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What is episodic generation?
When a very small quantity generator (VSQG) or small quantity generator (SQG) of hazardous waste has an event that generates enough waste to push them into a higher generator category, this is known as episodic generation. Because higher generator categories have additional and/or more-stringent requirements, it is considerably more burdensome to manage hazardous waste under the higher requirements. This is not an issue for large quantity generators (LQGs) because they already must comply with the most-stringent generator requirements.
Fortunately, under Part 262, Subpart L, VSQGs and SQGs may manage episodic hazardous waste without counting it towards their generator category. For planned events (e.g., scheduled maintenance), you must notify at least 30 days in advance; for unplanned events (e.g., spills), notification is required within 72 hours of the event. [§262.232(a)(2) (VSQGs) and §262.232(b)(2) (SQGs)] The episodic waste must be must be: 1) labeled “Episodic Hazardous Waste,” 2) managed in units meeting standards similar to central accumulation areas (CAAs) for SQGs, and 3) manifested offsite within 60 days of the start of the event. [§262.232(a)(4) (VSQGs) and §262.232(b)(4) (SQGs)] Only one episode is allowed a year, but generators may petition for a second as long as it is the opposite type of the first (i.e., planned or unplanned). [§262.233(a)] Not every state has adopted Subpart L, so check with your state agency first. Our website has additional compliance morsels and much more.
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