CHMM Facility Operations with Hazmat 5 — Questions and Answers
Question 1: A facility manager discovers that drums containing hazardous waste have been stored in a satellite accumulation area (SAA) for more than 60 days. Under 40 CFR 262.15, this situation most likely indicates a violation because:
- SAAs require a RCRA storage permit after 30 days
- SAAs are exempt from all time limits under EPA regulations
- Drums at an SAA must be moved to the central accumulation area once the container limit is reached, regardless of time (Correct answer)
- The 60-day limit applies only to large quantity generators in attainment areas
Correct answer: Drums at an SAA must be moved to the central accumulation area once the container limit is reached, regardless of time
SAAs are not subject to time limits per se, but containers must be moved once the volume limit (55 gallons for non-acute, 1 quart for acute) is reached—a long accumulation time suggests containers have exceeded limits.
Question 2: Under 40 CFR Part 264 Subpart I, hazardous waste containers must be marked with the words 'Hazardous Waste' and with information that identifies the hazard. This marking requirement becomes effective:
- Only when the container is full and sealed
- When waste is first placed into the container (Correct answer)
- After 72 hours of accumulation
- Only when the container leaves the SAA
Correct answer: When waste is first placed into the container
Containers must be marked as 'Hazardous Waste' from the moment waste is first added to them.
Question 3: A facility's chemical inventory includes a substance with an NFPA 704 diamond rating of Health=4, Flammability=0, Instability=1, Special=W with a slash through it (no water). This diamond most closely describes which type of hazard scenario?
- A cryogenic liquid that reacts violently with water and is acutely toxic (Correct answer)
- A corrosive acid that is highly flammable and unstable at room temperature
- A combustible dust that poses a severe explosion hazard when mixed with water
- A radioactive material with special handling requirements
Correct answer: A cryogenic liquid that reacts violently with water and is acutely toxic
Health 4 indicates a life-threatening chemical, Flammability 0 means non-combustible, Instability 1 means slightly unstable, and the W-bar means it reacts dangerously with water—consistent with certain cryogenic or water-reactive toxic materials.
Question 4: When a facility conducts a Management of Change (MOC) review for replacing a pump seal material in a sulfuric acid service line, which hazard analysis step must be completed BEFORE the change is implemented?
- Updating the annual Tier II report to reflect the new material
- Notifying the LEPC of the proposed equipment modification
- Evaluating whether the new seal material introduces new or different hazards to the process (Correct answer)
- Obtaining a written variance from OSHA before changing process equipment
Correct answer: Evaluating whether the new seal material introduces new or different hazards to the process
MOC requires a pre-change hazard evaluation to determine if the change introduces new hazards, before implementation—not after.
Question 5: A hazardous materials manager is selecting personal protective equipment for workers cleaning up a spill of a highly toxic liquid with unknown vapor concentration. Following the OSHA Hazwoper framework, which PPE level should be selected as the initial entry level?
- Level D — standard work clothes with safety glasses
- Level C — air-purifying respirator with chemical-resistant splash suit
- Level B — supplied-air respirator with non-encapsulating chemical suit
- Level A — fully encapsulating vapor-protective suit with SCBA (Correct answer)
Correct answer: Level A — fully encapsulating vapor-protective suit with SCBA
When skin and vapor hazards are unknown or known to be severe, Level A provides the highest level of protection with a fully encapsulating suit and SCBA.
Question 6: Under EPA's RCRA land disposal restrictions (LDRs) found in 40 CFR Part 268, a generator must send which document to the receiving treatment or disposal facility along with a hazardous waste shipment?
- A copy of the facility's RCRA operating permit
- An LDR notification and certification form (Correct answer)
- A signed Tier II chemical inventory report
- An EPA Form 8700-12 (RCRA hazardous waste report)
Correct answer: An LDR notification and certification form
Generators must send an LDR notification and certification to the receiving facility documenting the waste's treatment standards and compliance status.
Question 7: A facility operates a permitted hazardous waste storage unit and is subject to financial assurance requirements under 40 CFR Part 264 Subpart H. Which mechanism would NOT be an acceptable financial assurance instrument for closure costs?
- Closure trust fund
- Letter of credit from an acceptable financial institution
- Personal guarantee from the facility owner (Correct answer)
- Surety bond guaranteeing performance
Correct answer: Personal guarantee from the facility owner
EPA does not accept personal guarantees from individual facility owners as financial assurance; approved mechanisms include trust funds, letters of credit, surety bonds, insurance, and financial tests.
CHMM Facility Operations with Hazmat 5
A facility manager discovers that drums containing hazardous waste have been stored in a satellite accumulation area (SAA) for more than 60 days.
Under 40 CFR 262.15, this situation most likely indicates a violation because: