CHMM Record Keeping and Reporting 5 — Questions and Answers
Question 1: Which EPA regulation requires facilities to maintain a written Spill Prevention, Control, and Countermeasure (SPCC) Plan and associated records?
- RCRA Subtitle C
- Clean Water Act 40 CFR Part 112 (Correct answer)
- CERCLA Section 103
- EPCRA Section 302
Correct answer: Clean Water Act 40 CFR Part 112
The SPCC rule under 40 CFR Part 112 of the Clean Water Act requires certain oil-storage facilities to prepare, implement, and maintain an SPCC Plan.
Question 2: A very small quantity generator (VSQG) generates between 1 and 100 kg of hazardous waste per month. What manifest requirement applies?
- VSQGs must use a manifest for all off-site shipments
- VSQGs are exempt from manifest requirements if waste is sent to a large quantity generator facility (Correct answer)
- VSQGs are fully exempt from all RCRA requirements
- VSQGs must use a manifest only for acutely hazardous waste
Correct answer: VSQGs are exempt from manifest requirements if waste is sent to a large quantity generator facility
VSQGs are exempt from the manifest requirement provided their waste is sent to a facility that is a LQG under the same ownership, or to a permitted/licensed treatment or disposal facility.
Question 3: Under TSCA Section 8(e), a manufacturer or importer who obtains information that a chemical substance presents a substantial risk of injury must report to EPA within how many days?
- 15 calendar days
- 30 calendar days (Correct answer)
- 60 calendar days
- 90 calendar days
Correct answer: 30 calendar days
TSCA Section 8(e) requires companies to report substantial risk information to EPA within 30 calendar days of obtaining such information.
Question 4: What is the key difference between a RCRA Biennial Report and an Exception Report?
- The Biennial Report is a routine summary of waste activities; an Exception Report is filed when a manifest is not returned within the required timeframe (Correct answer)
- The Biennial Report is filed monthly; the Exception Report is filed annually
- The Exception Report covers hazardous waste exports; the Biennial Report covers imports
- They are the same form submitted at different intervals
Correct answer: The Biennial Report is a routine summary of waste activities; an Exception Report is filed when a manifest is not returned within the required timeframe
The Biennial Report is a scheduled summary of waste management activities, while an Exception Report is a corrective action document filed when manifest tracking breaks down.
Question 5: Under 49 CFR 172.700, how long must DOT hazmat training records be retained for a current employee?
- During employment only
- Previous training period plus 90 days (Correct answer)
- 3 years from the date of training
- 5 years from the date of training
Correct answer: Previous training period plus 90 days
DOT requires hazmat training records to be retained for the duration of employment plus 90 days after the employee leaves.
Question 6: Which of the following CERCLA hazardous substance releases is exempt from NRC notification requirements?
- A release from a broken storage tank to soil at a manufacturing plant
- Federally permitted releases such as those covered by a valid NPDES permit (Correct answer)
- A release in a populated area above the reportable quantity
- A release discovered during an OSHA inspection
Correct answer: Federally permitted releases such as those covered by a valid NPDES permit
CERCLA Section 101(10) exempts 'federally permitted releases' such as those authorized under NPDES, RCRA, or Clean Air Act permits from notification requirements.
Question 7: A facility's written emergency contingency plan is required under RCRA for which generator category?
- Very small quantity generators only
- Small quantity generators and large quantity generators
- Large quantity generators only (Correct answer)
- All generator categories including VSQGs
Correct answer: Large quantity generators only
Only large quantity generators are required to have a full written RCRA contingency plan; SQGs require a simpler emergency plan and LQGs require the comprehensive contingency plan.
CHMM Record Keeping and Reporting 5
Which EPA regulation requires facilities to maintain a written Spill Prevention, Control, and Countermeasure (SPCC) Plan and associated records?