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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, U.S. 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 U.S. 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.

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Limitations of the toxicity characteristic leaching procedure (TCLP) for simulating pollutant leaching from wastes disposed of in full-scale landfills are well understood in the waste management profession; the TCLP solution has a lower pH and greater organic acid content than typical landfill leachate. The TCLP serves its intended regulatory objective, however, as long as a conservative estimate of leaching is provided. Here, we examine TCLP's ability to represent worst-case leaching conditions for monofilled municipal solid waste incineration (MSWI) ash. A critical examination of TCLP's applicability to MSWI ash is especially relevant, as ash management at MSWI facilities often centers on passing TCLP, regardless of environmental risk posed by the ash or its recyclability. Multiple batch leaching tests were conducted on different MSWI ash streams: mixed ash, fly ash, and different size fractions of bottom ash. Batch-test results were compared with leachate simulating MSWI ash monofills. The TCLP did not consistently provide the most conservative estimate of leaching, supporting the need to consider alternative methodologies in future regulatory development. Implications: This paper analyzes the existing hazardous waste regulatory testing requirement for municipal solid waste incinerator (MSWI) ash management to evaluate whether the TCLP serves its intended purpose in providing the most conservative estimate of landfilled MSWI ash. The results will serve as guidance and motivation for policy makers and the regulatory community to reevaluate the TCLP's application for characterizing MSWI ash leaching in certain disposal scenarios and could promote consideration of alternative testing procedures based upon results of this study. This study serves to promote representative and accurate quantification of leaching risk from MSWI ash.

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