Very Small Quantity Generators (VSQGs) and Small Quantity Generators (SQGs) need to monitor the volume of hazardous waste their facilities generate each month to make sure that they do not exceed allowed limits. An event such as the removal of a chemical storage tank, a demolition project, a spill or a natural disaster that generates hazardous waste could quickly cause a facility to exceed their monthly limits.
Some facilities are accustomed to fluctuating between generator statuses. When this is the case, most will operate under the more stringent SQG or LQG regulations at all times because this simplifies training requirements and ensures that the facility is always compliant. But, for VSQGs or SQGs who traditionally operate only under the regulations that apply to their generator status, an infrequent event that generates a higher than allowable amount of hazardous waste could cause them to be non-compliant.
The Environmental Protection Agency (EPA) recognized this and created a special set of regulations for VSQGs and SQGs in this situation. Any circumstance, planned or unplanned, that does not occur as part of normal operations and causes a VSQG or SQG to exceed their monthly hazardous waste generation limit is called an “episodic event.” The EPA has established a special set of regulations for episodic events that allows facilities to maintain their current generator status if an episodic event occurs.