CHMM Storage 5 — Questions and Answers
Question 1: What is the purpose of a 'contingency plan' required for large quantity generator hazardous waste storage areas?
- To outline procedures for managing waste when storage capacity is exceeded
- To describe emergency response actions for fires, explosions, or unplanned releases (Correct answer)
- To provide backup labeling procedures if original labels are lost
- To schedule routine container inspections and aisle maintenance
Correct answer: To describe emergency response actions for fires, explosions, or unplanned releases
The contingency plan required under 40 CFR 265 Subpart D describes emergency response procedures for fires, explosions, and unplanned releases of hazardous waste.
Question 2: Corrosive hazardous materials should be stored at low levels (bottom shelves or floor) primarily because:
- Corrosives are heavier and may collapse upper shelving
- A spill from a high location increases splash exposure and the area of contamination (Correct answer)
- OSHA requires all hazardous materials to be stored at floor level
- Corrosives require grounding, which is only available at floor level
Correct answer: A spill from a high location increases splash exposure and the area of contamination
Storing corrosives at low levels minimizes the splash radius and worker exposure risk if a container is dropped or falls.
Question 3: Under DOT Hazardous Materials Regulations, which packaging group indicates the highest level of danger and most stringent storage requirements?
- Packing Group I (Correct answer)
- Packing Group II
- Packing Group III
- Packing Group IV
Correct answer: Packing Group I
DOT Packing Group I designates materials with the greatest danger, requiring the most stringent packaging and handling controls.
Question 4: When a small quantity generator (SQG) exceeds the 6,000 kg on-site accumulation limit, what is the regulatory consequence?
- The generator receives an automatic 30-day extension
- The generator immediately becomes subject to large quantity generator requirements (Correct answer)
- The generator must notify EPA and request a variance
- No consequence unless the exceedance persists for more than 30 days
Correct answer: The generator immediately becomes subject to large quantity generator requirements
If an SQG accumulates more than 6,000 kg on-site, it is immediately subject to LQG requirements for that month.
Question 5: Which of the following is a correct practice for storing compressed gas cylinders in a hazardous materials storage area?
- Laying cylinders horizontally to prevent tipping
- Storing oxygen and flammable gas cylinders together if both are secured with chains
- Securing cylinders upright with chains or straps and separating by gas type (Correct answer)
- Removing valve caps when cylinders are in storage to check for leaks
Correct answer: Securing cylinders upright with chains or straps and separating by gas type
Compressed gas cylinders must be stored upright, secured against falling, and segregated by gas type (e.g., oxidizers away from flammables).
Question 6: A facility stores both regulated medical waste and RCRA hazardous waste. Which statement about commingling these waste streams is correct?
- Commingling is allowed if a single manifest covers all materials
- Mixing regulated medical waste with RCRA hazardous waste makes the entire mixture subject to RCRA hazardous waste regulations (Correct answer)
- Medical waste regulations supersede RCRA, so RCRA standards apply only to the hazardous portion
- Commingling is permitted in satellite accumulation areas but not in 90-day storage areas
Correct answer: Mixing regulated medical waste with RCRA hazardous waste makes the entire mixture subject to RCRA hazardous waste regulations
If regulated medical waste is mixed with RCRA hazardous waste, the mixture is regulated as RCRA hazardous waste and all RCRA storage requirements apply.
Question 7: Under OSHA 29 CFR 1910.1200 (Hazard Communication), what must be posted or immediately available in a hazardous materials storage area?
- Copies of all DOT shipping papers for stored materials
- Safety Data Sheets (SDS) for all hazardous chemicals present (Correct answer)
- A complete inventory of all chemicals with their CAS numbers
- The facility's RCRA permit or interim status documentation
Correct answer: Safety Data Sheets (SDS) for all hazardous chemicals present
OSHA Hazard Communication requires that SDS for all hazardous chemicals be readily accessible to employees in their work area, including storage areas.
CHMM Storage 5
What is the purpose of a 'contingency plan' required for large quantity generator hazardous waste storage areas?