The Generator Improvements Rule created new regulations at 40 CFR 262, subpart L known as Alternative Standards for Episodic Generation.  These new regulations allow very small quantity generators of hazardous waste (VSQG) and small quantity generators of hazardous waste (SQG) to periodically exceed the thresholds for hazardous waste generation of their status (100 kg/mo and 1,000 kg/mo, respectively) without a change to their generator status.

In earlier articles I identified and explained the requirements for compliance with these new regulations for each applicable generator status.

• Read: Requirements for Episodic Generation of Hazardous Waste at a Very Small Quantity Generator
• Read: Requirements for Episodic Generation of Hazardous Waste at a Small Quantity Generator

Both a VSQG and SQG are limited to one episodic event per calendar year, unless a petition is granted by EPA under 40 CFR 262.233.

The purpose of this article is to explain the requirements of 40 CFR 262.233 for a very small quantity generator and a small quantity generator of hazardous waste to petition the EPA for one additional episodic event in a calendar year. (more…)