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REP practice questions

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Question 1Environmental compliance

Under the Resource Conservation and Recovery Act (RCRA), which characteristic makes a solid waste a hazardous waste when it leaches toxic constituents at or above regulatory levels using the Toxicity Characteristic Leaching Procedure (TCLP)?

  1. Ignitability
  2. Toxicity Correct answer.
  3. Reactivity
  4. Corrosivity

Explanation

RCRA defines four hazardous waste characteristics: ignitability, corrosivity, reactivity, and toxicity. The toxicity characteristic is determined by the TCLP, which simulates landfill leaching and compares concentrations of listed constituents against regulatory limits.

Question 2Environmental compliance

A facility generates 1,200 kg of hazardous waste in a single month. Under RCRA generator categories, how is the facility classified?

  1. Conditionally exempt generator (CEG)
  2. Small quantity generator (SQG)
  3. Large quantity generator (LQG) Correct answer.
  4. Very small quantity generator (VSQG)

Explanation

RCRA generator categories are based on monthly generation rates. A large quantity generator produces 1,000 kg or more per month, so 1,200 kg places this facility in the LQG category.

Question 3Environmental compliance

Which federal statute is the primary law governing the cleanup of releases of hazardous substances at contaminated sites and establishes the Superfund program?

  1. Safe Drinking Water Act (SDWA)
  2. Clean Water Act (CWA)
  3. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Correct answer.
  4. Clean Air Act (CAA)

Explanation

CERCLA, enacted in 1980, created the Superfund program and provides authority to respond to releases of hazardous substances and to recover cleanup costs from responsible parties. The other statutes regulate air, surface water, and drinking water rather than site remediation liability.

Question 4Environmental compliance

Under the Clean Water Act National Pollutant Discharge Elimination System (NPDES) program, what is the primary mechanism used to authorize point source discharges to waters of the United States?

  1. A Phase I environmental site assessment
  2. A Tier II chemical inventory report
  3. An NPDES permit with effluent limitations Correct answer.
  4. A Spill Prevention, Control, and Countermeasure plan

Explanation

The NPDES program requires a permit for point source discharges, and that permit contains effluent limitations and monitoring requirements. SPCC plans, Tier II reports, and Phase I assessments address different regulatory obligations.

Question 5Environmental compliance

Which reportable quantity (RQ) framework applies when a hazardous substance is released to the environment under CERCLA?

  1. Only releases exceeding 10,000 pounds must be reported to the National Response Center
  2. Releases of a hazardous substance equal to or greater than its assigned RQ must be reported to the National Response Center Correct answer.
  3. Any release, regardless of quantity, must be reported to the National Response Center
  4. Releases must be reported only if they reach surface water

Explanation

CERCLA assigns reportable quantities to hazardous substances, and a release meeting or exceeding the RQ triggers notification to the National Response Center. Reporting is quantity-based rather than dependent on the receiving medium.

Question 6Environmental compliance

A facility stores 15,000 pounds of a hazardous chemical on site. Under the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312, which threshold generally triggers Tier II reporting for a hazardous chemical?

  1. 10,000 pounds Correct answer.
  2. 500 pounds
  3. 100 pounds
  4. 1,000 pounds

Explanation

EPCRA Section 312 generally requires Tier II reporting when a hazardous chemical is present at or above 10,000 pounds at any time during the year. Certain extremely hazardous substances have lower planning thresholds under Section 302.

Question 7Environmental compliance

Which document must a facility prepare under the Spill Prevention, Control, and Countermeasure (SPCC) rule to address potential oil discharges?

  1. A stormwater pollution prevention plan
  2. A risk management plan
  3. A hazardous waste manifest
  4. An SPCC plan certified by a professional engineer or qualified self-certifier Correct answer.

Explanation

The SPCC rule requires facilities meeting oil storage thresholds to prepare and implement a plan describing prevention and control measures. The plan must be certified by a licensed professional engineer or, for qualifying facilities, by a self-certifier.

Question 8Environmental compliance

Which agency administers the Toxics Release Inventory (TRI) program established under EPCRA Section 313?

  1. The Federal Energy Regulatory Commission (FERC)
  2. The Occupational Safety and Health Administration (OSHA)
  3. The Department of Transportation (DOT)
  4. The U.S. Environmental Protection Agency (EPA) Correct answer.

Explanation

The EPA administers the TRI program, which requires certain facilities to report releases and waste management of listed toxic chemicals annually. The other agencies regulate worker safety, transport, and energy respectively.

Question 9Environmental compliance

A manufacturing plant is subject to the Clean Air Act Title V operating permit program. Which statement best describes the purpose of a Title V permit?

  1. It authorizes the facility to emit any pollutant without limits
  2. It consolidates applicable air requirements into a single enforceable permit with monitoring and reporting obligations Correct answer.
  3. It replaces the need for New Source Review permits
  4. It exempts the facility from all emission limitations

Explanation

Title V permits are intended to compile all applicable Clean Air Act requirements for a major source into one document and impose monitoring, recordkeeping, and reporting. They do not relax or eliminate underlying emission limits.

Question 10Environmental compliance

Under the Clean Air Act New Source Review program, a major modification at an existing major source that significantly increases emissions may require which of the following?

  1. A prevention of significant deterioration (PSD) permit with best available control technology Correct answer.
  2. A National Pollutant Discharge Elimination System permit
  3. An underground storage tank registration
  4. A Tier II inventory report

Explanation

In attainment areas, a major modification causing a significant emissions increase triggers PSD review, which requires best available control technology and demonstration that air quality is protected. The other options are unrelated to air permitting.

Question 11Environmental compliance

A facility's hazardous waste accumulation area lacks proper containment and labeling. Which RCRA requirement is most directly violated?

  1. The Toxicity Characteristic Leaching Procedure
  2. The Phase I environmental site assessment standard
  3. The National Ambient Air Quality Standards
  4. Accumulation standards for containers, including labeling and secondary containment Correct answer.

Explanation

RCRA generator accumulation standards require containers to be labeled with the date accumulation began, marked with the words 'Hazardous Waste,' and managed to prevent releases. Missing containment and labeling directly breaches these container management requirements.

Question 12Environmental compliance

When a hazardous waste generator ships waste off site, which document must accompany the shipment to track it from generation to disposal?

  1. A Tier II form
  2. A Uniform Hazardous Waste Manifest Correct answer.
  3. A discharge monitoring report
  4. A Material Safety Data Sheet

Explanation

The Uniform Hazardous Waste Manifest is the tracking document required under RCRA for hazardous waste shipments, following the waste from generator through transporter to the treatment, storage, or disposal facility. It supports cradle-to-grave accountability.

Question 13Environmental compliance

A facility discovers a release of a CERCLA hazardous substance that exceeds the reportable quantity. To which entity must the facility immediately notify under CERCLA?

  1. The Securities and Exchange Commission
  2. The Federal Communications Commission
  3. The Department of Commerce
  4. The National Response Center Correct answer.

Explanation

CERCLA requires immediate notification of qualifying releases to the National Response Center, which coordinates federal response. State and local emergency authorities may also require notification under EPCRA.

Question 14Environmental compliance

Which statute requires facilities that use extremely hazardous substances above threshold planning quantities to participate in local emergency planning?

  1. The Resource Conservation and Recovery Act (RCRA)
  2. The Emergency Planning and Community Right-to-Know Act (EPCRA) Correct answer.
  3. The Safe Drinking Water Act (SDWA)
  4. The Endangered Species Act (ESA)

Explanation

EPCRA Sections 301 through 303 establish state and local emergency planning structures and require facilities with extremely hazardous substances above threshold planning quantities to notify planning authorities and participate. RCRA, SDWA, and ESA address different environmental concerns.

Question 15Environmental compliance

A facility discharges process wastewater to a municipal sewer system. Which permit program typically applies to this discharge?

  1. The pretreatment program under the Clean Water Act Correct answer.
  2. The RCRA permit program for treatment, storage, and disposal
  3. The PSD program under the Clean Air Act
  4. The NPDES program for direct discharges

Explanation

Indirect dischargers to publicly owned treatment works are regulated through the National Pretreatment Program, which sets local limits and requires permits. NPDES applies to direct discharges to surface waters, not to sewer connections.

Question 16Environmental compliance

Under RCRA, which of the following best describes the cradle-to-grave concept?

  1. Only the disposal facility bears responsibility for the waste
  2. Generators remain responsible for waste from generation through final disposal Correct answer.
  3. Responsibility ends once waste leaves the generator's site
  4. Responsibility transfers to the transporter permanently

Explanation

Cradle-to-grave liability means the generator retains responsibility for hazardous waste through its lifecycle, including proper treatment and disposal. This principle underlies manifest tracking and CERCLA liability.

Question 17Environmental compliance

Which of the following is a key requirement for underground storage tanks (USTs) under RCRA Subtitle I?

  1. Annual TRI reporting
  2. Release detection and corrosion protection Correct answer.
  3. Best available control technology determination
  4. Effluent limitation compliance

Explanation

RCRA Subtitle I regulations require UST owners and operators to implement release detection, corrosion protection, and spill and overfill prevention. TRI reporting, BACT, and effluent limits belong to other programs.

Question 18Environmental compliance

A company plans to build a new major source of air emissions in an area that meets the National Ambient Air Quality Standards. Which permitting analysis is required?

  1. A prevention of significant deterioration (PSD) review Correct answer.
  2. A total maximum daily load calculation
  3. A nonattainment new source review analysis
  4. A groundwater monitoring plan

Explanation

In attainment areas, new major sources and major modifications undergo PSD review to prevent significant deterioration of air quality and to apply best available control technology. Nonattainment review applies where standards are not met.

Question 19Environmental compliance

A facility generates hazardous waste and stores it on site for 200 days without a permit. Which generator accumulation time limit is most likely exceeded?

  1. The 180-day limit for small quantity generators
  2. There is no accumulation time limit for generators
  3. The 270-day limit for VSQGs
  4. The 90-day accumulation limit for large quantity generators Correct answer.

Explanation

Large quantity generators may accumulate hazardous waste on site without a permit for up to 90 days; exceeding that period generally requires a RCRA permit or interim status. Small quantity generators have a 180-day limit, with limited extensions.

Question 20Environmental compliance

A facility operates a hazardous waste treatment, storage, and disposal facility. Which permit program governs its operations under RCRA?

  1. A RCRA permit issued by the authorized state or EPA Correct answer.
  2. An NPDES permit
  3. A Section 404 dredge and fill permit
  4. A Title V air permit

Explanation

Treatment, storage, and disposal facilities require a RCRA permit, issued by the EPA or an authorized state, that specifies design and operating standards. Other permits may be needed for air or water, but the core waste facility authorization is the RCRA permit.

Question 21Environmental compliance

A property transaction reveals historical operations that may have contaminated soil. Which assessment is typically conducted first to identify recognized environmental conditions?

  1. A risk management plan
  2. A remedial investigation and feasibility study
  3. A Phase I environmental site assessment Correct answer.
  4. A Phase II intrusive investigation

Explanation

A Phase I environmental site assessment is a non-intrusive review of records, site history, and visual observations to identify recognized environmental conditions. If concerns are found, a Phase II investigation may follow.

Question 22Environmental compliance

Under CERCLA, which parties may be held liable for cleanup costs at a contaminated site?

  1. Only the current owner of the property
  2. Only the federal government
  3. Current owners and operators, past owners who disposed of waste, and generators and transporters who arranged for disposal Correct answer.
  4. Only the transporter who moved the waste

Explanation

CERCLA imposes liability on current owners and operators, owners and operators at the time of disposal, and persons who arranged for disposal or transport of hazardous substances. Liability is broad and can be joint and several.

Question 23Environmental compliance

A facility subject to the Clean Air Act risk management program stores a regulated substance above its threshold. What must the facility develop?

  1. An SPCC plan
  2. A stormwater pollution prevention plan
  3. A Tier II report
  4. A risk management plan that includes hazard assessment, prevention, and emergency response elements Correct answer.

Explanation

Clean Air Act Section 112(r) requires facilities with regulated substances above threshold quantities to prepare a risk management plan covering hazard assessment, prevention program, and emergency response. The plan must be submitted to EPA and made available to the public.

Question 24Environmental compliance

Which of the following best describes the relationship between RCRA and CERCLA at a site where hazardous waste was improperly disposed?

  1. RCRA governs ongoing waste management, while CERCLA provides authority to clean up past releases and recover costs Correct answer.
  2. Neither statute applies to contaminated soil
  3. CERCLA governs ongoing waste management, while RCRA addresses past releases
  4. Both statutes apply only to air emissions

Explanation

RCRA regulates the management of solid and hazardous waste from generation to disposal, while CERCLA addresses releases of hazardous substances and provides cleanup authority and cost recovery. The two frameworks are complementary rather than interchangeable.

Question 25Environmental compliance

A facility's industrial activities expose materials to stormwater. Which Clean Water Act program requires a permit and a stormwater pollution prevention plan for such discharges?

  1. The industrial stormwater permitting program under NPDES Correct answer.
  2. The UST program
  3. The pretreatment program
  4. The PSD program

Explanation

Industrial stormwater discharges associated with industrial activity require NPDES permit coverage, often under a general permit, and preparation of a stormwater pollution prevention plan with best management practices. Pretreatment, PSD, and UST programs address other media.

Question 26Environmental compliance

Under EPCRA, a facility that stores a hazardous chemical above the OSHA threshold must submit an annual inventory form to which recipients?

  1. The state emergency response commission, the local emergency planning committee, and the local fire department Correct answer.
  2. The Occupational Safety and Health Administration and the Chemical Safety Board
  3. Only the U.S. EPA regional office and the state environmental agency
  4. Only the local fire department and the county health department

Explanation

EPCRA Section 312 requires facilities subject to OSHA Hazard Communication to submit annual Tier I or Tier II inventory reports. These go to the state emergency response commission, the local emergency planning committee, and the fire department with jurisdiction. The reports support emergency planning and community right-to-know.

Question 27Environmental compliance

A facility that releases a CERCLA hazardous substance in an amount equal to or greater than its reportable quantity must notify which entity immediately?

  1. The U.S. Chemical Safety Board
  2. The local zoning authority
  3. The National Response Center Correct answer.
  4. The state governor's office

Explanation

CERCLA Section 103 requires immediate notification of the National Response Center when a reportable quantity of a hazardous substance is released. The NRC is the federal point of contact for release reporting. State and local reporting may also be required but does not replace the NRC notification.

Question 28Environmental compliance

Which Clean Water Act mechanism sets technology-based effluent limits for categories of industrial dischargers?

  1. Stormwater pollution prevention plans
  2. Total maximum daily loads developed by the states
  3. Section 404 dredge and fill permits
  4. National Pollutant Discharge Elimination System permits incorporating effluent limitation guidelines Correct answer.

Explanation

Effluent limitation guidelines are established for industrial categories and are applied to individual facilities through NPDES permits. The permit translates the national standards into enforceable limits for that discharger. TMDLs address waterbody-level allocations rather than category technology standards.

Question 29Environmental compliance

Which characteristic makes a solid waste a hazardous waste under RCRA?

  1. It exhibits ignitability, corrosivity, reactivity, or toxicity Correct answer.
  2. It contains any amount of water
  3. It is transported across state lines
  4. It is generated in a quantity greater than 2,200 pounds per month

Explanation

RCRA defines hazardous waste through listing and through the four characteristics: ignitability, corrosivity, reactivity, and toxicity. A waste exhibiting any characteristic is regulated as hazardous waste. Generation quantity affects generator status but does not itself make waste hazardous.

Question 30Environmental compliance

Under RCRA, a large quantity generator may accumulate hazardous waste on site without a permit for up to how long?

  1. 90 days Correct answer.
  2. 270 days
  3. 180 days
  4. 365 days

Explanation

Large quantity generators may accumulate hazardous waste without a permit for up to 90 days, provided accumulation requirements are met. Small quantity generators generally have 180 days, with an extension available when the waste must travel a long distance. Exceeding the time limit requires a storage permit.

Question 31Environmental compliance

What is the primary purpose of the Phase I environmental site assessment in a property transaction?

  1. To design the remediation system that will be used to clean up the property
  2. To identify recognized environmental conditions through records review, site reconnaissance, and interviews Correct answer.
  3. To quantify the concentration of contaminants in soil and groundwater through laboratory testing
  4. To obtain a federal permit for continued industrial operations

Explanation

A Phase I ESA is a non-intrusive inquiry that identifies recognized environmental conditions using records review, site visits, interviews, and regulatory database searches. It does not involve sampling. If it identifies potential contamination, a Phase II investigation with sampling may follow.

Question 32Environmental compliance

Which statute provides the federal authority to clean up releases of hazardous substances at contaminated sites?

  1. Safe Drinking Water Act
  2. Resource Conservation and Recovery Act
  3. Clean Air Act
  4. Comprehensive Environmental Response, Compensation, and Liability Act Correct answer.

Explanation

CERCLA, enacted in 1980, authorizes federal response to releases of hazardous substances and establishes liability for cleanup costs. RCRA regulates ongoing management of solid and hazardous waste rather than abandoned site cleanup. The Clean Air Act and Safe Drinking Water Act address air and drinking water programs.

Question 33Environmental compliance

Which federal agency administers the RCRA hazardous waste program and the Toxics Release Inventory?

  1. Occupational Safety and Health Administration
  2. Pipeline and Hazardous Materials Safety Administration
  3. Federal Emergency Management Agency
  4. U.S. Environmental Protection Agency Correct answer.

Explanation

The U.S. EPA administers RCRA and the EPCRA Section 313 Toxics Release Inventory at the federal level. Many RCRA programs are delegated to authorized states that implement them. OSHA and PHMSA regulate worker safety and hazardous materials transport, respectively.

Question 34Environmental compliance

A facility's stormwater pollution prevention plan must include which of the following elements?

  1. A groundwater monitoring well network for every outfall
  2. An air dispersion modeling analysis for stack emissions
  3. A list of every employee's job title and salary
  4. A description of potential pollutant sources and the best management practices to control them Correct answer.

Explanation

A stormwater pollution prevention plan identifies potential sources of pollutants and describes the best management practices used to prevent contamination of stormwater. It also typically includes site descriptions and inspection schedules. Air modeling and groundwater monitoring are not required SWPPP elements.

Question 35Environmental compliance

A facility exceeds the threshold for a regulated substance under the Clean Air Act risk management program. Which analysis must the facility conduct to evaluate the consequences of a worst-case release?

  1. A noise impact assessment
  2. A cultural resources survey
  3. An offsite consequence analysis Correct answer.
  4. A Phase II environmental site assessment

Explanation

Risk management plans must include an offsite consequence analysis that evaluates a worst-case release and, for some facilities, an alternate release scenario. The analysis estimates potential impacts on the surrounding community. The results inform emergency response planning and are summarized in the RMP.

Question 36Environmental compliance

A facility wants to claim the bona fide prospective purchaser defense to CERCLA liability. What must it do before acquiring the property?

  1. Transfer ownership to a trust
  2. Conduct all appropriate inquiries and provide legally required notices Correct answer.
  3. File a Toxics Release Inventory report for the property
  4. Obtain a permit to store hazardous waste on the property

Explanation

The bona fide prospective purchaser defense requires the purchaser to conduct all appropriate inquiries before acquisition and to provide required notices regarding the property. The purchaser must also take reasonable steps to prevent releases and comply with information requests. The defense protects qualifying purchasers from CERCLA liability despite owning contaminated property.

Question 37Environmental compliance

An industrial facility plans to discharge treated process wastewater to a river. Which permit must it obtain under the Clean Water Act?

  1. A Prevention of Significant Deterioration permit
  2. A Resource Conservation and Recovery Act permit
  3. A Toxic Substances Control Act section 5 order
  4. A National Pollutant Discharge Elimination System permit Correct answer.

Explanation

Point source discharges of pollutants to waters of the United States require an NPDES permit. The permit sets effluent limits and monitoring and reporting requirements. PSD permits address air quality and RCRA permits address waste management.

Question 38Environmental compliance

A facility's emergency planning notification under EPCRA Section 302 is triggered by which condition?

  1. Generation of more than 1,000 kilograms of hazardous waste per month
  2. Discharge of stormwater associated with industrial activity
  3. Operation of a major source of nitrogen oxides
  4. Presence of an extremely hazardous substance at or above its threshold planning quantity Correct answer.

Explanation

EPCRA Section 302 requires facilities that have an extremely hazardous substance on site at or above its threshold planning quantity to notify the state emergency response commission and the local emergency planning committee. This notification supports local emergency planning. Hazardous waste generation and air emissions do not trigger Section 302.

Question 39Environmental compliance

A facility stores petroleum in an aboveground tank with a capacity of 2,000 gallons. Which SPCC requirement applies if the facility meets the aggregate capacity threshold?

  1. The facility must obtain an NPDES permit for the tank
  2. The facility must register the tank as an underground storage tank
  3. The facility must report the tank under the Toxics Release Inventory
  4. The facility must prepare an SPCC plan addressing oil discharge prevention and control measures Correct answer.

Explanation

Facilities with oil storage above the SPCC aggregate capacity threshold must prepare a plan describing prevention, control, and countermeasure measures. The plan addresses containment, inspection, and response procedures. It does not function as a water discharge permit or TRI report.

Question 40Environmental compliance

What is the primary distinction between RCRA corrective action and CERCLA response action?

  1. RCRA corrective action addresses releases at permitted hazardous waste facilities, while CERCLA addresses releases at sites without an operating permit Correct answer.
  2. RCRA corrective action is voluntary, while CERCLA response is mandatory
  3. RCRA corrective action applies only to air releases, while CERCLA applies only to water releases
  4. RCRA corrective action is administered by OSHA, while CERCLA is administered by EPA

Explanation

RCRA corrective action requires permitted hazardous waste facilities to remediate releases at their sites. CERCLA provides authority to respond to releases at abandoned or uncontrolled sites. The two programs can overlap, but their regulatory triggers differ.

Question 41Environmental compliance

A facility generates 500 kilograms of hazardous waste in a month and accumulates waste on site for 200 days. Which generator category and time limit apply?

  1. Small quantity generator, whose general accumulation limit is 180 days Correct answer.
  2. Large quantity generator, whose limit is 90 days
  3. Conditionally exempt small quantity generator, whose limit is unlimited
  4. Very small quantity generator, whose limit is 270 days

Explanation

A facility generating between 100 and 1,000 kilograms per month is a small quantity generator. Small quantity generators may accumulate waste for up to 180 days, extended to 270 days when the waste must be transported over 200 miles. Accumulating for 200 days without the extension would exceed the limit.

Question 42Environmental compliance

A facility subject to the Toxics Release Inventory must submit its annual report by which date?

  1. January 31 of the following year
  2. March 1 of the following year
  3. July 1 of the following year Correct answer.
  4. December 31 of the reporting year

Explanation

TRI reports are due by July 1 for releases occurring in the preceding calendar year. The reports cover releases and other waste management quantities for listed chemicals. The reporting form is submitted to EPA and the appropriate state.

Question 43Environmental compliance

Which of the following best describes the role of the local emergency planning committee under EPCRA?

  1. It develops a local emergency response plan for hazardous substance releases Correct answer.
  2. It enforces RCRA hazardous waste storage standards
  3. It approves Clean Air Act operating permits
  4. It issues NPDES permits to industrial dischargers

Explanation

Local emergency planning committees develop emergency response plans for their districts and receive hazardous chemical inventory information. They coordinate with local responders and facilities. They do not issue permits or enforce waste and air standards.

Question 44Environmental compliance

A company discovers that a previous owner disposed of solvents on the property decades ago. Which response is most consistent with CERCLA liability principles?

  1. The current owner is never liable because the disposal occurred before acquisition
  2. The current owner may be liable as an owner of a facility where hazardous substances were disposed, subject to available defenses Correct answer.
  3. The prior owner is the only potentially responsible party regardless of the current owner's status
  4. Liability attaches only if the current owner actively caused the release

Explanation

CERCLA imposes liability on current owners and operators of facilities where hazardous substances were disposed, regardless of who caused the contamination. Defenses such as the bona fide prospective purchaser or innocent landowner defenses may apply if their conditions are met. Past owners and generators may also be liable as potentially responsible parties.

Question 45Environmental compliance

A facility's Clean Air Act Title V permit application is submitted to the permitting authority. Which statement describes the permit's function?

  1. It replaces all Clean Water Act requirements for the facility
  2. It authorizes the facility to generate hazardous waste without a RCRA permit
  3. It exempts the facility from new source review for future modifications
  4. It consolidates applicable air requirements into a single federally enforceable permit with monitoring and reporting conditions Correct answer.

Explanation

A Title V permit compiles all applicable Clean Air Act requirements into one document and adds monitoring, recordkeeping, and reporting conditions. It is federally enforceable. It does not replace other environmental permits or exempt the source from future review.

Question 46Environmental compliance

A facility operates an underground storage tank that was installed in 1988 and lacks secondary containment and corrosion protection. Which RCRA Subtitle I requirement is most directly implicated?

  1. The tank must be permitted under the NPDES program
  2. The tank must be reported under the Toxics Release Inventory
  3. The tank must be included in the facility's risk management plan
  4. The tank must meet release detection and spill, overfill, and corrosion protection requirements or be upgraded or closed Correct answer.

Explanation

RCRA Subtitle I requires USTs to have release detection and to meet spill, overfill, and corrosion protection requirements. Older tanks that cannot meet these standards must be upgraded or closed. TRI, risk management, and NPDES programs do not govern UST integrity.

Question 47Environmental compliance

A facility in an attainment area proposes a new major source that will emit significant amounts of a criteria pollutant. Which Clean Air Act program applies?

  1. Nonattainment new source review with lowest achievable emission rate
  2. Prevention of Significant Deterioration review with best available control technology Correct answer.
  3. Section 404 dredge and fill permitting
  4. Title V permit modification only, without preconstruction review

Explanation

New major sources in areas meeting the National Ambient Air Quality Standards undergo Prevention of Significant Deterioration review. The review requires installation of best available control technology and a demonstration that air quality is protected. Nonattainment new source review applies in areas that do not meet the standards.

Question 48Environmental compliance

A facility's SPCC plan must be certified by which party for a facility that is not eligible for self-certification?

  1. The local fire chief
  2. The state attorney general
  3. A licensed professional engineer Correct answer.
  4. The facility's human resources manager

Explanation

SPCC plans for facilities not eligible for self-certification must be certified by a licensed professional engineer. The engineer certifies that the plan has been prepared according to applicable requirements and that the facility has considered appropriate measures. Self-certification is limited to qualified facilities meeting specified criteria.

Question 49Environmental compliance

A hazardous waste was disposed at a site before RCRA was enacted, and the site now poses a release threat. Which regulatory framework most directly governs the cleanup?

  1. Safe Drinking Water Act underground injection control, because groundwater is affected
  2. Clean Air Act new source review, because the site emits vapors
  3. RCRA generator accumulation standards, because the waste was hazardous
  4. CERCLA response authority, because the disposal predates RCRA regulation and the site is an uncontrolled release Correct answer.

Explanation

CERCLA authorizes response to releases of hazardous substances at uncontrolled or abandoned sites, including sites where waste was disposed before RCRA regulation. RCRA corrective action applies to permitted facilities operating under RCRA. The cleanup framework is determined by the site's regulatory status rather than the nature of the waste alone.

Question 50Environmental compliance

A facility plans to modify a major source in a nonattainment area in a way that will significantly increase emissions of the nonattainment pollutant. Which requirement is most likely to apply?

  1. Prevention of Significant Deterioration review with best available control technology
  2. A Section 404 permit from the Army Corps of Engineers
  3. A Title V permit revision without preconstruction review
  4. Nonattainment new source review requiring lowest achievable emission rate and emission offsets Correct answer.

Explanation

Major modifications in nonattainment areas trigger nonattainment new source review. The source must meet the lowest achievable emission rate and obtain emission offsets to ensure progress toward attainment. PSD review applies in attainment areas, and preconstruction review cannot be bypassed by a Title V revision alone.