DEQ Hazardous Materials and Chemical Regulations 2 — Questions and Answers
Question 1: What is the Toxics Release Inventory (TRI) and which federal law requires it?
- A DEQ database of permitted facilities, required by RCRA
- An annual public report of toxic chemical releases to the environment, required by EPCRA Section 313 (Correct answer)
- A state inventory of contaminated sites, required by CERCLA
- A federal registry of hazardous waste transporters, required by DOT regulations
Correct answer: An annual public report of toxic chemical releases to the environment, required by EPCRA Section 313
The TRI is an annual public reporting program under EPCRA Section 313 that requires certain industries to report their releases and transfers of listed toxic chemicals to the environment.
Question 2: Under DEQ hazardous materials regulations, what does 'land disposal restrictions' (LDR) mean?
- Prohibition on siting new hazardous waste facilities near residential areas
- Requirements that hazardous wastes meet specific treatment standards before being disposed of in land-based units (Correct answer)
- Limits on the total acreage of a permitted hazardous waste landfill
- Zoning rules governing chemical storage near bodies of water
Correct answer: Requirements that hazardous wastes meet specific treatment standards before being disposed of in land-based units
LDRs under RCRA prohibit land disposal of hazardous wastes unless they first meet EPA-established treatment standards designed to reduce toxicity and mobility.
Question 3: Which generator category under RCRA has the most stringent requirements for storage time limits and waste management?
- Very small quantity generator (VSQG)
- Small quantity generator (SQG)
- Large quantity generator (LQG) (Correct answer)
- Conditionally exempt small quantity generator (CESQG)
Correct answer: Large quantity generator (LQG)
Large quantity generators (LQGs), those generating 1,000 kg or more of hazardous waste per month, face the strictest RCRA requirements including 90-day storage limits and full manifest requirements.
Question 4: What is the purpose of a hazardous waste manifest under RCRA?
- To certify that a facility's treatment equipment meets design specifications
- To track hazardous waste shipments from the generator through transportation to the final disposal site (Correct answer)
- To document the chemical composition of a hazardous waste for LDR purposes
- To register a hazardous waste transporter with the state DEQ
Correct answer: To track hazardous waste shipments from the generator through transportation to the final disposal site
The hazardous waste manifest is a tracking document that accompanies waste shipments, ensuring accountability from the point of generation to final disposal.
Question 5: Under CERCLA (Superfund), who can be held liable for cleanup costs at a contaminated site?
- Only the entity that currently owns the contaminated property
- Only the company that originally disposed of the hazardous substances
- Any potentially responsible party including current owners, past owners, generators, and transporters (Correct answer)
- Only federal government contractors who operated the site
Correct answer: Any potentially responsible party including current owners, past owners, generators, and transporters
CERCLA imposes broad, joint and several, and retroactive liability on potentially responsible parties (PRPs), including current and past owners, operators, generators, and transporters of hazardous substances.
Question 6: What chemical regulation requires facilities with processes involving highly hazardous chemicals above threshold quantities to develop a Process Hazard Analysis (PHA)?
- RCRA hazardous waste standards
- OSHA Process Safety Management (PSM) Standard (Correct answer)
- EPCRA emergency planning requirements
- DEQ air toxics permit conditions
Correct answer: OSHA Process Safety Management (PSM) Standard
OSHA's PSM Standard (29 CFR 1910.119) requires facilities with highly hazardous chemicals above threshold quantities to conduct PHAs to identify and control process hazards.
DEQ Hazardous Materials and Chemical Regulations 2
What is the Toxics Release Inventory (TRI) and which federal law requires it?