test vs. the TCLP?  Is it coming into more common use?

  • I have not heard of SPLP at all prior to your email (I had to google it).  I have not heard anything from USEPA indicating they intend to accept anything for determination of the characteristic of Toxicity other than TCLP or the “Rule of 20”.
I hope this helps.
 
Please don’t hesitate to contact me with any other questions.

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I think my answers were what she was looking for:

Thank you very much for your thorough response to my questions.  I don’t know if the Rule of 20 is used very much in Florida, but it’s certainly good to know about.  I do remember something about…but I had to pull it out from my memory bank.

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Have a great week.

Answering questions is what I do.  Whether it’s through my training (Onsite or Webinar), my consulting services, or by responding to the questions I get from EHS professionals like you.

How to Determine the Toxicity Hazardous Waste Characteristic Without TCLP

All too often the costly and time-consuming TCLP test method (Toxicity Characteristic Leachate Procedure) is used to determine the applicability of a characteristic waste code for Toxicity (D004 to D043) when other less expensive options which are accepted by the US EPA are available. (more…)