From: “John Litton” <littonjt@COLUMB34.DHEC.STATE.SC.US>
To: <bredl@skybest.com >
Cc: <HOUGHMH@columb20.dhec.state.sc.us>
Sent: Wednesday, October 10, 2001 10:02 AM Subject: TCLP -Reply

Dear Mr. Zeller:

The State of South Carolina does follow the Federal Hazardous Waste Program in use of the TCLP to determine when solid wastes have to be managed as hazardous waste due to the toxicity characteristic. It is currently the State's intent to continue use of this test method, but as you are aware, the Federal Program continues to seek to better identify which solid waste streams are of the highest risks. South Carolina does actively follow development of regulation at the federal level and is currently in the process of listing one industrial waste stream that we believe deserving as a 'state specific listed waste.'

Thank you for your interest.

>>> Blue Ridge Environmental Defense League <bredl@skybest.com>
10/08/01 03:55am >>>

Dear Mr. Hough:

I write to ask for information regarding municipal solid waste testing for hazardous materials.

In 1996 the US EPA completed a Hazardous Waste Characteristics Scoping Study to determine whether the tests for hazardous wastes fully protect public health and the environment. The study clearly showed that the federal testing program allows some hazardous wastes to be disposed of as ordinary solid waste. But EPA has not implemented the changes recommended by the Scoping Study.

For example, EPA's regulations require use of the Toxic Characteristic Leaching Procedure (TCLP) to identify wastes that are toxic. Of the hundreds of toxic chemicals that are used by industry, only 43 are subject to the TCLP test. If none of the 43 specific chemicals are found, but other dangerous toxic chemicals are present, the waste is not considered hazardous and is sent to municipal landfills and municipal incinerators.

Does DHEC allow the use of TCLP for solid waste? If so, does it plan to continue to use it? If TCLP is not used, what other means of testing for toxicity are used?

Thank you in advance for responding to these questions.

Louis Zeller
Blue Ridge Environmental Defense League
BREDL@skybest.com