Module 3 Closure

While I would much rather teach fundamental principles than laws and regulations, in the hazardous waste field all our actions and decisions are constrained by laws and regulations.  Most prominent is RCRA.  Some of the very basic terminology in RCRA is confusing because is overlaps everyday usage.  Let’s define characteristic, listed, toxicity, and TCLP. 

A RCRA listed waste is a waste on one of the four lists: U, P, F, and K.  If a waste is on one of those lists, it is a listed waste. 

A RCRA characteristic waste is a waste that has one of four characteristics: ignitability, reactivity,  corrosivity, or toxicity.  The last needs some explanation.

The RCRA toxicity characteristic has a narrow definition.  (We remember what Paracelsus said, everything is toxic, if you get enough of it.) So the toxicity characteristic refers to a test, TCLP [“tea clip”], toxicity characteristic leaching procedure.  In that test, a sample of solid (and usually dry) waste is placed in a solution of mild acid (think vinegar) for a while and later the solution is drained.  If the solution has greater than a stated concentration of contaminant, the sample “fails the TCLP” and is judged to have the “toxicity characteristic.”  The list of those concentrations is a table with only 40 or so chemicals listed.