CPWM Environmental Compliance 2 — Questions and Answers
Question 1: Under the Clean Water Act Section 402, a Municipal Separate Storm Sewer System (MS4) permit requires public works departments to implement which program element?
- Groundwater recharge monitoring
- Illicit discharge detection and elimination (Correct answer)
- Wetland mitigation banking
- Underground injection control
Correct answer: Illicit discharge detection and elimination
MS4 NPDES permits require six minimum control measures including illicit discharge detection and elimination (IDDE) to prevent non-stormwater discharges.
Question 2: A public works crew discovers soil contamination while excavating for a water main replacement. Under CERCLA, the agency's first obligation is to:
- Continue work and document findings in the project report
- Immediately notify the state environmental agency and EPA (Correct answer)
- Hire a licensed contractor to remove all contaminated soil
- Install groundwater monitoring wells within 24 hours
Correct answer: Immediately notify the state environmental agency and EPA
CERCLA requires prompt notification to appropriate regulatory agencies when contamination is discovered, triggering formal response procedures.
Question 3: Which document establishes the legal framework for regulating emissions from public works vehicle fleets operating diesel engines?
- Safe Drinking Water Act
- Clean Air Act Title II (Correct answer)
- Solid Waste Disposal Act
- Resource Conservation and Recovery Act
Correct answer: Clean Air Act Title II
Clean Air Act Title II governs mobile source emissions, including diesel engines in public works fleets, establishing standards for NOx, PM, and other pollutants.
Question 4: A city's wastewater treatment plant receives a Notice of Violation for exceeding effluent limits. The most appropriate immediate response is to:
- Appeal the violation and request a variance
- Submit a written response and corrective action plan within the required timeframe (Correct answer)
- Shut down non-essential plant operations
- Request an emergency permit modification
Correct answer: Submit a written response and corrective action plan within the required timeframe
Regulatory agencies typically require a written response acknowledging the violation and outlining corrective actions within a specified timeframe, usually 30 days.
Question 5: The Spill Prevention, Control, and Countermeasure (SPCC) rule applies to public works facilities that store aboveground oil in aggregate quantities exceeding:
- 500 gallons
- 1,320 gallons (Correct answer)
- 2,500 gallons
- 5,000 gallons
Correct answer: 1,320 gallons
SPCC regulations apply to facilities with aboveground oil storage capacity greater than 1,320 gallons in aggregate or any single tank over 660 gallons.
Question 6: When conducting a street sweeping program for stormwater compliance, the primary environmental benefit is:
- Reducing vehicle noise pollution in residential areas
- Removing pollutants before they enter the storm drain system (Correct answer)
- Complying with air quality particulate standards
- Decreasing roadway surface temperature in urban heat islands
Correct answer: Removing pollutants before they enter the storm drain system
Street sweeping removes sediment, nutrients, heavy metals, and other pollutants from road surfaces before rainfall can wash them into storm drains and waterways.
Question 7: Under RCRA, a public works facility generating between 100 and 1,000 kg of hazardous waste per month is classified as a:
- Very Small Quantity Generator (VSQG)
- Small Quantity Generator (SQG) (Correct answer)
- Large Quantity Generator (LQG)
- Conditionally Exempt Generator (CEG)
Correct answer: Small Quantity Generator (SQG)
Facilities generating 100-1,000 kg/month of hazardous waste are classified as Small Quantity Generators with intermediate regulatory requirements.
CPWM Environmental Compliance 2
Under the Clean Water Act Section 402, a Municipal Separate Storm Sewer System (MS4) permit requires public works departments to implement which program element?