Episodic Generation

In the past, RCRA rules lacked the flexibility to address an "episodic" generation event that resulted in a temporary increase in the generation of hazardous waste that exceeded the calendar-month quantity limits for the generator's usual category. Such episodic events may be planned, such as periodic tank cleanouts or a short-term demolition project; or they may be unplanned, such as a natural disaster or accidental spill. Previously, generators had to comply with a more stringent set of regulations for the short period of time when they were generating higher amounts of hazardous waste, which was challenging for smaller generators.

Now, the RCRA rules include provisions that address episodic generation events. VSQGs and SQGs may take advantage of a new episodic generation provision that allows these generators to maintain their usual category during a period of non-routine generation and thereby avoid the increased requirements of a higher generator status. To take advantage of this new provision, generators must comply with a streamlined set of requirements set forth in 40 CFR 262, Subpart L.

To learn more about RCRA safety standards visit our RCRA Refresher Online Training web page.