A question to my website on April 29, 2016:

My question is: If your waste is considered a haz waste due to one chemical determined by the TCLP process. Do we count the weight of the chemical in the waste or the total weight of the waste that determines how much you generate. Thanks.

My reply later that same day:

If a representative sample of a waste is analyzed by TCLP and determined to have a leachable toxin above the regulatory threshold, then the entire waste from which the representative sample was derived is assigned the applicable hazardous waste code.  Therefore, the entire weight of the waste – not just the weight of the toxin in the waste – is used for the purpose of determining hazardous waste generation and the hazardous waste generator status.