CONSIDER A PLANNED EPISODIC GENERATION EVENT FOR SMALL AND VERY SMALL QUANTITY GENERATORS
Are you planning a spring cleaning at your facility that could involve disposing of hazardous materials? If so, you should consider taking advantage of a new provision in Nevada which allows an annual planned episodic hazardous waste generation event to clean up and dispose of old chemicals, tank residues, and outdated lab chemicals without changing your generator status.
An important rule to follow for a planned episodic generation event is notifying the NDEP 30 days prior to the planned event. The facility will need to obtain an EPA ID number if there is not one assigned. There are several other rules to follow. BEP staff can walk you through the requirements of an episodic event.
Download the planned event checklist to help you get started with the process. Contact BEP at (800) 882-3233, at help@unrbep.org or on through our website. We can work with you to help you decide if a planned episodic generation event is right for your facility.
What is an Episodic Generation Event?
According to the US Environmental Protection Agency (EPA), an episodic event is “an activity that does not normally occur during a generator’s operations and that causes the generator to exceed the threshold for its normal generator category for that month.” See 40 CFR § 262.231.
An episodic event can be planned or unplanned. A clean out of a large amount of old or expired chemicals that will not be used is an example of a planned event. An unplanned event might be a spill of hazardous materials that requires clean up and disposal of hazardous waste above a generator’s monthly status.
Episodic event relief is allowed only once per calendar year unless a facility petitions NDEP for relief a second time. It is important to note, however, the second event cannot be of the same type as the first. For example, if the first event was a planned clean-out, the second event must be unplanned.
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