CMS Environmental & Sustainability Compliance 3 — Questions and Answers
Question 1: A manufacturing facility stores 10,000 gallons of oil above ground. Which federal regulation requires them to have a Spill Prevention, Control, and Countermeasure (SPCC) plan?
- RCRA Subtitle D
- Clean Water Act Section 311 (Correct answer)
- EPCRA Section 313
- TSCA Section 5
Correct answer: Clean Water Act Section 311
Clean Water Act Section 311 and the SPCC rule (40 CFR Part 112) require facilities storing more than 1,320 gallons of oil above ground to have an SPCC plan.
Question 2: Under the Emergency Planning and Community Right-to-Know Act (EPCRA), Section 313 Toxic Release Inventory (TRI) reporting is triggered when a facility uses a listed chemical above what threshold?
- 1,000 pounds per year
- 10,000 pounds per year
- 25,000 pounds per year (Correct answer)
- 100,000 pounds per year
Correct answer: 25,000 pounds per year
EPCRA Section 313 requires TRI reporting when a facility manufactures or processes 25,000 pounds or otherwise uses 10,000 pounds of a listed chemical annually.
Question 3: Which metric is used to quantify the amount of greenhouse gases emitted by a facility, expressed in equivalent units?
- Carbon equivalent (CE)
- CO2 equivalent (CO2e) (Correct answer)
- Global warming factor (GWF)
- Emission intensity ratio (EIR)
Correct answer: CO2 equivalent (CO2e)
CO2 equivalent (CO2e) is the standard metric for comparing greenhouse gas emissions, converting all gases to their carbon dioxide warming potential.
Question 4: A manufacturer wants to achieve zero-waste-to-landfill status. Which action is most consistent with this goal?
- Switching from hazardous to non-hazardous waste streams
- Diverting at least 90–100% of waste from landfill through reuse, recycling, or energy recovery (Correct answer)
- Reducing overall production output to generate less waste
- Outsourcing waste management to a third-party vendor
Correct answer: Diverting at least 90–100% of waste from landfill through reuse, recycling, or energy recovery
Zero-waste-to-landfill is typically defined as diverting 90% or more (often 100%) of solid waste from landfill via reuse, recycling, composting, or energy recovery.
Question 5: Under OSHA's Hazard Communication Standard (HazCom), Safety Data Sheets (SDS) must follow which international format?
- ISO 11014 format with 12 sections
- GHS 16-section format (Correct answer)
- NFPA 704 diamond system
- DOT placard classification system
Correct answer: GHS 16-section format
OSHA's HazCom standard aligns with the Globally Harmonized System (GHS), requiring SDS documents with 16 standardized sections.
Question 6: Which environmental permit type is required for a manufacturing facility that discharges pollutants directly into a river or stream?
- Title V Air Permit
- NPDES Permit (Correct answer)
- RCRA Facility Permit
- Underground Injection Control Permit
Correct answer: NPDES Permit
A National Pollutant Discharge Elimination System (NPDES) permit is required for any direct discharge of pollutants into waters of the United States.
Question 7: In sustainable manufacturing, 'design for disassembly' (DfD) primarily aims to achieve which environmental benefit?
- Reducing the energy used during the manufacturing process
- Making products easier to repair, reuse, or recycle at end of life (Correct answer)
- Minimizing packaging material used in product distribution
- Improving worker ergonomics during assembly operations
Correct answer: Making products easier to repair, reuse, or recycle at end of life
Design for disassembly ensures products can be efficiently taken apart at end of life, enabling component reuse and material recycling.
CMS Environmental & Sustainability Compliance 3
A manufacturing facility stores 10,000 gallons of oil above ground.
Which federal regulation requires them to have a Spill Prevention, Control, and Countermeasure (SPCC) plan?