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Status Submitted
Created by Guest
Created on Nov 15, 2026

Ninety-Day Accumulation Clock Register

PROBLEM: A large quantity generator may accumulate hazardous waste on-site without a storage permit for no more than 90 days — with no limit on the amount, only on the time. Exceed the 90 days and the site becomes a treatment, storage and disposal facility subject to full permitting. The clock starts the day accumulation begins, and every container on the pad has its own start date. A facility with a hundred drums has a hundred clocks.

SOLUTION: A ninety-day accumulation clock register: every accumulation container logged with its start date and its 90-day deadline, with containers nearing the limit flagged for shipment — so no drum ever ages into an unpermitted storage facility.

EVIDENCE BASIS: DOCUMENTED — LQGs may accumulate on-site ≤90 days, no quantity limit (40 CFR 262.17(a)); exceeding the limit triggers TSDF permitting; sources: EPA generator summary; legalclarity.org.

Idea priority Low