CHMM CHMM Regulatory Compliance and Environmental Law 2 — Questions and Answers
Question 1: The Hazardous and Solid Waste Amendments (HSWA) of 1984 added which significant requirement to RCRA?
- Land disposal restrictions (LDRs) for untreated hazardous waste (Correct answer)
- Mandatory recycling of all industrial waste
- National ambient air quality standards for hazardous air pollutants
- Stormwater permitting for industrial facilities
Correct answer: Land disposal restrictions (LDRs) for untreated hazardous waste
HSWA introduced land disposal restrictions, requiring treatment of hazardous waste to meet specific standards before land disposal.
Question 2: Which regulation requires facilities with threshold quantities of regulated substances to develop Risk Management Plans (RMPs)?
- OSHA PSM Standard (29 CFR 1910.119)
- EPA RMP Rule (40 CFR Part 68) (Correct answer)
- EPCRA Title III
- DOT HMR 49 CFR 172
Correct answer: EPA RMP Rule (40 CFR Part 68)
EPA's RMP rule under CAA Section 112(r) requires facilities with regulated substances above threshold quantities to develop and submit RMPs to the EPA.
Question 3: A facility that generates between 100 and 1,000 kg of hazardous waste per month is classified under RCRA as which type of generator?
- Very Small Quantity Generator (VSQG)
- Small Quantity Generator (SQG) (Correct answer)
- Large Quantity Generator (LQG)
- Conditionally Exempt Generator (CEG)
Correct answer: Small Quantity Generator (SQG)
Small Quantity Generators (SQGs) generate between 100 and 1,000 kg of hazardous waste per month and have a 270-day accumulation limit.
Question 4: Under EPCRA Section 313, what is the Toxics Release Inventory (TRI) program designed to track?
- Imports of toxic chemicals from foreign countries
- Releases and transfers of listed toxic chemicals from manufacturing facilities (Correct answer)
- Occupational illnesses caused by toxic exposures
- Environmental violations by regulated industries
Correct answer: Releases and transfers of listed toxic chemicals from manufacturing facilities
TRI tracks annual releases and off-site transfers of listed toxic chemicals from covered facilities, making data publicly available.
Question 5: Which enforcement tool allows EPA to issue an order requiring immediate compliance with RCRA requirements without going to court?
- Compliance schedule order
- Administrative compliance order (ACO) (Correct answer)
- Consent decree
- Notice of violation
Correct answer: Administrative compliance order (ACO)
EPA can issue administrative compliance orders under RCRA Section 3008 directing violators to take corrective action without the need for court proceedings.
Question 6: Under CERCLA, which legal doctrine holds all potentially responsible parties jointly and severally liable for cleanup costs at a Superfund site?
- Strict liability
- Joint and several liability (Correct answer)
- Negligence per se
- Contributory liability
Correct answer: Joint and several liability
CERCLA imposes joint and several liability, meaning any one responsible party can be held liable for the entire cleanup cost regardless of their proportional contribution.
CHMM CHMM Regulatory Compliance and Environmental Law 2
The Hazardous and Solid Waste Amendments (HSWA) of 1984 added which significant requirement to RCRA?