HSE Environmental Compliance and Protection 2 — Questions and Answers
Question 1: Under RCRA, which category of hazardous waste generator is subject to the most stringent regulatory requirements?
- Very Small Quantity Generator (VSQG)
- Small Quantity Generator (SQG)
- Large Quantity Generator (LQG) (Correct answer)
- Conditionally Exempt Generator (CEG)
Correct answer: Large Quantity Generator (LQG)
Large Quantity Generators (LQGs) that generate 1,000 kg or more of hazardous waste per month face the most stringent RCRA requirements, including 90-day storage limits and full contingency plan requirements.
Question 2: Which section of the Clean Water Act requires facilities discharging pollutants into navigable waters to obtain a permit?
- Section 301
- Section 404
- Section 402 (Correct answer)
- Section 311
Correct answer: Section 402
Section 402 of the Clean Water Act establishes the National Pollutant Discharge Elimination System (NPDES) permit program for point source discharges into navigable waters.
Question 3: What is the primary purpose of a Stormwater Pollution Prevention Plan (SWPPP)?
- To document annual rainfall totals at a facility
- To identify and implement Best Management Practices to reduce pollutants in stormwater runoff (Correct answer)
- To calculate the volume of stormwater entering a facility's drainage system
- To establish flood control measures for nearby waterways
Correct answer: To identify and implement Best Management Practices to reduce pollutants in stormwater runoff
A SWPPP identifies potential sources of stormwater pollution and describes Best Management Practices (BMPs) to prevent pollutants from reaching receiving waters.
Question 4: Which EPA regulation governs the management of underground storage tanks (USTs) containing petroleum or hazardous substances?
- CERCLA
- RCRA Subtitle I (Correct answer)
- TSCA
- EPCRA
Correct answer: RCRA Subtitle I
RCRA Subtitle I specifically regulates underground storage tanks, requiring leak detection, spill and overfill prevention, and financial assurance for corrective action.
Question 5: A company discovers that a neighboring property's historical contamination is migrating onto their site. Under CERCLA, what defense might protect the company from liability?
- Act of God defense
- Innocent Landowner defense (Correct answer)
- Third-party liability waiver
- Statute of limitations defense
Correct answer: Innocent Landowner defense
The Innocent Landowner defense under CERCLA protects parties who conducted appropriate inquiry before purchase and had no knowledge of contamination at the time of acquisition.
Question 6: What does 'secondary containment' refer to in the context of chemical storage?
- A backup alarm system for chemical leaks
- A structure designed to contain spills or leaks from primary containers (Correct answer)
- Secondary labeling requirements on chemical drums
- An additional layer of personal protective equipment
Correct answer: A structure designed to contain spills or leaks from primary containers
Secondary containment is a physical barrier such as a berm, dike, or containment basin designed to capture leaks or spills from primary storage containers before they reach the environment.
Question 7: Under the Emergency Planning and Community Right-to-Know Act (EPCRA), what triggers the requirement to report a chemical release to the National Response Center?
- Any amount of a listed hazardous substance released to the environment
- A release that exceeds the Reportable Quantity (RQ) of a hazardous substance (Correct answer)
- A release that causes visible environmental damage
- A release that occurs outside normal working hours
Correct answer: A release that exceeds the Reportable Quantity (RQ) of a hazardous substance
EPCRA Section 304 requires immediate notification to the NRC and local emergency planning committees when a release of a listed hazardous substance exceeds its established Reportable Quantity.
HSE Environmental Compliance and Protection 2
Under RCRA, which category of hazardous waste generator is subject to the most stringent regulatory requirements?