CHMM Record Keeping and Reporting 3 — Questions and Answers
Question 1: What is the EPCRA Section 313 Toxics Release Inventory (TRI) reporting threshold for a listed chemical under standard manufacturing criteria?
- 10,000 pounds manufactured or processed; 1,000 pounds otherwise used
- 25,000 pounds manufactured or processed; 10,000 pounds otherwise used (Correct answer)
- 50,000 pounds manufactured or processed; 25,000 pounds otherwise used
- 100,000 pounds manufactured or processed; 10,000 pounds otherwise used
Correct answer: 25,000 pounds manufactured or processed; 10,000 pounds otherwise used
Standard TRI thresholds are 25,000 lbs manufactured or processed and 10,000 lbs otherwise used per year for covered facilities.
Question 2: Under OSHA's Hazard Communication Standard, how long must employers retain SDSs for hazardous chemicals used in the workplace?
- For the duration of employment only
- 5 years after last use
- 30 years after worker exposure (Correct answer)
- 10 years after the chemical is no longer used
Correct answer: 30 years after worker exposure
OSHA 1910.1020 requires that exposure records, including SDSs relevant to worker exposures, be retained for 30 years.
Question 3: A small quantity generator accumulates hazardous waste on-site for more than 270 days without a permit. What violation has occurred?
- Storage without a permit under RCRA (Correct answer)
- Illegal transportation of hazardous waste
- Failure to file a Biennial Report
- Improper manifest completion
Correct answer: Storage without a permit under RCRA
SQGs may accumulate waste for up to 270 days; exceeding this limit without a permit constitutes unpermitted storage, a RCRA violation.
Question 4: Under the Clean Air Act Section 112(r), what must facilities subject to the Risk Management Program submit to EPA?
- Annual emission inventory reports
- Risk Management Plans (RMPs) (Correct answer)
- Quarterly chemical usage logs
- Monthly release monitoring reports
Correct answer: Risk Management Plans (RMPs)
CAA Section 112(r) requires facilities with listed regulated substances above threshold quantities to develop and submit a Risk Management Plan to EPA.
Question 5: Which record must accompany a hazardous waste shipment that is subject to Land Disposal Restrictions?
- A signed generator certification and waste characterization notice sent to the receiving facility (Correct answer)
- A copy of the facility's RCRA permit
- An EPA waste code determination letter
- A state-issued transport authorization
Correct answer: A signed generator certification and waste characterization notice sent to the receiving facility
LDR regulations require generators to send a one-time written notice and certification to the receiving TSD facility documenting that waste meets treatment standards.
Question 6: How frequently must RCRA-permitted TSD facilities conduct and document inspections of their facility and equipment?
- Monthly
- Quarterly
- At least daily for areas with potential for discharge (Correct answer)
- Annually
Correct answer: At least daily for areas with potential for discharge
RCRA requires TSD facilities to inspect areas where releases could occur at least daily, with results logged in the facility inspection log.
Question 7: What is the purpose of the National Response Center (NRC) database maintained by the USCG?
- To issue hazmat transportation permits to carriers
- To centrally record all federally reportable hazardous substance releases (Correct answer)
- To certify hazmat emergency responders nationally
- To track RCRA manifest discrepancies
Correct answer: To centrally record all federally reportable hazardous substance releases
The NRC serves as the single federal point of contact for reporting releases and maintains a database of all reportable hazardous substance incidents.
CHMM Record Keeping and Reporting 3
What is the EPCRA Section 313 Toxics Release Inventory (TRI) reporting threshold for a listed chemical under standard manufacturing criteria?