CPWM Regulatory Compliance and Environmental Safety 2 — Questions and Answers
Question 1: Under RCRA Subtitle C, which characteristic makes a solid waste a hazardous waste?
- Ignitability, corrosivity, reactivity, or toxicity (Correct answer)
- Radioactivity, flammability, or pathogenicity
- High volume, low density, or inert composition
- Biodegradability, solubility, or volatility
Correct answer: Ignitability, corrosivity, reactivity, or toxicity
RCRA Subtitle C defines hazardous waste by four characteristics: ignitability, corrosivity, reactivity, and toxicity (TCLP).
Question 2: Which EPA program regulates underground storage tanks (USTs) containing petroleum or hazardous substances?
- RCRA Subtitle I (Correct answer)
- CERCLA Section 103
- TSCA Title VI
- CAA Section 112
Correct answer: RCRA Subtitle I
RCRA Subtitle I establishes the federal UST regulatory program covering leak detection, spill prevention, and corrective action.
Question 3: A waste generator ships hazardous waste without a manifest to an unpermitted facility. Which penalty category applies under RCRA?
- Class I administrative penalty
- Criminal felony with imprisonment up to 5 years (Correct answer)
- Civil penalty only, capped at $1,000
- Warning letter for first offense
Correct answer: Criminal felony with imprisonment up to 5 years
Knowingly transporting hazardous waste to an unpermitted facility is a criminal violation under RCRA Section 3008(d), punishable by fines and up to 5 years imprisonment.
Question 4: What is the primary purpose of the Toxicity Characteristic Leaching Procedure (TCLP)?
- To simulate leaching of contaminants from waste into groundwater (Correct answer)
- To measure the pH of liquid waste streams
- To determine the ignition temperature of solid waste
- To quantify the radioactive decay rate of mixed waste
Correct answer: To simulate leaching of contaminants from waste into groundwater
TCLP simulates how contaminants leach from landfill-disposed waste into groundwater, determining if a waste exhibits the toxicity characteristic.
Question 5: Which federal law requires facilities to report releases of hazardous substances above reportable quantities to the National Response Center?
- CERCLA Section 103 (Correct answer)
- RCRA Section 3002
- EPCRA Section 313
- SDWA Section 1431
Correct answer: CERCLA Section 103
CERCLA Section 103 requires immediate notification to the National Response Center when a reportable quantity of a hazardous substance is released.
Question 6: Under the Clean Water Act, a facility discharging pollutants into navigable waters must obtain which permit?
- NPDES permit (Correct answer)
- UIC permit
- Title V operating permit
- RCRA Part B permit
Correct answer: NPDES permit
The National Pollutant Discharge Elimination System (NPDES) permit, established under CWA Section 402, is required for any point-source discharge to waters of the US.
Question 7: A small quantity generator (SQG) under RCRA generates between what monthly waste quantities?
- 100 kg and 1,000 kg (Correct answer)
- Less than 100 kg
- Greater than 1,000 kg
- 1,000 kg to 10,000 kg
Correct answer: 100 kg and 1,000 kg
SQGs generate between 100 kg and 1,000 kg of hazardous waste per month and have intermediate compliance requirements compared to VSQGs and LQGs.
Under RCRA Subtitle C, which characteristic makes a solid waste a hazardous waste?