CEA Hazardous Materials Handling 5 — Questions and Answers
Question 1: When conducting a hazardous materials audit at a facility storing Class 3 flammable liquids, which distance requirement must be verified between storage tanks and property lines?
- NFPA 30 setback requirements based on tank size and liquid flash point (Correct answer)
- EPA 40 CFR Part 112 spill prevention distances only
- OSHA 29 CFR 1910.106 ventilation requirements
- DOT placard distance standards from public roads
Correct answer: NFPA 30 setback requirements based on tank size and liquid flash point
NFPA 30 (Flammable and Combustible Liquids Code) establishes setback distances from property lines, buildings, and public ways based on tank capacity and liquid classification.
Question 2: A facility subject to OSHA PSM stores more than the threshold quantity of anhydrous ammonia. Which element of the PSM standard requires a written plan for investigating process incidents and near-misses?
- Management of Change (MOC)
- Incident Investigation (Correct answer)
- Emergency Action Plan
- Pre-Startup Safety Review (PSSR)
Correct answer: Incident Investigation
PSM's Incident Investigation element (29 CFR 1910.119(m)) requires a written investigation for incidents and near-misses within 48 hours of the event.
Question 3: Under 40 CFR Part 112, which facilities are required to prepare and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan?
- Any facility storing more than 55 gallons of petroleum products
- Non-transportation-related facilities with aggregate above-ground oil storage capacity greater than 1,320 gallons (Correct answer)
- All RCRA large quantity generators storing petroleum waste
- Facilities with underground storage tanks only
Correct answer: Non-transportation-related facilities with aggregate above-ground oil storage capacity greater than 1,320 gallons
SPCC regulations apply to non-transportation facilities with aggregate above-ground storage capacity exceeding 1,320 gallons of oil in aboveground containers.
Question 4: During a hazardous waste audit, an inspector finds a container labeled only with the words 'old paint.' Under RCRA, this labeling is:
- Acceptable if the paint is non-hazardous
- A violation; containers must be labeled 'Hazardous Waste' with contents and accumulation start date (Correct answer)
- Acceptable for satellite accumulation areas only
- Compliant if the facility maintains an internal waste tracking log
Correct answer: A violation; containers must be labeled 'Hazardous Waste' with contents and accumulation start date
RCRA requires hazardous waste containers to be labeled 'Hazardous Waste' and include the type of waste and the accumulation start date.
Question 5: Which internationally recognized system aligns GHS (Globally Harmonized System) chemical classification with US requirements through OSHA's HazCom 2012 standard?
- NFPA 704 placarding system
- Safety Data Sheet (SDS) with 16-section format and GHS-aligned labels (Correct answer)
- DOT 49 CFR shipping paper requirements
- EPA RCRA waste characterization protocol
Correct answer: Safety Data Sheet (SDS) with 16-section format and GHS-aligned labels
OSHA HazCom 2012 aligned US requirements with GHS by mandating the 16-section SDS format and standardized GHS label elements including pictograms, signal words, and hazard statements.
Question 6: A facility generates 0.8 kg of acute hazardous waste (P-listed) in a month. Under RCRA, this facility is regulated as a:
- Very Small Quantity Generator (VSQG)
- Small Quantity Generator (SQG)
- Large Quantity Generator (LQG) (Correct answer)
- Conditionally Exempt Generator (CEG)
Correct answer: Large Quantity Generator (LQG)
Any facility generating 1 kg or more of acute (P-listed) hazardous waste per month is regulated as an LQG; 0.8 kg is just below that threshold and would be SQG if between 0 and 1 kg.
Question 7: An auditor reviews emergency response plans and finds the facility has not conducted an emergency response drill in over three years. Under EPCRA and RCRA combined requirements, drills are important because they:
- Satisfy the DOT annual refresher training requirement
- Verify that emergency coordinators and response procedures are functional and personnel are trained (Correct answer)
- Replace the need for a written contingency plan
- Only apply to facilities with on-site treatment units
Correct answer: Verify that emergency coordinators and response procedures are functional and personnel are trained
Emergency drills are required to ensure emergency coordinators, equipment, and procedures are tested and functional, satisfying RCRA contingency plan and EPCRA emergency planning requirements.
CEA Hazardous Materials Handling 5
When conducting a hazardous materials audit at a facility storing Class 3 flammable liquids, which distance requirement must be verified between storage tanks and property lines?