Re-evaluating the TCLP's Role as the Regulatory Driver in the Management of Municipal Solid Waste Incinerator Ash

Up to 30% of the municipal solid waste (MSW) that is incinerated for energy recovery ends up as MSW incinerator (MSWI) ash. In light of the large volume of MSWI ash and the expenses and regulatory burden if this ash were managed as a hazardous waste, US MSWI facilities place great emphasis on ensuring MSWI ashes pass the toxicity characteristic leaching procedure (TCLP). The focus on passing the TCLP has the unintended consequence of making recycling more difficult and arguably making the ash less benign. This policy analysis examines current US MSWI ash management practices in relation to the TCLP, and discusses the role of the TCLP as a regulatory driver in the management of MSWI ashes. A review of existing information, example data, and common MSWI ash management practices provide insight into potential issues with the current approach and opportunities for alternative directions.