CPP Risk Management & Mitigation 2

Question 1

What is the 'Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)' most commonly known as, and when does it affect permitting?

Accepted Answer

Superfund; it affects permitting when a project site has or may have contamination requiring cleanup or when acquiring potentially contaminated property

Answer

The Clean Streams Law; it affects stormwater permits

Answer

The Resource Conservation Act; it affects solid waste permits

Answer

The National Contingency Plan; it triggers emergency permits

Question 2

What is a 'Phase I Environmental Site Assessment' and how does it relate to risk management in permitting?

Accepted Answer

A records review and site inspection to identify Recognized Environmental Conditions (RECs) and CERCLA liability risks, conducted before property acquisition or development

Answer

A soil sampling study required for all construction permits

Answer

A federal EPA inspection of contaminated sites

Answer

A permit application for remediation of contaminated sites

Question 3

What is an 'adaptive management' approach in environmental permitting?

Accepted Answer

A framework for adjusting permit conditions and mitigation measures based on monitoring data and feedback to achieve environmental goals under uncertainty

Answer

A management approach that adapts permit fees to market conditions

Answer

A federal program for managing national parks

Answer

A method for accelerating permit timelines by adapting schedules

Question 4

Which Clean Water Act program requires industrial facilities to develop Spill Prevention, Control, and Countermeasure (SPCC) plans?

Accepted Answer

40 CFR Part 112 (Oil Pollution Prevention) requires SPCC plans for facilities with oil storage above threshold quantities that could discharge to navigable waters

Answer

NPDES General Permit for industrial stormwater

Answer

RCRA Subtitle C hazardous waste regulations

Answer

CAA Risk Management Plan requirements

Question 5

What is the 'reasonable worst case scenario' concept in risk assessment for hazardous facility permits?

Accepted Answer

An EPA methodology under Risk Management Planning (RMP) that models the worst-case credible release of hazardous chemicals to assess off-site impacts

Answer

The worst possible outcome regardless of probability used in all environmental permits

Answer

A FEMA methodology for flood risk assessment

Answer

A construction risk assessment methodology for worker safety

Question 6

What is 'permit by rule' and how does it manage regulatory risk for routine operations?

Accepted Answer

A pre-established permit category where operations meeting specified criteria are automatically authorized without individual application, reducing compliance uncertainty

Answer

A rule allowing one permit to cover all operations at a facility

Answer

A rule that exempts small businesses from permitting requirements

Answer

A waiver of permit requirements during declared emergencies