CEA Hazardous Materials Handling 4 — Questions and Answers
Question 1: An auditor discovers that a facility's satellite accumulation area (SAA) contains 65 gallons of flammable solvent waste in a single container. What is the primary violation?
- Containers must be closed except when adding waste
- SAAs are limited to 55 gallons of hazardous waste or 1 quart of acute hazardous waste (Correct answer)
- The waste should be labeled 'Hazardous Waste' not 'Satellite Accumulation'
- Flammable waste cannot be stored in SAAs under any circumstances
Correct answer: SAAs are limited to 55 gallons of hazardous waste or 1 quart of acute hazardous waste
RCRA regulations limit satellite accumulation areas to 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) per waste stream at or near the point of generation.
Question 2: Under OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, which level of training is required for workers who regularly work on a hazardous waste clean-up site?
- 8-hour awareness training
- 24-hour technician training
- 40-hour initial training plus 3 days supervised field experience (Correct answer)
- 16-hour operations-level training
Correct answer: 40-hour initial training plus 3 days supervised field experience
HAZWOPER 29 CFR 1910.120(e) requires general site workers to complete 40 hours of initial training plus a minimum of 3 days supervised field experience.
Question 3: Which Section of EPCRA requires facilities to report annual releases of listed toxic chemicals to the Toxics Release Inventory (TRI)?
- Section 302
- Section 304
- Section 311
- Section 313 (Correct answer)
Correct answer: Section 313
EPCRA Section 313 requires covered facilities to submit annual Form R reports to EPA's Toxics Release Inventory for listed toxic chemicals above threshold quantities.
Question 4: A facility generates polychlorinated biphenyl (PCB) waste from transformer oil. Which federal regulation primarily governs PCB disposal?
- RCRA Subtitle C (40 CFR Part 261)
- TSCA (40 CFR Part 761) (Correct answer)
- CERCLA Section 102
- CAA Section 112
Correct answer: TSCA (40 CFR Part 761)
PCB disposal is governed by TSCA regulations at 40 CFR Part 761, which set concentration thresholds and approved disposal methods independent of RCRA.
Question 5: During a facility inspection, an auditor finds secondary containment for a chemical storage area is cracked and does not hold liquid. The secondary containment must be capable of holding:
- At least 25% of total container volume
- At least 10% of total container volume or the volume of the largest container, whichever is greater (Correct answer)
- Exactly 110% of the largest single container volume
- Enough to contain a 24-hour rainfall event only
Correct answer: At least 10% of total container volume or the volume of the largest container, whichever is greater
RCRA 40 CFR 264.175/265.175 requires secondary containment to hold at least 10% of total container volume or the volume of the largest container, whichever is greater.
Question 6: Which of the following is a key requirement when transporting a hazardous waste from a generator to a licensed TSDF under RCRA?
- The waste must be transported within 10 days of generation
- A Uniform Hazardous Waste Manifest must accompany each shipment (Correct answer)
- The generator must provide a performance bond to the transporter
- The TSDF must inspect the waste before the transporter departs the generator site
Correct answer: A Uniform Hazardous Waste Manifest must accompany each shipment
RCRA requires a Uniform Hazardous Waste Manifest to travel with each hazardous waste shipment from generator to TSDF to track the waste cradle-to-grave.
Question 7: A drum of hazardous waste has been stored at a large quantity generator (LQG) facility for 88 days. Under RCRA, what action must occur?
- The generator must apply for a storage permit immediately
- The waste must be shipped off-site before the 90-day accumulation limit is exceeded (Correct answer)
- The generator must notify EPA of the storage exceedance
- No action is required until day 90
Correct answer: The waste must be shipped off-site before the 90-day accumulation limit is exceeded
LQGs must ship hazardous waste off-site within 90 days; with only 2 days remaining, the waste should be shipped immediately to avoid a storage permit violation.
CEA Hazardous Materials Handling 4
An auditor discovers that a facility's satellite accumulation area (SAA) contains 65 gallons of flammable solvent waste in a single container.
What is the primary violation?