HSE Environmental Compliance and Protection 5 — Questions and Answers
Question 1: Under EPA's Risk Management Program (RMP) under CAA Section 112(r), what is the primary goal of a Process Hazard Analysis (PHA) for facilities handling regulated substances?
- To calculate annual chemical release quantities for TRI reporting
- To systematically identify and evaluate hazards associated with processes to prevent accidental releases (Correct answer)
- To develop employee training schedules for chemical handling
- To determine the financial cost of environmental compliance
Correct answer: To systematically identify and evaluate hazards associated with processes to prevent accidental releases
A PHA is a structured, systematic examination of a chemical process to identify potential hazards, causes of accidental releases, and risk reduction measures as required under the RMP rule.
Question 2: Which term describes the concentration of a pollutant in surface water, sediment, or biota above which adverse ecological effects are expected to occur?
- Threshold Limit Value (TLV)
- Benchmark Concentration (BMC)
- Criterion Continuous Concentration (CCC) (Correct answer)
- Regulatory Action Level (RAL)
Correct answer: Criterion Continuous Concentration (CCC)
The Criterion Continuous Concentration (CCC), also called the chronic criterion, is the EPA water quality criterion level above which chronic adverse effects on aquatic life are expected with prolonged exposure.
Question 3: A construction site disturbs more than 1 acre of land. Under the Clean Water Act, what permit is required to manage stormwater discharges from the site?
- Section 404 Dredge and Fill Permit
- NPDES Construction General Permit (CGP) (Correct answer)
- RCRA Land Disposal Permit
- TSCA Chemical Use Authorization
Correct answer: NPDES Construction General Permit (CGP)
Construction sites disturbing 1 or more acres must obtain coverage under an NPDES Construction General Permit (CGP) and develop a SWPPP to control stormwater runoff and prevent pollutant discharges.
Question 4: Which of the following best describes a 'deed restriction' as an institutional control in environmental remediation?
- A physical barrier such as a cap installed over contaminated soil
- A legal limitation recorded in property records that restricts future land use to prevent exposure to residual contamination (Correct answer)
- A treatment technology that permanently destroys contaminants in place
- A monitoring program that tracks contaminant migration over time
Correct answer: A legal limitation recorded in property records that restricts future land use to prevent exposure to residual contamination
A deed restriction is a legally recorded land use control that limits activities (e.g., prohibiting residential use or well drilling) on property with residual contamination that does not meet unrestricted cleanup standards.
Question 5: Under the Clean Air Act's Prevention of Significant Deterioration (PSD) program, which facilities must apply for a PSD permit before construction?
- Any facility that emits any regulated air pollutant
- New major sources or major modifications in attainment areas that exceed specified emission thresholds (Correct answer)
- All facilities located within 10 miles of a national park or wilderness area
- Only facilities that emit sulfur dioxide or nitrogen oxides above 100 tons per year
Correct answer: New major sources or major modifications in attainment areas that exceed specified emission thresholds
PSD applies to new major stationary sources and major modifications of existing sources located in areas that meet National Ambient Air Quality Standards (NAAQS), requiring Best Available Control Technology (BACT) analysis.
Question 6: What is the primary regulatory purpose of the Spill Prevention, Control, and Countermeasure (SPCC) rule under the Clean Water Act?
- To set cleanup standards for petroleum-contaminated groundwater
- To prevent oil discharges from reaching navigable waters or adjoining shorelines through engineering controls and response planning (Correct answer)
- To regulate the transportation of hazardous liquids by pipeline
- To establish effluent limits for oil refineries discharging to surface water
Correct answer: To prevent oil discharges from reaching navigable waters or adjoining shorelines through engineering controls and response planning
The SPCC rule (40 CFR Part 112) requires facilities with above-threshold oil storage capacity to prepare and implement plans with secondary containment and other engineering controls to prevent oil from reaching navigable waters.
Question 7: An HSE professional is conducting a compliance audit and finds that the facility's wastewater discharge permit limit for total suspended solids (TSS) is 30 mg/L, but recent monitoring data shows discharges averaging 45 mg/L. What is the most appropriate immediate action?
- Continue monitoring and report the exceedance in the next annual report
- Notify the permitting authority as required by the permit, identify the root cause, and implement corrective actions (Correct answer)
- Dilute the wastewater stream to bring TSS within permit limits
- Halt all facility operations until the TSS level is reduced
Correct answer: Notify the permitting authority as required by the permit, identify the root cause, and implement corrective actions
NPDES permits typically require self-reporting of exceedances; immediate notification to the regulatory authority, coupled with root cause analysis and corrective action, is the legally required and professionally appropriate response.
HSE Environmental Compliance and Protection 5
Under EPA's Risk Management Program (RMP) under CAA Section 112(r), what is the primary goal of a Process Hazard Analysis (PHA) for facilities handling regulated substances?