EDIT: Whoops, I think I thought it out wrong. Assuming he doesn't renew the spell during his reign in the Dungeon, Xykon would be a minimum(?) of 26-27.
At the same time, I can't find a reason why Xykon would wait, say, any interval of time after mastering an epic spell. Does the SRD mention a minimum amount of time a sorcerer can learn an epic spell?