CPWM Regulatory Compliance and Environmental Safety 5 — Questions and Answers
Question 1: The National Contingency Plan (NCP) establishes the framework for federal response to which type of events?
- Oil spills and hazardous substance releases (Correct answer)
- Municipal solid waste disposal failures
- Air quality emergencies from industrial stack emissions
- Groundwater depletion from over-extraction
Correct answer: Oil spills and hazardous substance releases
The NCP, codified at 40 CFR Part 300, provides the organizational structure and procedures for federal response to oil spills and hazardous substance releases under CWA and CERCLA.
Question 2: Which RCRA exclusion allows generators to accumulate hazardous waste on-site without a permit for up to 90 days?
- Large quantity generator (LQG) accumulation time exemption (Correct answer)
- Satellite accumulation area exemption
- Totally enclosed treatment unit exemption
- Elementary neutralization unit exemption
Correct answer: Large quantity generator (LQG) accumulation time exemption
LQGs may accumulate hazardous waste on-site for up to 90 days without a storage permit, provided they meet all applicable standards during accumulation.
Question 3: Under the Clean Air Act's Prevention of Significant Deterioration (PSD) program, major new sources in attainment areas must apply:
- Best Available Control Technology (BACT) (Correct answer)
- Maximum Achievable Control Technology (MACT)
- Reasonably Available Control Technology (RACT)
- Lowest Achievable Emission Rate (LAER)
Correct answer: Best Available Control Technology (BACT)
PSD requires major new or modified sources in attainment areas to install BACT, which is determined case-by-case based on energy, environmental, and economic factors.
Question 4: A waste management professional discovers that a listed hazardous waste has been mixed with a non-hazardous solid waste. Under RCRA's mixture rule, the resulting mixture is:
- Considered hazardous unless it meets delisting criteria (Correct answer)
- Non-hazardous if the listed waste is less than 10% of the mixture
- Non-hazardous if diluted below characteristic thresholds
- Hazardous only if it still exhibits a characteristic
Correct answer: Considered hazardous unless it meets delisting criteria
RCRA's mixture rule states that any mixture of a listed hazardous waste with solid waste is considered hazardous waste and subject to full Subtitle C regulation.
Question 5: Which international agreement governs the transboundary movement of hazardous waste and requires prior informed consent from receiving countries?
- Basel Convention (Correct answer)
- Stockholm Convention
- Rotterdam Convention
- Minamata Convention
Correct answer: Basel Convention
The Basel Convention requires exporting countries to obtain prior informed consent from importing and transit countries before shipping hazardous waste across borders.
Question 6: Under RCRA's derived-from rule, residues generated from the treatment of a listed hazardous waste (e.g., incinerator ash) are:
- Still considered hazardous waste unless delisted (Correct answer)
- Non-hazardous if treatment reduces volume by 90%
- Non-hazardous if they do not exhibit any characteristic
- Subject only to state solid waste regulations
Correct answer: Still considered hazardous waste unless delisted
The derived-from rule states that any residue derived from the treatment, storage, or disposal of a listed hazardous waste retains its hazardous waste status.
Question 7: Which federal agency is the lead agency for emergency response to hazardous substance releases under the National Response System?
- EPA for inland releases; US Coast Guard for coastal/marine releases (Correct answer)
- FEMA for all hazardous substance emergencies
- DOT for all transportation-related releases
- OSHA for all worker-safety-related releases
Correct answer: EPA for inland releases; US Coast Guard for coastal/marine releases
Under the NCP, EPA serves as the On-Scene Coordinator lead for inland hazardous substance releases, while the US Coast Guard leads coastal and marine zone responses.
CPWM Regulatory Compliance and Environmental Safety 5
The National Contingency Plan (NCP) establishes the framework for federal response to which type of events?