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REP: Environmental Compliance

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Environmental Compliance

Environmental compliance

This domain tests whether you can apply the U.S. federal regulatory framework - and stricter state overlays - to real facility operations. Expect questions on waste identification, permits, release reporting, and recordkeeping.

Core rules

  • RCRA follows waste “cradle to grave.” Generator status depends on monthly mass: very small (<100 kg/mo), small (100–1,000 kg/mo), large (≥1,000 kg/mo); acute hazardous waste has a 1 kg/mo threshold. LQGs need 90-day storage, a contingency plan, training, and biennial reports.
  • Clean Air Act permits include Title V operating permits; NESHAP/MACT set technology-based limits.
  • Clean Water Act discharges need NPDES permits; stormwater often needs a SWPPP and no-exposure certifications.
  • EPCRA requires Tier II inventory and TRI Form R; CERCLA reportable quantities trigger immediate notification.
  • NEPA applies to federal actions, not directly to private permits.

Worked example

A plant generates 1,200 kg of listed hazardous waste in March and stores it 120 days. It is an LQG because 1,200 kg ≥ 1,000 kg/month. The 120-day storage exceeds the 90-day LQG limit, so the facility is storing without a permit unless it has interim status or a permit. Corrective action: ship within 90 days, maintain manifest records, and verify state rules because some states are stricter.

Traps

Assuming a permit renewal is automatic; ignoring state rules; treating all waste as non-hazardous without testing or process knowledge; missing the 15-day written EPCRA release follow-up; and confusing RCRA generator categories with DOT shipping classes.