To start simply, it's certainly possible to prove that a disk installed with a base install of an OS (and then never touched) contains no encrypted volumes if all of the remaining blocks are empty. Every file can be compared to a known good copy and if there's no other data anywhere on the disk then there can't be anything hidden on it.
From there it's a case of proving that each bit of extra data on this disk relates to a file available under the OS or a fragment of such a file (now deleted). This gets progressively harder the more the disk has been used.
It impossible to deny this when you have a GB+ sized area of unpartitioned data (or unmounted partition) containing seemingly random noise. Or a similar GB+ sized file that you cannot demonstrate to be something benign by unpacking/decrypting/etc. "It's a file of random noise I generated" is going to set off the alarm bells.
Am I wrong or outdated on this?
So in that framework "stored somewhere" is a long ways from "You can characterize the contents of a known drive".