The creation of the Episodic Event is one of the best things EPA has ever done for hazardous waste generators. If your facility experiences a situation where a large, out-of-the-ordinary amount of hazardous waste is quickly generated, you can notify your regulators of an Episodic Event, follow a few extra rules, and not have to bump up to a higher generator category.

Something to know up front is that there are two kinds of episodic events:

• Planned Events. These are waste-generating events that you will know about before the waste is generated. An example would be a tank cleaning or a process cleanout that will generate hazardous waste in volumes that would push you over the limits for your generator category. That doesn’t take much for a VSQG since your limit is 220 pounds in a month.
• Unplanned Events. These are unexpected waste-generating events that happen without any forewarning. The most likely event would be a spill that creates lots of waste, or the production of an off-spec batch of material that is hazardous.

Each of these types of events have different requirements for notifications and waste management.