CPWM Regulatory Compliance and Environmental Safety 4 — Questions and Answers
Question 1: Which provision of CERCLA allows EPA to recover cleanup costs from potentially responsible parties (PRPs) at Superfund sites?
- Cost recovery under Section 107 (Correct answer)
- Emergency removal under Section 104
- Natural resource damages under Section 106
- Settlement authority under Section 122
Correct answer: Cost recovery under Section 107
CERCLA Section 107 establishes strict, joint and several liability allowing EPA to sue PRPs to recover response costs incurred at Superfund sites.
Question 2: A facility subject to EPCRA Section 313 must file a Toxic Release Inventory (TRI) Form R if it manufactures or processes a listed chemical above what threshold?
- 25,000 pounds for manufacturing/processing; 10,000 pounds for otherwise use (Correct answer)
- 1,000 pounds for any listed chemical
- 10,000 pounds for all listed chemicals
- 100,000 pounds for manufacturing only
Correct answer: 25,000 pounds for manufacturing/processing; 10,000 pounds for otherwise use
TRI reporting thresholds are 25,000 lbs for manufactured or processed chemicals and 10,000 lbs for chemicals otherwise used at the facility.
Question 3: The Safe Drinking Water Act's Underground Injection Control (UIC) program regulates wells to protect:
- Underground sources of drinking water (USDWs) (Correct answer)
- Surface water quality in navigable rivers
- Atmospheric emissions from industrial facilities
- Soil contamination from landfill leachate
Correct answer: Underground sources of drinking water (USDWs)
The UIC program protects USDWs by regulating the construction, operation, and closure of injection wells that could contaminate groundwater.
Question 4: Which type of RCRA permit is required to store, treat, or dispose of hazardous waste at a facility?
- RCRA Part B permit (Correct answer)
- RCRA Part A interim status
- NPDES general permit
- CAA Title V permit
Correct answer: RCRA Part B permit
A RCRA Part B permit is the full operating permit required for hazardous waste treatment, storage, and disposal facilities (TSDFs).
Question 5: Under DOT regulations, which placard is required on a vehicle transporting more than 1,000 lbs of a Class 3 flammable liquid?
- FLAMMABLE placard (red diamond with flame symbol) (Correct answer)
- COMBUSTIBLE placard (red and white striped diamond)
- DANGEROUS placard (white and red split diamond)
- POISON placard (white diamond with skull symbol)
Correct answer: FLAMMABLE placard (red diamond with flame symbol)
Class 3 flammable liquids require the red FLAMMABLE placard when transported in quantities exceeding 1,000 lbs under 49 CFR Part 172.
Question 6: An environmental audit conducted at a facility reveals past RCRA violations. Which EPA policy may reduce penalties if violations are voluntarily disclosed?
- EPA Audit Policy (Incentives for Self-Policing) (Correct answer)
- National Enforcement Compliance Initiative
- Supplemental Environmental Projects Policy
- Emergency Planning Exemption Policy
Correct answer: EPA Audit Policy (Incentives for Self-Policing)
EPA's Audit Policy provides significant penalty mitigation when facilities voluntarily discover, disclose, and correct environmental violations in good faith.
Question 7: Which RCRA requirement mandates that hazardous waste facilities have financial assurance mechanisms to cover closure and post-closure costs?
- Financial assurance under 40 CFR Part 264 Subpart H (Correct answer)
- Corrective action under RCRA Section 3008(h)
- Manifest tracking under 40 CFR Part 262
- Land disposal restrictions under 40 CFR Part 268
Correct answer: Financial assurance under 40 CFR Part 264 Subpart H
40 CFR Part 264 Subpart H requires TSDFs to establish financial assurance mechanisms such as trusts, bonds, or insurance to cover closure and post-closure costs.
CPWM Regulatory Compliance and Environmental Safety 4
Which provision of CERCLA allows EPA to recover cleanup costs from potentially responsible parties (PRPs) at Superfund sites?