An “episodic event” is defined as “An activity or activities, either planned or unplanned, that does not normally occur during generator operations, resulting in an increase in the generation of hazardous wastes that exceeds the calendar month quantity limits for the generator’s usual category.” Examples of planned episodic events include tank clean-outs, short-term construction projects, site remediation, and removal of excess chemical inventories. Unplanned episodic events would include production process upsets, product recalls, accidental spills, or an “act of nature,” such as a tornado, hurricane, or flood. Very small quantity generators (VSQGs) and small quantity generators (SQGs) are each limited to one episodic event per calendar year unless a petition is granted by the state environmental regulatory agency.

Notification

VSQGs and SQGs must notify the state environmental regulatory agency using EPA Form 8700-12 at least 30 calendar days before initiating a planned episodic event. For an unplanned episodic event, notification must be within 72 hours after the unplanned event has occurred or as soon as possible by phone, e-mail, or fax and followed up with submission of EPA Form 8700-12.

On-Site Accumulation

As the waste is accumulated on-site, VSQGs and SQGs must comply with the following hazardous waste management conditions.

Units to accumulate waste. The waste must be accumulated in containers or tanks. Using drip pads or containment buildings is prohibited.

Labeling. Both containers and tanks must be labeled or marked with the words “Episodic Hazardous Waste.”

Containers. In addition, containers must be labeled or marked with words that identify the hazards of the contents. Containers must be in good condition, compatible with the hazardous waste contained, and kept closed except to add or remove waste.

Tanks. Tanks used must be in good working condition, be compatible with the hazardous waste contained, and have procedures to prevent overflow. Tanks must be inspected at least once each operating day to ensure all applicable discharge control equipment and drainage systems are in good working order and the tank is operated according to its design. You must use inventory logs, monitoring equipment, or other records for tanks to identify:

• The contents of the tank and its associated hazards
• The date the episodic event begins on

Shipment of Waste Off-Site

To ship the episodic hazardous waste off-site, you must use a hazardous waste manifest and hazardous waste transporter and ship the episodic waste to a Resource Conservation and Recovery Act, or RCRA-designated facility within 60 calendar days from the start of the episodic event.

Recordkeeping

The following records of an episodic event must be completed and maintained:

• The beginning and end dates of the episodic event;
• A description of the episodic event;
• A description of the types and quantities of hazardous wastes generated during the event;
• A description of how the hazardous waste was managed;
• Names of the hazardous waste transporters and the RCRA-designated facility that received the waste; and
• If applicable, the approval letter of a petition to add an episodic event in a calendar year or to add a 30-day extension to the 60-calendar-day period already approved.

These records must be kept for 3 years from the end date of the episodic event.
It’s very important to follow these episodic waste requirements because failure to meet these specified conditions will trigger immediate loss of a VSQG or SQG status. The consequence would be that the facility would be deemed the operator of a nonexempt storage facility unless you immediately complied with the requirements of the next-largest generator category, such as an SQG for a VSQG or a large quantity generator, or LQG, for an SQG.