Episodic Generation

In the past, RCRA rules lacked flexibility to address an "episodic" generation event that resulted in a temporary increase in the generation of hazardous waste exceeding the calendar month quantity limits for the generator's usual category. Such increases in generation may result from a planned event, such as periodic tank cleanout or short-term demolition project, or an unplanned event, such as a natural disaster or spill, that does not normally occur during generator operations. 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, VSQGs and SQGs may take advantage of an episodic generation provision which allows these categories of generators to maintain their usual category during a period of non-routine generation and avoid the increased requirements of a higher generator status. To do so, generators must comply with a streamlined set of requirements set forth in 40 CFR 262 Subpart L.

To learn more about RCRA visit our RCRA Hazardous Waste Safety Online Training web page.