Episodic Events in Nevada

Information Now Available on BEP’s Website

What happens when a very small quantity generator (VSQG) or small quantity generator (SQG) goes over the limit for their generator status and generates more hazardous waste for just a month due to something like a planned annual clean-out or cleaning up an accidental spill? Does the business move up in generator status and need to follow all the rules that apply to the higher generator category? Not necessarily!

The State of Nevada adopted the Subpart L – Alternative Standards for Episodic Generation. (40 CFR 262 Subpart L) in August of 2020. In order to take advantage of the episodic relief provisions, certain conditions must be met and rules followed.

BEP recently posted detailed information on our website that explains the new provisions and how they could apply to an episodic event at your facility. We have also included checklists for unplanned and planned episodic generation events that can be printed and used to help guide you through the process.

The key for taking advantage of the episodic generation event provisions is notification. If you have a planned event for which you will be generating higher amounts of hazardous waste than usual (for example, an annual clean-out), be sure to provide a minimum of 30 days advance notification to NDEP. If you have a spill or other unplanned event that generates large amounts of hazardous waste, be sure to provide NDEP with notification within 72 hours of the unplanned event. Failure to provide the necessary notifications will prevent a facility from being able to take advantage of these provisions.

Have questions about episodic generation and how it applies to your facility? Contact BEP.