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Hazardous Waste Fact Sheet: TCLP: Toxicity Characteristic Leaching Procedure and Characteristic Hazardous Wastes
Provided by EHSO: http://www.EHSO.com

The TCLP: Toxicity Characteristic Leaching Procedure
The TCLP, or Toxicity Characteristic Leaching (not Leachate) Procedure is designed to determine the mobility of both organic and inorganic analytes present in liquid, solid, and multiphasicwastes. This is usually used to determine if a waste may meet the definition of EP Toxicity, that is, carrying a hazardous waste code under RCRA (40 CFR Part 261) of D004 through D052. As it is the generator's responsibility to make this determination, but generators often contract outside labs to perform the TCLP test, these questions and answers may be helpful to generators. For this reason andsometimes in cleanup actions, businesses are often asked to perform an analysis on their waste using the TCLP. The Code of Federal Regulations (CFR) 40 CFR §261.24, outlines the 40 contaminants the TCLP analysis tests for (See Table 1—Maximum Concentration of Contaminants for Toxicity Characteristic). If a “ Solid Waste” fails the test for one or more of these compounds, the waste is considered tobe a characteristic hazardous waste – unless there is an exemption that applies. Bear in mind, too, that a characteristic waste may still also be a “ listed” hazardous waste. What does the TCLP Analysis Show? The TCLP analysis simulates landfill conditions. Over time, water and other liquids percolate through landfills. The percolating liquid often reacts with the solid waste in the landfill, andmay pose public and environmental health risks because of the contaminants it absorbs. The TCLP analysis determines which of the contaminants identified by the United States Environmental Protection Agency (EPA) are present in the leachate and their concentrations. Who Performs the TCLP? There are many businesses, in almost every state, who can perform these analysis. Look in t ylwp g s n e “a oar s n li lM n h eo a e u d rL b rt i —A a ta . a y e l oe yc ” laboratories will offer courier services for a nominal fee, and provide sampling containers and a chain of custody form. Businesses in remote areas should contact the nearest lab to discuss sampling protocol and sample preparation for transportation. Improper sample handling can result in unreliable test results and wasted money! Whatdoes it cost? The cost of the TCLP depends on the laboratory and location; but typically, a full TCLP analysis may cost as much as $3,000. When is a Waste Hazardous? A waste is considered hazardous when it exhibits one or more of the following characteristics: Ignitable (Flashpoint 12.5)  Reactive (normally unstable, undergoes violent changes without detonating, water reactive)  Toxic (xe d gh rg loyi tfr o tmi n u d rh T L o “-1 t t ece i t e u tr l so cna n t n e te C P r7 1 e ” n e a mi as s analysis) OR it is “i e ” the CFR (wastes which are pre-defined and categorized) Ls d in t
For the purposes of this fact sheet, a waste is considered hazardous due to toxicity if it exhibits results exceeding the regulatory limits outlined in Table 1 above. There are many exclusions andexemptions within the CFR. For this reason, call the your state EPA (DEP, DER, etc.) or talk to your hazardous waste inspector if you have ANY questions!
Table 1—Maximum Concentration of Contaminants for Toxicity Characteristic EPA HW # D004 D005 D018 D006 D019 D020 D021 D022 D007 D023 D024 D025 D026 D016 D027 D028 D029 D030 D012 D031 D032 D033 D034 D008 D013 D009 D014 D035 D036 D037 D038 D010 D011D039 D015 D040 D041 D042 D017 D043 Contaminant Regulatory Level (mg/ l) 5.0 100.0 0.5 1.0 0.5 0.03 100.0 6.0 5.0 200.0 200.0 200.0 200.0 10.0 7.5 0.5 0.7 0.13 0.02 0.008 0.13 0.5 3.0 5.0 0.4 0.2 10.0 200.0 2.0 100.0 5.0 1.0 5.0 0.7 0.5 0.5 400.0 2.0 1.0 0.2

Arsenic (As) Barium (Ba) Benzene Cadmium (Cd) Carbon Tetrachloride Chlordane Chlorobenzene Chloroform Chromium (Cr) o-Cresol m-Cresol...