McMorsel: The RCRA "Divide-by-20 Rule."

Learn math the McCoy way.

Would you like to reduce your waste analytical costs? Skip the TCLP. Did you know that when a waste is 100% physically solid, the total concentration of a regulated constituent may be divided by 20? Once that calculation is done, compare the result to the regulatory limit for that constituent as identified in §261.24. [RO 11721, 13563, 13647]. If the calculated value is below the limit, document your knowledge that the waste cannot be hazardous. Run a TCLP only when the calculated value is above the regulatory limit. The savings will add up because TCLP testing is expensive compared to just testing for totals. Visit our our website for more compliance morsels.

McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.