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2009-04-13_REVISION - M2008012 (17)
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2009-04-13_REVISION - M2008012 (17)
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Last modified
6/15/2021 5:55:48 PM
Creation date
4/20/2009 2:58:53 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M2008012
IBM Index Class Name
REVISION
Doc Date
4/13/2009
Doc Name
Conversion of application from 110(2) to 112d(1) (part 2)
From
Nuvermco
To
DRMS
Type & Sequence
CN1
Email Name
GRM
Media Type
D
Archive
No
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INCIZEASllVG USE OF THE SPLP BY THE EPA <br />Chemical characterization of a hazardous waste site focuses on two primary approaches. Total <br />waste analyses evaluate the chemical makeup of site materials and are intended to identify the <br />constituents of concern in site soils or sludges. Leachability analyses identify the potential for <br />these constituents of concern to mobilize to the groundwater, thereby increasing their threat to <br />human health and the environment. Until recently, the Environmental Protection Agency (EPA) <br />has specified characterization of hazardous or waste materials through the Toxicity Characteristic <br />Leaching Procedure (TCLP). In fact, the legal definition of a hazardous material is dependant <br />upon the results of TCLP analyses. Recently, however, EPA has been initiating a gradual and <br />unofficial change away from the use of the TCLP for characterizing a waste site. This change <br />has led to the increased use of the Synthetic Precipitate Leaching Procedure (SPLP) for <br />delineation and treatment verification testing. <br />The TCLP, while legally providing the current definition of a hazardous material, was not the <br />original leaching procedure identified by EPA. The original test developed by the EPA for <br />determining whether a waste was hazardous by virtue of its toxicity was the Extraction Procedure <br />Toxicity Test (EP Tox). This test was developed to simulate a worst-case scenario in which the <br />potential hazardous waste would be co-disposed with municipal solid waste in a landfill with <br />actively decomposing material. EPA reasoned that the most likely pathway for human exposure <br />to toxic constituents would be through drinking water contaminated by landfill leachate. <br />Based on the assumptions outlined above, EPA developed the EP Tox test relying on organic <br />acids, simulating those commonly developed during anaerobic degradation occurring in <br />municipal landfills. Through this procedure, materials were identified as being characteristically <br />hazardous based on toxicity. This test was the primary leachability evaluation in use in the <br />industry until 1986 when its successor, the TCLP was introduced. <br />The TCLP extraction procedure was initially proposed by the EPA on 13 June 1986 with the <br />introduction of the Toxicity Characteristics (TC) Rule. By 5 March 1990, the final rule and <br />revision for the extraction procedure was signed by the EPA. The TCLP procedure was designed <br />to simulate the leaching of chemicals by organic acids occurring in sanitary and/or municipal <br />landfills. Therefore, acetic acid, an organic acid is used as the leaching fluid. The TCLP <br />procedure which is found in 40 CFR 268 Appendix I and is identified as analytical method EPA <br />SW-846 Method 1311, is performed through the use of two different leaching fluids. The <br />procedure utilizes two different fluids to account for different buffering capacities in the <br />materials tested. Specifically, Leaching Fluid 91 (LF 1) is deionized water adjusted to a pH <br />value of 4.93 f 0.05 standard units (s.u.) with acetic acid and sodium hydroxide. Leaching Fluid <br />#2 (LF 2) is deionized water adjusted to a pH value of 2.88 f 0.05 s.u. with acetic acid. The <br />leaching fluid used for each sample is determined based on a hydrochloric acid buffering <br />capacity test that is performed prior to the extraction.
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