Limitations of the toxicity characteristic leaching procedure for providing a conservative estimate of landfilled municipal solid waste incineration ash leaching

Limitations of the toxicity characteristic leaching procedure (TCLP) for simulating pollutant leaching from wastes disposed of in full-scale landfills are well understood in the waste management profession; the TCLP solution has a lower pH and greater organic acid content than typical landfill leachate. The TCLP serves its intended regulatory objective, however, as long as a conservative estimate of leaching is provided. Here, we examine TCLP’s ability to represent worst-case leaching conditions for monofilled municipal solid waste incineration (MSWI) ash. A critical examination of TCLP’s applicability to MSWI ash is especially relevant, as ash management at MSWI facilities often centers on passing TCLP, regardless of environmental risk posed by the ash or its recyclability. Multiple batch leaching tests were conducted on different MSWI ash streams: mixed ash, fly ash, and different size fractions of bottom ash. Batch-test results were compared with leachate simulating MSWI ash monofills. The TCLP did not consistently provide the most conservative estimate of leaching, supporting the need to consider alternative methodologies in future regulatory development.

Implications: This paper analyzes the existing hazardous waste regulatory testing requirement for municipal solid waste incinerator (MSWI) ash management to evaluate whether the TCLP serves its intended purpose in providing the most conservative estimate of landfilled MSWI ash. The results will serve as guidance and motivation for policy makers and the regulatory community to reevaluate the TCLP’s application for characterizing MSWI ash leaching in certain disposal scenarios and could promote consideration of alternative testing procedures based upon results of this study. This study serves to promote representative and accurate quantification of leaching risk from MSWI ash.     

Initiatives to reduce lead from electronic devices: evidence of success from the toxicity characteristic leaching procedure

Discarded electronic devices (E-waste) have historically been found to exceed US Toxicity Characteristic hazardous waste thresholds for lead. Research was conducted to assess whether global and national lead reduction initiatives in the past decade translate to reduced toxicity characteristic leaching procedure (TCLP) lead leaching from E-waste. Nine categories of devices were subjected to TCLP and in all devices except one (smoke detectors), mean TCLP lead concentration results decreased by an order of magnitude or more (to levels below regulation thresholds). Mean TCLP lead concentrations decreased from 29.1 mg/L (2000–2005) to 0.224 mg/L (2008+) for cell phones and 1.26 mg/L (2000–2005) to 0.060 mg/L (2008+) for PCs. Most recently manufactured electronic devices (of those types tested here) comply with the definition of non-hazardous waste under US regulations.

Implications: Discarded electronic devices (E-waste) have often been tested as hazardous waste in the US because of lead leaching. Toxicity characteristic leaching procedure (TCLP) testing on more recently manufactured devices reveals that global lead reduction efforts have resulted in newer devices complying with US non-hazardous waste definitions. While these results highlight the success of lead reduction efforts, they raise policy questions regarding how best to incentivize E-waste recycling going forward.