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REPA: Environmental Law, Regulations, and Compliance

REPA · Work through your exam, one topic at a time.

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Environmental Law, Regulations, and Compliance

Domain 2 tests whether you can identify the requirement that actually applies, then test compliance against it rather than against the organization's own habits.

Core rules

  • US statutes map to duties: Clean Air Act (Title V, New Source Review), Clean Water Act (NPDES permits, stormwater), RCRA (cradle-to-grave manifests, land disposal restrictions), CERCLA (strict, joint and several, retroactive liability), EPCRA (TRI, release notification), TSCA, and OPA 90/SPCC planning.
  • The binding rule is often the permit itself: numeric limits, monitoring methods, and reporting deadlines.
  • ISO 14001 6.1.3 covers compliance obligations - legal requirements plus other requirements the organization adopts.
  • 9.1.2 requires evaluating compliance and maintaining knowledge and understanding of compliance status.
  • In the EU, the Industrial Emissions Directive imposes BAT conclusions, with REACH and the EIA Directive as separate layers.

Worked example

An auditor reviews a pH discharge limit of 6.0–9.0 with daily monitoring. Two of thirty daily results are 9.4 and 9.6, and no exceedance was reported. Testing the say-do-check chain: the procedure says daily monitoring (say), the log shows the values (do), the permit sets the limit (check). Result: a nonconformity recorded with dates and log identifier, plus a second question - was the exceedance captured in the 9.1.2 compliance evaluation? A release-notification question under EPCRA or CERCLA applies only if a reportable quantity was released, which is a different test from a permit exceedance.

Traps that cost marks

  • Treating the existence of a permit as evidence of compliance.
  • Confusing permit-limit exceedance with reportable-quantity release notification.
  • Accepting “we have no noncompliances” without sampling monitoring and reporting records.
  • Missing that a permit condition can be stricter than the underlying statute.