What is the proper way to handle Petroleum Products (i.e., oils) for Method 1311 (TCLP)? We prefer to handle these as totals because we do not want to contaminate our ZHEs and pressure filtration apparatus with oil. However, we get some resistance from clients that feel we are not handling their samples by the regulatory procedure.
Waste oils need to be characterized if they will be disposed of instead of being recycled.
It is absolutely acceptable to analyze the total fraction in oil samples to determine if they are hazardous. However, the results must be properly interpreted. For oil that passes through a filter as described in the method, the total concentrations must be compared DIRECTLY to the TCLP limits. For oil that does NOT pass through the filter, it is considered a solid and the total concentrations can be divided by 20 in order to compare to the TCLP limits.
Here is a more detailed description of the steps to follow:
First, determine if the waste passes through a filter according to Section 7.1.1 of EPA Method 1311. If the waste passes through the filter, treat the filtrate as the TCLP sample, perform all appropriate determinative methods directly on this sample (diluted as necessary for analysis), and compare the results (corrected for any dilution) directly to the TCLP limits given in Table 7‐1 of Chapter 7.
According to Section 7.1.2, if the percent solids are greater than 0.5% of the sample, the unfilterable portion is treated as a solid. Caution should be taken when attempting to dry waste samples that may be flammable. The unfilterable material can either be processed through TCLP as a solid or a total analysis can be performed on the material (i.e., divide the total result by 20 for comparison to TCLP limits). For details on how to convert total results to a number for comparison to TCLP limits, see the RCRA FAQ on this subject: https://waste.zendesk.com/hc/en-us/articles/217452377-Can-totals-analysis-be-used-in-lieu-of-the-TCLP-for-determining-the-toxicity-characteristic-
If the totals results corrected as described in the link above are below the TCLP limits, the waste can be considered nonhazardous. If the corrected total results exceed the TCLP limits, the sample can be considered hazardous. In order to demonstrate that such a sample (where total results exceed TCLP limits) is NOT hazardous, it would need to be carried through the TCLP procedure as a solid to determine if the leachate yields results less than the TCLP limits.
Following is a web link to an older reference document titled, Technical Assistance Document for Complying with the TC Rule and Implementing the Toxicity Characteristic Leaching Procedure (TCLP) that is quite comprehensive: http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P1007NTD.txt.