Free Environmental Compliance Inspector Federal Environmental Regulations Questions and Answers 1 — Questions and Answers
Question 1: Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), who must be notified immediately if a facility releases a hazardous substance in an amount equal to or greater than its Reportable Quantity (RQ)?
- The local fire department
- The State Emergency Response Commission (SERC)
- The National Response Center (NRC) (Correct answer)
- The Environmental Protection Agency (EPA) Regional Office
Correct answer: The National Response Center (NRC)
CERCLA Section 103(a) requires that the person in charge of a facility must immediately notify the National Response Center (NRC) as soon as they have knowledge of a release of a CERCLA hazardous substance in a quantity that equals or exceeds its RQ within a 24-hour period. While the SERC and local authorities are notified under EPCRA, the initial federal notification for a CERCLA release goes to the NRC.
Question 2: A facility generates 1,200 kg of non-acute hazardous waste and 0.5 kg of acutely hazardous waste in a calendar month. Under the Resource Conservation and Recovery Act (RCRA), how would this facility be classified?
- Conditionally Exempt Small Quantity Generator (CESQG)
- Small Quantity Generator (SQG)
- Large Quantity Generator (LQG) (Correct answer)
- Very Small Quantity Generator (VSQG)
Correct answer: Large Quantity Generator (LQG)
A facility is classified as a Large Quantity Generator (LQG) if it generates 1,000 kg or more of non-acute hazardous waste per month OR more than 1 kg of acutely hazardous waste per month. Since this facility generates over 1,000 kg of non-acute hazardous waste, it falls into the LQG category, which has the most stringent regulatory requirements.
Question 3: An inspector is reviewing a manufacturing plant's obligations under the Clean Air Act (CAA). The plant is planning a modification that will significantly increase its emissions of a regulated pollutant. Which CAA program is specifically designed to set technology-based emission standards for such new or modified stationary sources?
- National Ambient Air Quality Standards (NAAQS)
- Maximum Achievable Control Technology (MACT)
- New Source Performance Standards (NSPS) (Correct answer)
- Acid Rain Program
Correct answer: New Source Performance Standards (NSPS)
The New Source Performance Standards (NSPS) program, established under Section 111 of the Clean Air Act, sets nationally uniform, technology-based emission standards for new, modified, and reconstructed stationary sources. The goal is to ensure that new sources of pollution incorporate the best demonstrated control technologies.
Question 4: A facility that stores 12,000 pounds of a hazardous chemical (that is not an Extremely Hazardous Substance) is required to submit a Tier II form by March 1st each year. Which federal regulation mandates this reporting?
- Toxic Substances Control Act (TSCA)
- Emergency Planning and Community Right-to-Know Act (EPCRA) (Correct answer)
- Resource Conservation and Recovery Act (RCRA)
- Clean Water Act (CWA)
Correct answer: Emergency Planning and Community Right-to-Know Act (EPCRA)
The Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 requires facilities that store hazardous chemicals above certain thresholds to submit an annual Tier II inventory form. The threshold for most hazardous chemicals is 10,000 pounds. These reports are submitted to the SERC, LEPC, and local fire department to aid in emergency planning.
Question 5: Which of the following activities would most likely require a National Pollutant Discharge Elimination System (NPDES) permit under the Clean Water Act?
- Discharging wastewater to a publicly owned treatment works (POTW)
- A construction project that disturbs 0.5 acres of land
- A farm releasing agricultural runoff from a field into a ditch
- A manufacturing facility discharging treated wastewater from a pipe directly into a river (Correct answer)
Correct answer: A manufacturing facility discharging treated wastewater from a pipe directly into a river
The Clean Water Act's NPDES program regulates discharges of pollutants from a point source (like a pipe) into waters of the United States. A manufacturing facility discharging directly to a river is a classic example of a point source discharge requiring an NPDES permit. Discharges to a POTW are regulated under pretreatment standards, and construction activities generally require a permit only if they disturb one or more acres.
Question 6: A chemical company experiences a spill of 50 gallons of a substance defined as 'oil' under the Clean Water Act (CWA). The spill creates a visible sheen on an adjacent navigable waterway. What is the immediate reporting requirement under Section 311 of the CWA?
- Report the spill in writing to the EPA Regional Administrator within 60 days.
- No reporting is required as the volume is less than 1,000 gallons.
- Immediately notify the National Response Center (NRC). (Correct answer)
- Clean up the spill and document it in the facility's internal logbook.
Correct answer: Immediately notify the National Response Center (NRC).
Section 311 of the Clean Water Act prohibits the discharge of oil in quantities that may be harmful, which is often interpreted as a discharge that causes a sheen or sludge. Such discharges must be immediately reported to the National Response Center (NRC). The definition of 'oil' is broad and includes petroleum and non-petroleum-based oils.
