From time to time, events happen which cause a generator of hazardous waste to exceed their generation/storage thresholds. The October 2016 revisions to the hazardous waste regulations now incorporate requirements on how hazardous waste will be handled during those events so that the generator will not have to move to a more regulated generation category as a result of the event. These are now defined as "Episodic Events."
Episodic Event = 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 (40 CFR 262.231).
- Planned episodic events include wastes generated by regular maintenance, tank cleanouts, short-term projects, and removal of excess chemical inventory.
- Unplanned episodic events include situations such as production process upsets, product recalls, accidental spills, or ''acts of nature,'' such as tornado, hurricane, or flood.
- A VSQG or SQG is only allowed one episodic event per calendar year unless a petition has been granted by the Regional Administrator.
If a VSQG or SQG has an episodic event (planned or unplanned), it must:
- Have or obtain an EPA identification number
- Notify the EPA no later than 30 days prior to a planned episodic event using EPA Form 8700-12
- Notify the EPA within 72 hours of an unplanned event by phone, email, or fax and followup with EPA Form 8700-12
- Mark or label containers with the following:
- the words "Episodic Hazardous Waste"
- the date on which the episodic event began
- an indication of the contents hazards such as one of the following approaches:
- the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic), or
- hazard communication consistent with the Department of Transportation requirements at 49 CFR 172 subpart E (labeling) or subpart F (placarding), or
- a hazard statement or pictogram consistent with the OSHA Hazard Communication Standard at 29 CFR 1910.1200, or
- a chemical hazard label consistent with the NFPA code 704).
- Mark or label tanks with the following:
- the words "Episodic Hazardous Waste"
- an indication of the contents hazards such as one of the following approaches:
- the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic), or
- hazard communication consistent with the Department of Transportation requirements at 49 CFR 172 subpart E (labeling) or subpart F (placarding), or
- a hazard statement or pictogram consistent with the OSHA Hazard Communication Standard at 29 CFR 1910.1200, or
- a chemical hazard label consistent with the NFPA code 704.
- If using tanks, the VSQG or SQG keeps inventory logs, monitoring equipment or other records to identify the date on which the episodic event began.
- If using tanks, the tanks are inspected at least once each operating day.
- The hazardous waste is manages so as to minimize the possibility of a fire, explosion, or release to the air, soil, or water.
- The VSQG or SQG manifests for and sends the hazardous waste generated from the episodic event to a designated facility within 60 calendar days from the start of the episodic event.
- The VSQG or SQG maintains the following records for 3 yr from the end date of the episodic event:
- 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 as well as the name of the RCRA-designated facility that received the hazardous waste
- name(s) of hazardous waste transporters
- an approval letter from EPA if the generator petitioned to conduct one additional episodic event per calendar year.
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