HSE Environmental Compliance and Protection Questions and Answers — Questions and Answers
Question 1: A facility in the United States generates 1,500 kg of non-acutely hazardous waste and 0.5 kg of acutely hazardous waste in a calendar month. According to the EPA's Resource Conservation and Recovery Act (RCRA), what is the facility's hazardous waste generator status?
- Small Quantity Generator (SQG)
- Very Small Quantity Generator (VSQG)
- Large Quantity Generator (LQG) (Correct answer)
- Conditionally Exempt Small Quantity Generator (CESQG)
Correct answer: Large Quantity Generator (LQG)
Under RCRA, a facility is classified as a Large Quantity Generator (LQG) if it generates 1,000 kg or more of non-acutely hazardous waste per month OR more than 1 kg of acutely hazardous waste per month. Since this facility generates 1,500 kg, it exceeds the 1,000 kg threshold and is therefore an LQG.
Question 2: Under the U.S. Clean Water Act (CWA), what is the primary purpose of a Stormwater Pollution Prevention Plan (SWPPP)?
- To document procedures for treating process wastewater before discharge to a municipal sewer.
- To identify potential pollutant sources and describe the Best Management Practices (BMPs) to prevent them from contaminating stormwater discharges. (Correct answer)
- To report the annual quantity of toxic chemicals released into surface waters.
- To obtain a permit for dredging or filling activities in navigable U.S. waters.
Correct answer: To identify potential pollutant sources and describe the Best Management Practices (BMPs) to prevent them from contaminating stormwater discharges.
A SWPPP is a site-specific plan required by the National Pollutant Discharge Elimination System (NPDES) permit program. Its fundamental purpose is to identify potential sources of stormwater pollution and detail the control measures, known as Best Management Practices (BMPs), that will be implemented to minimize or eliminate the discharge of these pollutants into local water bodies.
Question 3: When developing an Environmental Management System (EMS) compliant with ISO 14001, which of the following best defines an 'environmental aspect'?
- Any change to the environment, whether adverse or beneficial, resulting from the organization's activities.
- A specific, measurable environmental performance target set by the organization.
- An element of an organization's activities, products, or services that can interact with the environment. (Correct answer)
- A legal requirement related to environmental protection that the organization must adhere to.
Correct answer: An element of an organization's activities, products, or services that can interact with the environment.
ISO 14001 defines an 'environmental aspect' as the cause—an element of an organization's activities, products, or services that interacts with the environment. The resulting 'environmental impact' is the effect—the change to the environment. For example, the use of electricity is an aspect, while the resulting depletion of natural resources is the impact.
Question 4: A facility accidentally releases 120 pounds of anhydrous ammonia, which has a reportable quantity (RQ) of 100 pounds under CERCLA and is also an Extremely Hazardous Substance (EHS) under EPCRA. What is the facility's immediate reporting obligation?
- Document the release for the annual Toxic Release Inventory (TRI) report.
- Clean up the spill and report it during the next regulatory inspection.
- Immediately notify the National Response Center (NRC), the State Emergency Response Commission (SERC), and the Local Emergency Planning Committee (LEPC). (Correct answer)
- Notify only the local fire department within 24 hours.
Correct answer: Immediately notify the National Response Center (NRC), the State Emergency Response Commission (SERC), and the Local Emergency Planning Committee (LEPC).
When a release of a substance exceeds its Reportable Quantity (RQ) under both CERCLA and EPCRA, federal law requires immediate notification. The facility must notify the National Response Center (NRC) to satisfy CERCLA, and the SERC and LEPC to satisfy EPCRA.
Question 5: Which of the following activities is the best example of Pollution Prevention (P2) at the source?
- Changing a manufacturing process to use a non-toxic, water-based solvent instead of a chlorinated solvent. (Correct answer)
- Installing a carbon filter to capture volatile organic compounds (VOCs) before they are emitted from a stack.
- Sending used solvents to a third-party facility to be recycled and reused.
- Disposing of hazardous waste at a licensed high-temperature incinerator.
Correct answer: Changing a manufacturing process to use a non-toxic, water-based solvent instead of a chlorinated solvent.
Pollution Prevention (P2), or source reduction, is the most preferred strategy in the waste management hierarchy. It involves practices that reduce or eliminate the creation of pollutants in the first place. Substituting a hazardous material with a non-hazardous one is a prime example of source reduction. The other options represent control, recycling, and disposal, which are lower on the hierarchy.
Question 6: A facility stores 12,000 pounds of sulfuric acid on-site. The Threshold Planning Quantity (TPQ) for sulfuric acid as an Extremely Hazardous Substance (EHS) is 1,000 pounds. Under the Emergency Planning and Community Right-to-Know Act (EPCRA), what is a key requirement for this facility?
- Prepare a hazardous waste contingency plan under RCRA.
- Develop a Spill Prevention, Control, and Countermeasure (SPCC) plan.
- Notify its SERC and LEPC of its EHS presence and cooperate in emergency plan development. (Correct answer)
- Submit a risk management plan (RMP) to the EPA under the Clean Air Act.
Correct answer: Notify its SERC and LEPC of its EHS presence and cooperate in emergency plan development.
EPCRA Section 302 requires facilities that have an Extremely Hazardous Substance (EHS) on-site in an amount equal to or greater than its Threshold Planning Quantity (TPQ) to notify the State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC). This notification obligates the facility to participate in the community's emergency planning process.
HSE Environmental Compliance and Protection Questions and Answers
A facility in the United States generates 1,500 kg of non-acutely hazardous waste and 0.5 kg of acutely hazardous waste in a calendar month.
According to the EPA's Resource Conservation and Recovery Act (RCRA), what is the facility's hazardous waste generator status?