Storage Prohibition

The final component of the LDR program is the storage prohibition. Before a waste can be treated, it is usually stored in units, such as containers and tanks. These storage units are not intended for the long-term management of waste, and therefore, are not required to provide the same level of protective measures as disposal units. To prevent indefinite storage, U.S. EPA regulations state that if waste storage exceeds one year, the facility has the burden of proving that such storage is being maintained in order to accumulate quantities necessary for effective treatment or disposal. For storage less than one year, U.S. EPA has the burden of proving that such storage is not for the purpose of accumulating quantities necessary for effective treatment or disposal. Generators accumulating waste on sites within their respective accumulation time limits, and transfer facilities temporarily storing manifested shipments of hazardous waste for <10 days, are not subject to this burden of proof requirement.

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