CESCO - Certified Environmental, Safety and Compliance Officer Emergency Preparedness and Response Questions and Answers — Questions and Answers
Question 1: A facility stores 750 pounds of anhydrous ammonia, which is listed as an Extremely Hazardous Substance (EHS) with a Threshold Planning Quantity (TPQ) of 500 pounds. What is the facility's primary notification requirement under EPCRA Sections 302-303?
- Submit annual Toxic Release Inventory (TRI) Form R reports to the EPA.
- Develop and submit a Risk Management Plan (RMP) to the EPA.
- Notify the SERC and LEPC of the presence of the EHS and designate a facility emergency coordinator. (Correct answer)
- Submit annual Tier II hazardous chemical inventory forms to the SERC, LEPC, and local fire department.
Correct answer: Notify the SERC and LEPC of the presence of the EHS and designate a facility emergency coordinator.
EPCRA Section 302 requires a facility to notify the State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC) within 60 days of having an Extremely Hazardous Substance (EHS) on-site in an amount equal to or greater than its threshold planning quantity (TPQ). The facility must also designate a representative to participate in the local emergency planning process. While Tier II forms and RMPs might also be required, the initial step for emergency planning under Section 302 is this specific notification.
Question 2: A facility's Spill Prevention, Control, and Countermeasure (SPCC) Plan must be certified by a Professional Engineer (PE). However, certain "qualified facilities" can self-certify their plans. Which of the following conditions must be met for a facility to be considered a qualified facility eligible for self-certification?
- The facility has a total aboveground oil storage capacity of 10,000 U.S. gallons or less and has not had a significant oil spill in the past three years. (Correct answer)
- The facility has any amount of oil storage but is located more than 10 miles from a navigable waterway.
- The facility stores only non-petroleum oils like animal fats and vegetable oils.
- The facility's total oil storage capacity is less than 42,000 gallons and it is not a "major source" under the Clean Air Act.
Correct answer: The facility has a total aboveground oil storage capacity of 10,000 U.S. gallons or less and has not had a significant oil spill in the past three years.
Under 40 CFR Part 112, a Tier I or Tier II qualified facility can self-certify its SPCC Plan. To qualify, the facility must have a total aggregate aboveground oil storage capacity of 10,000 U.S. gallons or less and, in the three years prior, has not had a single discharge of oil to navigable waters exceeding 1,000 gallons or two discharges each exceeding 42 gallons.
Question 3: According to OSHA's standard on Emergency Action Plans (EAP), 29 CFR 1910.38, which of the following elements is required to be included in the plan?
- A detailed list of all hazardous chemicals stored on-site with their corresponding Safety Data Sheets.
- Procedures for employees who remain to operate critical plant operations before they evacuate. (Correct answer)
- The name and specific qualifications of the on-site HAZMAT team leader.
- A copy of the facility's most recent air permit and stormwater pollution prevention plan.
Correct answer: Procedures for employees who remain to operate critical plant operations before they evacuate.
OSHA's standard 29 CFR 1910.38(c) specifies the minimum required elements of an Emergency Action Plan. This includes procedures for reporting an emergency, evacuation procedures, and procedures to be followed by employees who remain to operate critical plant operations before they evacuate.
Question 4: During an emergency response to a chemical spill of an unknown substance, a response team is preparing to enter the hot zone. The team leader determines that the atmosphere poses the highest level of respiratory, skin, and eye hazard due to high concentrations of toxic and skin-absorbable vapors. What is the minimum level of PPE required for this entry under OSHA's HAZWOPER standard?
- Level C
- Level B
- Level D
- Level A (Correct answer)
Correct answer: Level A
Level A protection is required when the greatest potential for exposure exists and the highest level of skin, respiratory, and eye protection is needed. It consists of a fully encapsulating, chemical-resistant suit with a positive pressure self-contained breathing apparatus (SCBA). This level is appropriate for situations involving high concentrations of unknown or highly toxic, skin-absorbable substances.
Question 5: Which of the following best distinguishes the primary purpose of the EPA's Risk Management Plan (RMP) Rule from the planning requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)?
- EPCRA applies to all OSHA-defined hazardous chemicals, while RMP applies only to flammable substances.
- RMP is focused on preventing accidental releases at the source, while EPCRA is focused on community emergency response planning for releases that occur. (Correct answer)
- RMP plans are submitted to the LEPC and SERC, while EPCRA plans are submitted directly to the EPA.
- RMP is an OSHA regulation for worker safety, while EPCRA is an EPA regulation for environmental protection.
Correct answer: RMP is focused on preventing accidental releases at the source, while EPCRA is focused on community emergency response planning for releases that occur.
While both programs deal with hazardous substances, the RMP rule (under the Clean Air Act) is primarily focused on prevention. It requires facilities to identify hazards and design and maintain a safe facility to prevent accidental releases. EPCRA's emergency planning sections (301-303) are focused on ensuring that the community, through LEPCs and SERCs, is prepared to respond effectively to a chemical release that does occur.
Question 6: A CESCO is participating in a full-scale emergency drill at their facility that involves multiple outside agencies, including the local fire department and county HAZMAT team. To ensure effective and efficient management of this multi-agency response, what standardized management structure should be implemented?
- The Corporate Crisis Management Team
- The HAZWOPER Site Safety and Health Plan
- The Incident Command System (ICS) (Correct answer)
- The Emergency Operations Center (EOC)
Correct answer: The Incident Command System (ICS)
The Incident Command System (ICS) is a standardized, on-scene management system designed for all-hazards incidents to allow for the integration of facilities, equipment, personnel, procedures, and communications operating within a common organizational structure. It is the national standard for managing multi-agency responses.
CESCO - Certified Environmental, Safety and Compliance Officer Emergency Preparedness and Response Questions and Answers
A facility stores 750 pounds of anhydrous ammonia, which is listed as an Extremely Hazardous Substance (EHS) with a Threshold Planning Quantity (TPQ) of 500 pounds.
What is the facility's primary notification requirement under EPCRA Sections 302-303?