UMC Regulatory Compliance & Risk Management 2 — Questions and Answers
Question 1: Under the Clean Water Act, what is the primary regulatory mechanism utilities use to discharge treated wastewater into surface waters?
- National Pollution Discharge Elimination System (NPDES) permit (Correct answer)
- State Revolving Fund (SRF) agreement
- Sanitary Survey authorization
- Safe Drinking Water Act variance
Correct answer: National Pollution Discharge Elimination System (NPDES) permit
The NPDES permit program under the Clean Water Act controls water pollution by regulating point sources that discharge pollutants into navigable waters.
Question 2: A utility discovers that a chemical spill has contaminated groundwater near a wellfield. Which federal law most directly governs the cleanup liability and response actions?
- Safe Drinking Water Act (SDWA)
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (Correct answer)
- Resource Conservation and Recovery Act (RCRA)
- National Environmental Policy Act (NEPA)
Correct answer: Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
CERCLA (Superfund) governs cleanup of hazardous substance releases and assigns liability for remediation costs.
Question 3: What does a 'consent order' from a state environmental agency typically require a utility to do?
- Voluntarily upgrade infrastructure within a self-set timeline
- Comply with a legally binding corrective action plan under regulatory oversight (Correct answer)
- Pay a one-time fine with no further obligations
- Transfer operational control to the state temporarily
Correct answer: Comply with a legally binding corrective action plan under regulatory oversight
A consent order is an enforceable legal agreement between a utility and a regulatory agency outlining specific corrective actions and deadlines.
Question 4: Which risk assessment method assigns numerical probabilities to failure events and calculates expected consequences?
- SWOT Analysis
- Failure Mode and Effects Analysis (FMEA)
- Quantitative Risk Assessment (QRA) (Correct answer)
- Bowtie Analysis
Correct answer: Quantitative Risk Assessment (QRA)
Quantitative Risk Assessment uses numerical probabilities and consequence values to calculate risk scores for prioritizing mitigation efforts.
Question 5: Under EPA's Lead and Copper Rule, what action is required when a utility's 90th percentile lead level exceeds the action level?
- Immediately shut down the distribution system
- Issue a Do Not Drink advisory and begin corrosion control treatment
- Notify the state and begin a public education program while optimizing corrosion control (Correct answer)
- Replace all service lines within 30 days
Correct answer: Notify the state and begin a public education program while optimizing corrosion control
When the action level is exceeded, utilities must notify the state, initiate or optimize corrosion control treatment, and conduct public education outreach.
Question 6: A utility manager is reviewing an insurance policy that covers losses from a cyberattack on SCADA systems. This coverage falls under which risk management strategy?
- Risk avoidance
- Risk retention
- Risk transfer (Correct answer)
- Risk reduction
Correct answer: Risk transfer
Purchasing insurance transfers the financial consequences of a risk to a third party (the insurer), making it a risk transfer strategy.
Question 7: Which federal regulation requires water utilities to conduct vulnerability assessments and submit them to EPA?
- America's Water Infrastructure Act (AWIA) of 2018 (Correct answer)
- Homeland Security Act of 2002
- Safe Drinking Water Act Amendments of 1996
- Water Resources Development Act (WRDA)
Correct answer: America's Water Infrastructure Act (AWIA) of 2018
AWIA 2018 requires community water systems serving more than 3,300 people to conduct risk and resilience assessments and certify completion to EPA.
Under the Clean Water Act, what is the primary regulatory mechanism utilities use to discharge treated wastewater into surface waters?