TCLP Criteria Explained: How Hazardous Waste Is Determined Under RCRA
The Toxicity Characteristic Leaching Procedure (TCLP) is a regulatory test used to determine whether a waste is classified as hazardous due to its potential to leach toxic contaminants into the environment. The TCLP criteria—specifically the regulatory concentration limits established by the U.S. Environmental Protection Agency (EPA)—form the basis for this determination under the Resource Conservation and Recovery Act (RCRA).
Understanding TCLP criteria is essential for waste generators, environmental consultants, and disposal facilities to ensure regulatory compliance and environmental protection.
What Are TCLP Criteria?
TCLP criteria refer to the maximum allowable concentrations of specific contaminants in the leachate generated during TCLP testing. These limits are established in 40 CFR §261.24, Table 1 and represent thresholds above which a waste is considered hazardous.
If the concentration of any one contaminant exceeds its regulatory level, the waste exhibits the toxicity characteristic and must be managed as hazardous waste under RCRA Subtitle C.
Regulatory Basis for TCLP Criteria
The EPA developed TCLP criteria to simulate a worst-case landfill scenario in which waste is exposed to acidic conditions similar to municipal solid waste landfill leachate. The goal is to determine whether contaminants could migrate from the waste into groundwater at levels that pose a risk to human health or the environment.
Key regulatory references include:
- 40 CFR Part 261.24 – Toxicity Characteristic
- EPA Method 1311 – TCLP test method
- RCRA Subtitle C – Hazardous waste management requirements
TCLP Contaminant Categories
The TCLP criteria apply to 40 regulated contaminants, grouped into four main categories:
1. Metals (8)
Commonly associated with industrial wastes, ash, sludges, and contaminated soils.
Examples include:
- Arsenic (D004)
- Cadmium (D006)
- Chromium (D007)
- Lead (D008)
- Mercury (D009)
2. Volatile Organic Compounds (VOCs)
Often found in solvents, fuels, and chemical manufacturing wastes.
Examples include:
- Benzene (D018)
- Chloroform (D022)
- Tetrachloroethylene (D039)
3. Semi-Volatile Organic Compounds (SVOCs)
Typically associated with combustion byproducts, resins, and coal tar wastes.
4. Pesticides and Herbicides
Historically used in agriculture and pest control, often present in legacy wastes.
TCLP Regulatory Levels (Selected Examples)
| Contaminant | EPA Waste Code | Regulatory Level (mg/L) |
|---|---|---|
| Arsenic | D004 | 5.0 |
| Barium | D005 | 100.0 |
| Cadmium | D006 | 1.0 |
| Chromium | D007 | 5.0 |
| Lead | D008 | 5.0 |
| Mercury | D009 | 0.2 |
| Benzene | D018 | 0.5 |
| Chlordane | D020 | 0.03 |
| Tetrachloroethylene | D039 | 0.7 |
These values represent leachate concentrations, not total contaminant content in the waste.
How TCLP Criteria Are Applied
Step 1: Conduct TCLP Testing
The waste is extracted using an acidic solution to simulate landfill leaching conditions.
Step 2: Analyze the Leachate
The extracted liquid is analyzed using EPA-approved analytical methods.
Step 3: Compare Results to Regulatory Limits
Measured concentrations are compared directly to TCLP criteria in 40 CFR §261.24.
- Below all limits → Waste does not exhibit toxicity characteristic
- Above any limit → Waste is hazardous and assigned a D-code
Important Clarifications About TCLP Criteria
- Failing one parameter is enough: Only one exceedance is required for hazardous classification.
- Passing TCLP does not mean “non-toxic”: It only means the waste does not meet RCRA toxicity criteria.
- TCLP is not a total metals test: It evaluates leachable contaminants, not total concentrations.
- Landfill-specific model: Results apply primarily to municipal landfill disposal scenarios.
Common Compliance Challenges
- Improper sample preparation or extraction fluid selection
- Using TCLP results for purposes beyond RCRA classification
- Misinterpreting results when concentrations are near regulatory limits
- Assuming TCLP is unnecessary based solely on process knowledge
Alternatives and Supplemental Evaluations
In some cases, other tests may be used alongside or instead of TCLP:
- Total Constituent Analysis – To screen wastes before TCLP testing
- SPLP (EPA Method 1312) – Simulates rainwater leaching
- WET Test – Required for California hazardous waste determinations
- Risk-Based Assessments – Used for site-specific disposal decisions
Why TCLP Criteria Matter
TCLP criteria serve as a regulatory safeguard, ensuring that wastes capable of releasing dangerous levels of toxic contaminants are properly controlled. By establishing clear, enforceable thresholds, the EPA provides a consistent framework for hazardous waste classification across industries and states.
Conclusion
TCLP criteria are the cornerstone of RCRA’s toxicity characteristic determination. Understanding how these limits are defined, applied, and interpreted is critical for maintaining compliance, avoiding enforcement actions, and protecting groundwater resources. Proper application of TCLP criteria ensures that hazardous wastes are identified early and managed responsibly from generation to final disposal.
For complex waste streams or borderline results, consultation with experienced environmental professionals or accredited laboratories is strongly recommended.


















