Environmental Compliance Inspector Environmental Laws and Regulations 3 — Questions and Answers
Question 1: A facility that generates between 100 and 1,000 kg of hazardous waste per month is classified under RCRA as a:
- Very Small Quantity Generator (VSQG)
- Small Quantity Generator (SQG) (Correct answer)
- Large Quantity Generator (LQG)
- Conditionally Exempt Small Quantity Generator (CESQG)
Correct answer: Small Quantity Generator (SQG)
Under the 2016 Generator Improvements Rule, facilities generating 100–1,000 kg/month of hazardous waste are classified as Small Quantity Generators with specific storage time and manifest requirements.
Question 2: Which CERCLA provision allows EPA to recover cleanup costs from PRPs after completing a removal or remedial action?
- Section 103 notification requirements
- Section 104 response authority
- Section 107 liability provisions (Correct answer)
- Section 121 cleanup standards
Correct answer: Section 107 liability provisions
CERCLA Section 107 establishes the liability framework that allows EPA (or private parties) to recover response costs from PRPs including owners, operators, generators, and transporters.
Question 3: Under the Clean Air Act, what distinguishes a 'major source' from an 'area source' for hazardous air pollutant regulation?
- Major sources emit more than 10 tons/yr of a single HAP or 25 tons/yr of combined HAPs (Correct answer)
- Major sources are regulated only in non-attainment areas
- Major sources are defined solely by the number of employees at a facility
- Major sources emit more than 100 tons/yr of any regulated pollutant
Correct answer: Major sources emit more than 10 tons/yr of a single HAP or 25 tons/yr of combined HAPs
Under CAA Section 112, a major source emits or has the potential to emit ≥10 tons/yr of any single HAP or ≥25 tons/yr of any combination of HAPs; area sources emit below these thresholds.
Question 4: NEPA requires federal agencies to prepare an Environmental Impact Statement (EIS) for actions that are found to 'significantly affect' the quality of the human environment. What document is typically prepared first to determine if an EIS is needed?
- Finding of No Significant Impact (FONSI)
- Record of Decision (ROD)
- Environmental Assessment (EA) (Correct answer)
- Categorical Exclusion (CE)
Correct answer: Environmental Assessment (EA)
An Environmental Assessment is a concise public document that briefly provides evidence for determining whether an EIS is required or if a FONSI can be issued.
Question 5: Under EPCRA Section 302, which category of chemicals requires facilities to notify Local Emergency Planning Committees (LEPCs) if stored above threshold planning quantities?
- Toxic Release Inventory chemicals
- Extremely Hazardous Substances (EHS) (Correct answer)
- RCRA listed hazardous wastes
- TSCA new chemical substances
Correct answer: Extremely Hazardous Substances (EHS)
EPCRA Section 302 requires facilities that store Extremely Hazardous Substances above their Threshold Planning Quantities to notify the LEPC and participate in emergency planning.
Question 6: The Clean Water Act's Section 404 program, administered by the Army Corps of Engineers, regulates what activity?
- Discharge of industrial process wastewater to navigable waters
- Dredge and fill activities in waters of the United States, including wetlands (Correct answer)
- Stormwater discharges from municipal separate storm sewer systems
- Ocean dumping of dredged material beyond the 12-mile limit
Correct answer: Dredge and fill activities in waters of the United States, including wetlands
CWA Section 404 authorizes the Corps of Engineers to issue permits for discharge of dredged or fill material into waters of the US, which includes wetlands.
Question 7: Under TSCA Section 5, a manufacturer must submit a Premanufacture Notice (PMN) to EPA before:
- Importing any existing chemical substance in quantities above 25,000 lbs
- Manufacturing or importing a new chemical substance not on the TSCA Inventory (Correct answer)
- Exporting any chemical substance to countries without equivalent regulations
- Distributing a chemical substance to consumers for the first time
Correct answer: Manufacturing or importing a new chemical substance not on the TSCA Inventory
TSCA Section 5 requires a PMN be submitted to EPA at least 90 days before manufacturing or importing a chemical substance not already listed on the TSCA Chemical Substance Inventory.
Environmental Compliance Inspector Environmental Laws and Regulations 3
A facility that generates between 100 and 1,000 kg of hazardous waste per month is classified under RCRA as a: