CARO Environmental Compliance 2 — Questions and Answers
Question 1: Under CERCLA, what is the reportable quantity (RQ) for an anhydrous ammonia release within a 24-hour period?
- 10 pounds
- 100 pounds (Correct answer)
- 500 pounds
- 1,000 pounds
Correct answer: 100 pounds
Ammonia has a CERCLA reportable quantity of 100 pounds released within any 24-hour period.
Question 2: When an ammonia release exceeds the reportable quantity, which federal body must be notified immediately?
- The National Response Center (Correct answer)
- The Department of Transportation
- The Occupational Safety and Health Administration
- The U.S. Fish and Wildlife Service
Correct answer: The National Response Center
CERCLA requires immediate notification of the National Response Center for releases at or above the RQ.
Question 3: EPCRA Section 304 requires that a reportable ammonia release also be reported to which agencies?
- The local fire marshal only
- The State Emergency Response Commission and Local Emergency Planning Committee (Correct answer)
- The EPA regional administrator only
- The facility's insurance carrier
Correct answer: The State Emergency Response Commission and Local Emergency Planning Committee
EPCRA Section 304 requires notifying the SERC and LEPC for affected areas in addition to federal reporting.
Question 4: What is the EPA Risk Management Program (RMP) threshold quantity for anhydrous ammonia in a process?
- 500 pounds
- 5,000 pounds
- 10,000 pounds (Correct answer)
- 20,000 pounds
Correct answer: 10,000 pounds
Processes holding more than 10,000 pounds of anhydrous ammonia are subject to the EPA RMP rule under Clean Air Act Section 112(r).
Question 5: Which provision of the Clean Air Act applies to facilities with ammonia even below the RMP threshold quantity?
- The Section 608 venting prohibition
- The General Duty Clause of Section 112(r)(1) (Correct answer)
- The Title V operating permit program
- The New Source Performance Standards
Correct answer: The General Duty Clause of Section 112(r)(1)
The General Duty Clause requires any facility handling extremely hazardous substances to identify hazards, design safely, and minimize release consequences regardless of quantity.
Question 6: How often must a facility's RMP be updated and resubmitted to EPA at a minimum?
- Every year
- Every 3 years
- Every 5 years (Correct answer)
- Every 10 years
Correct answer: Every 5 years
RMPs must be updated and resubmitted at least once every five years, or sooner after certain changes.
Question 7: Under EPCRA Sections 311/312, the annual Tier II hazardous chemical inventory report is due by what date?
- January 1
- March 1 (Correct answer)
- July 1
- December 31
Correct answer: March 1
Tier II reports covering the previous calendar year are due by March 1 each year.
CARO Environmental Compliance 2
Under CERCLA, what is the reportable quantity (RQ) for an anhydrous ammonia release within a 24-hour period?