CPWM Hazardous Waste Management 5 — Questions and Answers
Question 1: Under RCRA, which waste management activity is considered 'recycling' and may exempt material from hazardous waste regulation?
- Burning for energy recovery in a cement kiln under applicable standards (Correct answer)
- Storing spent solvents in open containers pending shipment
- Diluting hazardous waste with water to lower concentration
- Mixing listed and non-listed wastes to average out toxicity
Correct answer: Burning for energy recovery in a cement kiln under applicable standards
Burning hazardous waste for energy recovery in a permitted industrial furnace or boiler can qualify as recycling under specific RCRA conditions.
Question 2: What is the 'mixture rule' under 40 CFR 261.3(a)(2)(iv) in the context of RCRA hazardous waste?
- Any mixture of listed hazardous waste with solid waste remains a listed hazardous waste (Correct answer)
- Mixing two non-hazardous wastes creates a hazardous waste
- A mixture becomes non-hazardous if the listed waste is less than 1% by volume
- Only the listed waste fraction of a mixture requires manifesting
Correct answer: Any mixture of listed hazardous waste with solid waste remains a listed hazardous waste
The mixture rule states that any mixture containing a listed hazardous waste retains its listed status regardless of dilution.
Question 3: A hazardous waste storage tank at a TSDF fails a weekly inspection. What is the required immediate action under 40 CFR Part 264 Subpart J?
- Submit a variance request to EPA within 30 days
- Remove the waste, assess the problem, and repair or replace the tank before returning it to service (Correct answer)
- Notify the state agency within 90 days and continue operations
- Apply secondary containment and continue use indefinitely
Correct answer: Remove the waste, assess the problem, and repair or replace the tank before returning it to service
Upon detecting a tank system failure, the TSDF must remove waste and inspect the tank; repairs must be completed before the system is returned to service.
Question 4: Which of the following is an example of a 'K-listed' hazardous waste?
- Spent non-halogenated solvents (acetone)
- Wastewater treatment sludge from electroplating operations (Correct answer)
- Discarded commercial chemical product (acutely toxic)
- Off-specification pesticide product
Correct answer: Wastewater treatment sludge from electroplating operations
K-listed wastes are source-specific, such as K062 (spent pickle liquor and sludges from electroplating), generated by particular industries.
Question 5: Under the Emergency Planning and Community Right-to-Know Act (EPCRA), what triggers a facility's obligation to notify the Local Emergency Planning Committee (LEPC)?
- Storing any amount of a hazardous chemical on-site
- Having an Extremely Hazardous Substance at or above its Threshold Planning Quantity (Correct answer)
- Releasing any chemical listed on CERCLA Table 302.4
- Generating more than 1,000 kg/month of hazardous waste
Correct answer: Having an Extremely Hazardous Substance at or above its Threshold Planning Quantity
EPCRA Section 302 requires facilities to notify the LEPC when an Extremely Hazardous Substance is present at or above its Threshold Planning Quantity.
Question 6: What does 'contained-in' determination mean under RCRA hazardous waste regulations?
- A TSDF certifying that a tank is leak-free
- An authorized agency determination that environmental media no longer contains hazardous waste (Correct answer)
- A generator's claim that waste is below detection limits
- EPA confirmation that a landfill cell is properly lined
Correct answer: An authorized agency determination that environmental media no longer contains hazardous waste
A 'contained-in' determination by an authorized state or EPA means that contaminated environmental media no longer contains hazardous waste and is no longer subject to RCRA management standards.
Question 7: Which financial assurance mechanism requires a facility to set aside funds annually over the facility's operating life to ensure closure and post-closure care costs are covered?
- Surety bond
- Closure trust fund (Correct answer)
- Letter of credit
- Corporate guarantee
Correct answer: Closure trust fund
A closure trust fund requires annual payments into a third-party trustee account, building up to the full closure cost estimate over the facility's life.
CPWM Hazardous Waste Management 5
Under RCRA, which waste management activity is considered 'recycling' and may exempt material from hazardous waste regulation?