Code of Maine Rules › 06 - DEPARTMENT OF ENVIRONMENTAL PROTECTION › 096 - DEPARTMENT OF ENVIRONMENTAL PROTECTION - GENERAL › Chapter 405 - Solid Waste Management Rules: Water Quality Monitoring, Leachate Monitoring, and Waste Characterization › Appendix 096-405-D - Non-Hazardous Waste Determination

Current through 2024-29, July 17, 2024
Test Methods for Evaluating Solid Wastes
,
				  USEPA, SW-846, 3rd Edition, 2013 ("SW-846") includes
				  the laboratory procedures for performing Method 1311, the Toxicity
				  Characteristic Leaching Procedure (TCLP) on a waste to determine if it contains
				  hazardous levels of any leachable TCLP constituents. Section 1.2 of Method
				  1311states:
If a total analysis of the waste demonstrates that individual
				  analytes are not present in the waste, or that they are present but at such low
				  concentrations that the appropriate regulatory levels could not possibly be
				  exceeded, the TCLP need not be run.
This provision allows flexibility in choosing the appropriate
				  analysis for determining whether a waste is or may be hazardous by reason of
				  the Toxicity Characteristic. If certain conditions are met, it may be possible
				  to show by analysis for total parameters that a waste is not hazardous by
				  characteristic without performing the TCLP analysis. This is done by
				  determining the percent wet solids (per EPA SW-846, Method 1311, section 7.1), calculating the "dilution" factor
				  (DF), and dividing the total results for each constituent by the DF. If any
total
÷
DF
is less than
				  the TCLP regulatory limit for that constituent, then the waste is not
				  TC-hazardous, and TCLP analysis is not needed. If
total
÷
DF
is equal to
				  or greater than the TCLP regulatory limit for any constituent, then the waste
				  may be, but is not necessarily, a hazardous waste. In this case, full TCLP
				  testing for the constituent(s) in question is required to make that
				  determination.
TCLP analysis is done by extracting the waste with a mild
				  aqueous acid. The fraction of the waste recovered as solid upon filtration of a
				  sample of the waste (i.e. % wet solids - see SW-846, Method 1311, section 7.1) determines the volume of extractant to
				  be used (see SW-846, sections 7.2 and 7.3 ). To the extent that filterable
				  liquid is present in the waste, the extractant volume to be used is lessened.
Each unit (e.g. gram) of non-liquid waste requires the
				  addition of twenty times its mass of extractant. Thus each gram of liquid
				  filterable from the waste (and eventually added back to the final extract)
				  lessens the volume of the extract by approximately nineteen grams (20 grams-1
				  gram=19 grams). As a result, the final volume in which all the extractable
				  constituents are dissolved varies with the liquid content of the waste, and the
				  "dilution" of the constituents from the waste varies. At one extreme, in the
				  case of a waste with no filterable liquid, the mass of final extract is twenty
				  times the mass of the original sample, resulting in a twenty-fold "dilution".
				  At the other extreme, when the entire sample is a filterable liquid, the
				  dilution factor is one-fold; the "extract" (the liquid) is not diluted. Such a
				  dilution factor may be applied to the results of a totals analysis to estimate
				  the maximum possible TCLP extract constituent concentrations for that specific
				  waste. For this purpose, the percent filterable solids in a separate sample
				  must be determined, and the appropriate dilution factor then determined.
The TCLP Method 1311 should be consulted for details.