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How to Use the New RCRA Relief for Episodic Events

Posted on 4/8/2019 by Noah Polsky, RCRA & Hazmat Instructor

Hazardous waste can have a severe impact on human health and the environment. As a result, there are hundreds of pages of complicated regulations that hazardous waste generators have to contend with in order to properly manage and dispose of their waste. Fortunately, EPA’s November 2016 Hazardous Waste Generator Improvements Rule (GIR) reorganized parts of the hazardous waste regulations to close gaps in understanding and help generators confidently know what is expected of them.
One topic of the GIR that may benefit many generators is episodic generation. It allows certain types of generators to maintain a “lower” generator status, even if they have an “episode” of waste generation that would normally push them into a higher generator status. Before the GIR, there were no Federal standards for episodic events; instead, local jurisdictions had independent policies. Now, there is a uniform national standard, which we will explore here.

The GIR also added new requirements that hazardous waste generators must know. Attend the Hazardous Waste Management Workshop near you to stay up to date on EPA’s latest updates to the RCRA requirements.

What Is an Episodic Event?

First, let’s explore what the GIR means by episodic event. According to the regulation, an “episodic event” means
“…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.”
What type of generator might this apply to? The very first sentence in the new regulation states that “This subpart is applicable to very small quantity generators (VSQG) and small quantity generators (SQG) as defined in §260.10 of this chapter.” Why aren’t large quantity generators (LQG) included? It’s simple: LQGs are already the highest status possible for a generator, so there is no risk of being bumped to a higher generator status.

Planned vs. Unplanned Episodic Events

There are two important terms that come up in the definition: “planned” and “unplanned” episodic events.
A planned episodic event means an episodic event that the generator planned and prepared for, including regular maintenance, tank cleanouts, short-term projects, and removal of excess chemical inventory.
This is pretty clear—if a VSQG or SQG knows in advance that there is an upcoming major project or cleanout, it is a planned event.
An unplanned episodic event means an episodic event that the generator did not plan or reasonably did not expect to occur, including production process upsets, product recalls, accidental spills, or “acts of nature,” such as a tornado, hurricane, or flood.
Again, this is clear—an unplanned event could be caused by a natural disaster or something along the lines of “Oops, that 1,000-gallon raw material storage tank just ruptured and spilled all over the place, and now we have to collect and manage everything as hazardous waste.”

EPA Notification, ID Numbers, and Off-site Shipment Requirements

Throughout the new episodic generation subchapter, the rules are outlined for what generators must do before, during, and after an episodic event. Among the most significant requirements are to:
  • Notify the EPA at least 30 days before a planned event, or within 72 hours after an unplanned event.
  • Obtain an EPA ID number (if the generator doesn’t already have one).
  • Finish the event AND ship the episodic waste off site within 60 days of starting the event, whether planned or unplanned.
For all generator requirements pertaining to episodic generation, check 40 CFR 262.232.

Limited to One (or Two) Episodic Events per Year

Typically, a generator is only allowed to have one episodic event per year, whether planned or unplanned. It is possible, though, to have one other episodic event, IF the generator petitions the EPA first. Not only that, but the potential second event must be the OTHER type of event than the first one; this means that if the generator had a planned event, the second event can only be the result of an unplanned event. Similarly, if the generator first had an unplanned event, the second event can only be planned—it is not possible to manage two planned or two unplanned events as episodic in the same year.

Will My State Adopt Relaxed Episodic Generation Rules?

One last important thing to realize is that many parts of the GIR made the Federal regulations more stringent. This means that each state that operates its own hazardous waste program will need to incorporate these changes into its State regulations. However, the option to manage waste under episodic generation is actually a less stringent rule change, which means states can choose whether or not to make it an available option for generators. So, make sure you check your state regulations to see if your state has incorporated episodic generation into its hazardous waste rules.

RCRA Hazardous Waste Management Training Near You

Are you ready for compliance with EPA’s major “Generator Improvements”? One by one, states have started adopting the new hazardous waste standards. The new rules not only re-organized all the RCRA regulations, they also impact episodic generation, satellite areas, container labels, contingency planning, EPA notifications, and more.  
If your state has not adopted stricter contingency planning rules or new container label standards yet—they will soon. Learn what’s new for facilities large and small at the two-day workshop that’s considered the gold standard in hazardous waste management training.
St. Louis April 29–30
Dallas May 1–3 (3-day RCRA + Texas Industrial Waste training)
Houston May 6–8 (3-day RCRA + Texas Industrial Waste training
Pittsburgh May 9–10
Cleveland May 13–14
Detroit May 15–16
Cincinnati  May 16–17

See all 2019 RCRA training workshops.


Tags: episodic event, episodic generation, hazardous waste management, new rules, RCRA

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