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Extended Storage

The following guidelines will help you report extended storage of dangerous wastes on the GM form and the WR form. This does not apply to generators doing routine waste accumulation on-site. Refer to the definition of Accumulation for more information.

What is extended storage?

Extended storage occurs when a TSDR generates or receives from off-site a dangerous waste that is then placed into on-site permitted storage during the current reporting year for a period of time that will extend beyond the next reporting year. It lasts a minimum of two reporting years (i.e., the waste enters storage during one reporting year and does not emerge until after the next reporting year).

Example: A TSDR places a dangerous waste into on-site permitted storage during the current (e.g., 2003) reporting year and anticipates that the waste will remain in storage throughout the next reporting year, (e.g., 2005), so the earliest time that the waste would emerge from storage is sometime during the 2005 reporting year. In this example, the waste will have been in permitted storage for a minimum of two reporting years (entering in 2003 and continuing in 2005). This constitutes extended storage.

TSDRs should use their best judgment to decide when storage becomes extended storage. If a TSDR decides to correct previous Annual Report(s) for waste in extended storage, then they should contact Ecology for instructions on amending their reports.

This definition of extended storage is only for the purpose of reporting dangerous waste generation and management activities in the context of the Annual Report forms. The definition is not intended to serve any other regulatory purpose, nor does it alter any definitions set forth in Chapter 173-303 WAC.

Who does this apply to?

Facilities with a RCRA storage permit should review this information before completing their Annual Report forms.

TSDRs that generate dangerous waste and place it into extended storage on-site should review the section, How to report extended storage of generated waste.

TSDRs that receive dangerous waste from off-site and place it into extended storage should review the section, How to report extended storage of waste received.

How to report extended storage of generated waste

The first year extended storage begins report generated waste on the GM form:

• B-2 Waste Management Activities, Check box for On-site management.
• B-3 Waste Management Activities, Enter Management Method Code H142.
• Be sure to complete the rest of the form as appropriate.

The year extended storage ends report generated waste on the GM form:

• Use the same waste stream description and codes as on the original GM Form from the year the waste entered extended storage.
• A-7 Source Code, Enter G61.
• A-9 Origin Code, Check box “iv.”
• A-9.a. Management Method Code, Enter H142.
• B-5. vi. Management Method Code, Enter H142.

How to report extended storage of waste received

The first year extended storage begins report waste received on the WR form:

• B. 9 Waste Management Activities, Enter individual shipments of waste received for extended storage.
• B. 9 vi Management Method Code, Enter H142
• Be sure to complete the rest of the form as appropriate.

The year extended storage ends report waste received on the GM form:

• Use the same waste stream description and codes as on the original WR Form from the year the waste received entered extended storage.
• A-7 Source Code, Enter G61
• A-9 Origin Code, Check box “iv”  A-9.a. Management Method Code, Enter H142
• B-5. vi. Management Method Code, Enter H142