ASP Environmental Management 5 — Questions and Answers
Question 1: Under CERCLA (Superfund), which party can be held liable for cleanup costs at a contaminated site even if they properly disposed of waste according to regulations at the time?
- Only the current property owner
- Any potentially responsible party including past owners, operators, and waste generators (Correct answer)
- Only parties that violated environmental regulations
- Federal contractors exclusively
Correct answer: Any potentially responsible party including past owners, operators, and waste generators
CERCLA imposes strict, joint and several liability on all PRPs — current owners, past owners, operators, arrangers, and transporters — regardless of regulatory compliance at the time of disposal.
Question 2: A facility's stormwater runoff from an industrial site must be managed under which specific Clean Water Act program?
- Safe Drinking Water Act underground injection control
- NPDES Industrial Stormwater Permit program (Correct answer)
- RCRA corrective action program
- EPCRA Tier II reporting
Correct answer: NPDES Industrial Stormwater Permit program
Industrial facilities disturbing stormwater must obtain an NPDES stormwater permit (often a general permit) and implement a Stormwater Pollution Prevention Plan (SWPPP).
Question 3: The 'bubble concept' under the Clean Air Act allows a facility to:
- Exempt new emission sources from permitting if total facility emissions stay below thresholds (Correct answer)
- Trade emission allowances with facilities in other states
- Self-certify compliance without EPA inspection
- Increase stack height to dilute pollutants
Correct answer: Exempt new emission sources from permitting if total facility emissions stay below thresholds
The bubble concept treats an entire plant as a single emission source, allowing internal emission offsets so that new or modified sources don't trigger NSR permitting as long as net facility emissions don't increase.
Question 4: Which environmental management tool uses a 'cradle-to-grave' approach to evaluate the total environmental impact of a product or process?
- Environmental Impact Assessment (EIA)
- Life Cycle Assessment (LCA) (Correct answer)
- Risk-Based Corrective Action (RBCA)
- Material Safety Data Sheet (MSDS) review
Correct answer: Life Cycle Assessment (LCA)
Life Cycle Assessment quantifies environmental impacts across all stages of a product's life — from raw material extraction through production, use, and end-of-life disposal.
Question 5: Under the Resource Conservation and Recovery Act (RCRA), the land disposal restrictions (LDRs) program primarily requires that hazardous wastes:
- Be landfilled only in double-lined facilities regardless of treatment
- Meet specific treatment standards before land disposal (Correct answer)
- Be incinerated rather than buried under all circumstances
- Obtain state approval within 60 days of generation
Correct answer: Meet specific treatment standards before land disposal
LDRs prohibit land disposal of hazardous wastes until they have been treated to meet EPA-specified technology-based or concentration-based treatment standards.
Question 6: A safety professional identifying that a facility's boiler emissions require a Title V operating permit under the Clean Air Act should recognize that Title V applies to:
- Any source emitting more than 1 ton per year of any air pollutant
- Major sources emitting above threshold quantities of regulated air pollutants (Correct answer)
- Area sources in non-attainment zones exclusively
- Mobile sources and fleet vehicles only
Correct answer: Major sources emitting above threshold quantities of regulated air pollutants
Title V permits are required for major sources, generally those emitting 100 tons/year or more of a regulated pollutant (lower thresholds apply in non-attainment areas and for HAPs).
Question 7: When conducting an environmental audit, the primary distinction between a compliance audit and a management system audit is that a management system audit evaluates:
- Whether specific regulatory limits are being met
- The effectiveness of the organization's processes for achieving environmental objectives (Correct answer)
- Laboratory analytical data for soil and water samples
- Financial liability for past contamination
Correct answer: The effectiveness of the organization's processes for achieving environmental objectives
A management system audit assesses whether the EMS is properly implemented and effective at achieving goals, whereas a compliance audit checks adherence to specific legal requirements.
ASP Environmental Management 5
Under CERCLA (Superfund), which party can be held liable for cleanup costs at a contaminated site even if they properly disposed of waste according to regulations at the time?