CESCO - Certified Environmental, Safety and Compliance Officer Hazardous Waste Management (RCRA) Questions and Answers — Questions and Answers
Question 1: A facility generates 1,200 kg of non-acute hazardous waste and 0.5 kg of acutely hazardous waste in a calendar month. Under RCRA, what is the facility's generator status for that month?
- Very Small Quantity Generator (VSQG)
- Small Quantity Generator (SQG)
- Large Quantity Generator (LQG) (Correct answer)
- Conditionally Exempt Small Quantity Generator (CESQG)
Correct answer: Large Quantity Generator (LQG)
A facility is classified as a Large Quantity Generator (LQG) if it generates 1,000 kg or more of non-acute hazardous waste OR more than 1 kg of acutely hazardous waste in a calendar month. Since this facility generated 1,200 kg of non-acute hazardous waste, it exceeds the 1,000 kg threshold and is therefore an LQG for that month.
Question 2: Which of the following is a key requirement for a hazardous waste satellite accumulation area (SAA) under RCRA?
- Weekly inspections of the containers must be documented.
- The area can accumulate up to 100 gallons of non-acute hazardous waste.
- Waste containers must be located at or near the point of generation and under the control of the operator. (Correct answer)
- A formal contingency plan must be posted in the satellite accumulation area.
Correct answer: Waste containers must be located at or near the point of generation and under the control of the operator.
RCRA regulations for satellite accumulation areas (SAAs) at 40 CFR 262.15 state that containers must be at or near the point of generation where the waste initially accumulates and must be under the control of the operator of the process generating the waste. While weekly inspections and contingency plans are required for central accumulation areas, they are not specific requirements for SAAs. The accumulation limit for non-acute hazardous waste in an SAA is 55 gallons.
Question 3: A manufacturing plant needs to dispose of a 55-gallon drum that previously held a listed hazardous waste (not an acute hazardous waste). To be considered 'RCRA empty,' which condition must be met?
- The drum must be triple-rinsed with a suitable solvent.
- The drum must be crushed so that it can no longer hold waste.
- All wastes that can be removed by pouring or pumping have been removed, and no more than 1 inch of residue remains on the bottom. (Correct answer)
- The drum must be filled with an absorbent material to solidify any remaining liquid.
Correct answer: All wastes that can be removed by pouring or pumping have been removed, and no more than 1 inch of residue remains on the bottom.
According to 40 CFR 261.7, a container that held a non-acute hazardous waste is considered 'RCRA empty' if all wastes have been removed using common practices (like pouring or pumping) AND no more than 1 inch of residue remains on the bottom of the container. Triple rinsing is a requirement for containers that held acute hazardous waste.
Question 4: The primary purpose of the RCRA Land Disposal Restrictions (LDR) program is to:
- Encourage the recycling of hazardous waste over disposal.
- Prohibit the land disposal of untreated hazardous wastes to minimize future environmental risks. (Correct answer)
- Set national standards for the design and operation of hazardous waste landfills.
- Establish a fee structure for the disposal of hazardous waste in surface impoundments.
Correct answer: Prohibit the land disposal of untreated hazardous wastes to minimize future environmental risks.
The Land Disposal Restrictions (LDR) program, established by the 1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA, prohibits the land disposal of untreated hazardous wastes. The program's goal is to minimize threats to human health and the environment by requiring that wastes be treated to reduce their toxicity or the mobility of hazardous constituents before being land disposed.
Question 5: A Small Quantity Generator (SQG) has an on-site accumulation time limit for hazardous waste of 180 days. Under what specific circumstance can this be extended to 270 days?
- The SQG generates less than 500 kg of hazardous waste that month.
- The waste must be transported to a Treatment, Storage, and Disposal Facility (TSDF) that is over 200 miles away. (Correct answer)
- The generator has applied for and received a special extension from the EPA Regional Administrator.
- The waste is being accumulated in a satellite accumulation area.
Correct answer: The waste must be transported to a Treatment, Storage, and Disposal Facility (TSDF) that is over 200 miles away.
RCRA regulations at 40 CFR 262.16 allow a Small Quantity Generator (SQG) to accumulate hazardous waste on-site for up to 180 days without a permit. This time limit can be extended to 270 days if the treatment, storage, or disposal facility (TSDF) where the waste must be sent is located more than 200 miles away.
Question 6: What is the primary function of the Uniform Hazardous Waste Manifest?
- To serve as a permit for generating hazardous waste.
- To certify that a hazardous waste has been treated according to LDR standards.
- To provide emergency response information to first responders.
- To track hazardous waste from the point of generation to its final destination ('cradle-to-grave'). (Correct answer)
Correct answer: To track hazardous waste from the point of generation to its final destination ('cradle-to-grave').
The Uniform Hazardous Waste Manifest is a multi-copy shipping document designed to track hazardous waste from the generator's facility to the off-site facility that will treat, store, or dispose of it. This system ensures accountability and creates a complete record of the waste's journey, embodying the 'cradle-to-grave' management principle of RCRA.
A facility generates 1,200 kg of non-acute hazardous waste and 0.5 kg of acutely hazardous waste in a calendar month.
Under RCRA, what is the facility's generator status for that month?