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Storage/transfer activity

What is storage/transfer?

Storage/transfer means a dangerous waste handling activity, (not including treatment, recycling, or disposal), that may involve the permitted storage of a dangerous waste before its final management. Storage/transfer can happen on-site or off-site. It can include sorting, consolidating, and/or re-packaging of dangerous wastes received from off-site for management or transport. Examples of storage/transfer activities include:

• Sorting lab packs received from generators to identify the amounts and designation of the various items, before re-packaging of the lab pack's contents for transport to another TSDR;
• Consolidating waste in a container or tank to simplify transport or reduce transport costs to another TSDR; and
• Crushing miscellaneous waste containers for more compact and efficient transport to another TSDR.

Assign waste streams sent off-site or received from off site for storage/transfer Management Method Code H141.

How to report storage/transfer on the GM Form

A generator sending waste off-site to a facility, such as a broker, that conducts storage/transfer activity on the waste will report:

• B-4-ii Management Method Code: Enter H141 for storage/transfer.
• B-5-vi Management Method Code: Enter H141 for storage/transfer.

A TSDR will report the generation of a waste stream it received as a storage/transfer waste when it is shipped off-site for management. The TSDR will report:

• A-7 Source Code: Enter G61 for storage/transfer.
• A-9 Origin Code: Enter “iv” for a storage/transfer waste stream received from off-site that was not treated, recycled, or disposed on-site before being shipped off-site.

How to report storage/transfer on the WR Form

A TSDR that receives waste from off-site for storage/transfer activity will report:

• B.9-vi Management Method Code: Enter H141 for storage/transfer.