How long may a large quantity generator accumulate hazardous waste on site without a RCRA permit?
A large quantity generator may accumulate hazardous waste on site for 90 days or less without a permit or interim status under 40 CFR 262.17, provided the accumulation conditions are met.
The answer
The 90-day window
40 CFR 262.17(a) allows a large quantity generator to accumulate hazardous waste on site for 90 days or less without a permit and without having interim status, as long as the generator complies with the listed conditions. Those conditions include proper containment, labeling and dating of containers, and compliance with preparedness and emergency procedures.
Why the deadline matters
The 90-day period is a condition of the exemption from permitting. A generator that holds waste beyond 90 days without an extension becomes an operator of a storage facility subject to the permit requirements that section 262.17 otherwise avoids.
The judged input
What the AI drafted
Submitted to the judgeThis is an excerpt from a draft permit-compliance opinion — the kind of work product a lawyer generates with a legal-AI drafting tool, then has to stand behind. Kingsfield does not write it; it rules on the citations the model put in it. This draft cites two authorities; one of them is wrong.
The judge ruled on every citation as the draft used it — it accepted 40 CFR 262.17(a) and rejected 40 CFR 261.31. Here is why.
The verdict
How Kingsfield ruled
Ruled 2026-06-23Each citation in the draft above was submitted to the Kingsfield judge and ruled against the primary-law corpus — Accept, Reject, or Inconclusive, per citation. These are live verdicts, not editorial. Each card shows the claim the draft made and the verbatim authority the verdict was rendered against.
The draft claimed: A large quantity generator may accumulate hazardous waste on site for 90 days or less without a permit and without having interim status, provided the generator complies with the listed accumulation conditions.
“Accumulation. A large quantity generator accumulates hazardous waste on site for no more than 90 days, unless in compliance with the accumulation time limit extension or F006 accumulation conditions for exemption in paragraphs (b) through (e) of this section. The following accumulation conditions also apply:”
Cite found; proposition supported by the cited text.
The draft claimed: Section 261.31 is the regulation that sets the 90-day on-site accumulation period for a large quantity generator of hazardous waste.
Cite found, but the cited text does not support the claim. 40 CFR 261.31 lists hazardous wastes from non-specific sources (the F-list) and identifies which wastes are listed; the 90-day generator accumulation period is set by 40 CFR 262.17. Regenerate with the correct authority.
Run your own work through the judge
Kingsfield rules on every citation, quote, and proposition your AI produces, against the primary law we cover. Accept, Reject, or Inconclusive, per citation, with a signed Audit Capsule.
Connect the Judge See the architectureThis page is legal information, not legal advice, and does not create an attorney-client relationship. The draft shown is an illustration of a typical AI answer; verdicts reflect the cited authority in the Kingsfield corpus as of the ruling date shown above.