Under EPA’s RCRA law, if there is a known or documented source of release of a listed
hazardous compound detected in soil at any concentration – for example, from a leaking tank, or leaking drums of stored solvent, or from a known surface spill – then any of these conditions would cause the soil to be classified as a listed hazardous waste.
If the source of release is unknown but the soil fails the TCLP, then it would be classified as a characteristically hazardous waste.
Such soils can also carry a combination RCRA waste code, such as F002/D039 when classified as both listed hazardous as well as characteristically hazardous.