What Is an Episodic Event?

by Karen

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.

Planned episodic events include:	Unplanned episodic events include:
Regular maintenance Tank cleanouts Short-term projects Removing excess inventory	Production process upsets Product recalls Accidental spills Acts of nature

There are limits to this perk, however, and facilities must follow a special set of rules to claim the episodic event exemption. Facilities may only have one episodic event per year in most cases, but they may petition for a second event in some circumstances.

Keep reading for specific requirements that VSQGs and SQGs must following when declaring for an episodic event.

Very Small Quantity Generator Requirements [40 CFR 262.232(a)]

A VSQG may maintain their generator status during an episodic event by:

Notifying the EPA no later than 30 calendar days prior to a planned event or within 72 hours of an unplanned event, using Form 8700-12
Obtaining an EPA Identification Number, using Form 8700-12
Accumulating hazardous waste in properly marked and closed containers or tanks
Complying with manifesting requirements when wastes are shipped offsite
Shipping waste within 60 calendar days from the start of the episodic event
Maintaining records for 3 years from the end of the episodic event that describes the event, the type and quantity of hazardous waste generated, a description of how the waste was managed and the name of the transporter
Keeping a copy of the approval letter from EPA, if they petitioned for an additional episodic event within one calendar year

Small Quantity Generator Requirements [40 CFR 262.232(b)]

A SQG may maintain its generator status during an episodic event by:

Notifying the EPA no later than 30 calendar days prior to a planned event or within 72 hours of an unplanned event, using Form 8700-12
Having or obtaining an EPA Identification Number, using Form 8700-12
Accumulating hazardous waste in properly marked and closed containers or tanks
Treating or shipping hazardous waste within 60 calendar days from the start of the episodic event
Maintaining records for 3 years from the end of the episodic event that describes the event, the type and quantity of hazardous waste generated, a description of how the waste was managed and the name of the transporter

Petitions to Manage One Additional Episodic Event per Calendar Year [40 CFR 262.233]

A VSQG or SQG that has had a planned episodic event may petition for a second unplanned episodic event within the same calendar year if they do so within 72 hours of the unplanned event. Petitions must be made to the Regional EPA Administer and must include:

Reason why an additional event is needed
Nature of the event
Time that will be needed to manage the hazardous waste generated by the event
Information about the previous episodic event, including the nature of the event and how it was managed

Reports can be made electronically or by mail. If the petition is granted, the facility must maintain records for 3 years from the end date of the episodic event.

By allowing VSQGs and SQGs to maintain their generator status while managing certain hazardous waste situations as episodic events, the EPA provides a practical solution that eases compliance burdens for facilities while still protecting public health and the environment.

Want to learn more about hazardous waste handling? Check out our RCRA 101 series, which guides you through everything hazardous waste from how to make waste determinations to what generator status you belong to.

TAGS: Hazardous Waste

Very Small Quantity Generator Requirements [40 CFR 262.232(a)]

Small Quantity Generator Requirements [40 CFR 262.232(b)]

Petitions to Manage One Additional Episodic Event per Calendar Year [40 CFR 262.233]

Karen

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