For an effective field theory in the background of an evaporating black hole with spherical symmetry, we consider non-renormalizable interactions and their relevance to physical effects. The background geometry is determined by the semi-classical Einstein equation for an uneventful horizon where the vacuum energy–momentum tensor is small for freely falling observers. Surprisingly, after Hawking radiation appears, the transition amplitude from the Unruh vacuum to certain multi-particle states grows exponentially with time for a class of higher-derivative operators after the collapsing matter enters the near-horizon region, despite the absence of large curvature invariants. Within the scrambling time, the uneventful horizon transitions towards a firewall, and eventually the effective field theory breaks down.