Environmental Compliance Inspector Enforcement and Reporting Questions and Answers

Question 1

A facility manufactures a product using toluene, a chemical listed on the Toxics Release Inventory (TRI).
The facility meets the employee threshold and manufactures more than 25,000 pounds of toluene in a year.
What is this facility's primary annual reporting requirement under EPCRA Section 313?

Accepted Answer

Submit a Form R to the EPA and the state.

Answer

Submit a Tier II report to the SERC, LEPC, and local fire department.

Answer

Report the release immediately to the National Response Center.

Answer

Include the toluene emissions in their RCRA Biennial Report.

Question 2

An environmental agency has documented a significant violation and seeks to recover the economic benefit the company gained from non-compliance, plus a gravity-based amount. The agency and the facility cannot agree on a settlement. Which type of enforcement action would the agency typically pursue next to compel compliance and assess these penalties through the court system?

Accepted Answer

A civil judicial action.

Answer

Issuing a second Notice of Violation (NOV).

Answer

A criminal referral.

Answer

An informal administrative conference.

Question 3

Under the Clean Water Act, facilities with an NPDES permit are typically required to submit periodic reports summarizing their wastewater monitoring results to the permitting authority. What is this standard self-monitoring report called?

Accepted Answer

Discharge Monitoring Report (DMR).

Answer

Toxics Release Inventory (TRI) Report.

Answer

Hazardous Waste Biennial Report.

Answer

Annual Emissions Inventory.

Question 4

An inspector is reviewing a facility's compliance with the Emergency Planning and Community Right-to-Know Act (EPCRA). The facility stores 12,000 pounds of sulfuric acid (an EHS with a 500-pound threshold) and 8,000 pounds of acetone (a hazardous chemical with a 10,000-pound threshold) on-site. What is the facility's annual reporting obligation under EPCRA Sections 311-312 (Tier II)?

Accepted Answer

They must report sulfuric acid but not acetone.

Answer

They must report both sulfuric acid and acetone.

Answer

They are not required to report either chemical because the total amount is less than 20,000 pounds.

Answer

They only need to report if a release occurs.

Question 5

What is the primary purpose of an inspector's official report following a compliance inspection?

Accepted Answer

To provide a legally defensible record of the inspector's observations and findings.

Answer

To serve as the facility's new operating permit.

Answer

To negotiate the penalty amount for any violations found.

Answer

To publicize the facility's environmental performance to the local community.

Question 6

During an enforcement settlement negotiation for a Clean Water Act violation, a company offers to fund a local wetland restoration project that is not otherwise legally required. The cost of this project would partially offset the proposed cash penalty. What is this type of settlement component known as?

Accepted Answer

A Supplemental Environmental Project (SEP).

Answer

An Economic Benefit Recapture.

Answer

A Compliance Assistance Grant.

Answer

A Criminal Fine.

A facility manufactures a product using toluene, a chemical listed on the Toxics Release Inventory (TRI).The facility meets the employee threshold and manufactures more than 25,000 pounds of toluene in a year.What is this facility's primary annual reporting requirement under EPCRA Section 313?

A facility manufactures a product using toluene, a chemical listed on the Toxics Release Inventory (TRI).
The facility meets the employee threshold and manufactures more than 25,000 pounds of toluene in a year.
What is this facility's primary annual reporting requirement under EPCRA Section 313?