PCEW cheat sheet

Clean Air Act Title V permits apply to major sources; Title V is a federally enforceable operating permit that consolidates all applicable requirements into one document.

Clean Water Act NPDES permits regulate point source discharges to waters of the US; stormwater discharges from construction sites disturbing 1 acre or more require coverage.

RCRA Subtitle C governs hazardous waste from cradle to grave; Subtitle D governs non-hazardous solid waste and is implemented primarily by states.

CERCLA (Superfund) authorizes response to releases and establishes liability for past disposal; EPCRA requires community right-to-know reporting under SARA Title III.

Toxicity Characteristic Leaching Procedure (TCLP) determines whether a waste exhibits the toxicity characteristic; the regulatory levels are in 40 CFR 261.24.

Permit modifications: minor modifications can often be handled administratively, while major modifications require public notice and comment periods.

Compliance reporting deadlines: Title V annual certifications, EPCRA Tier II by March 1, and TRI Form R by July 1 each year.

A permit shield protects a permittee from enforcement for complying with permit terms, but only for requirements explicitly addressed in the permit application.

A waste is hazardous if it is listed (F, K, P, U lists) or exhibits a characteristic: ignitability, corrosivity, reactivity, or toxicity.

Ignitability: flash point below 140 degrees F; corrosivity: pH less than or equal to 2 or greater than or equal to 12.5; reactivity: unstable or generates toxic gases.

Generator categories: very small quantity generator (VSQG), small quantity generator (SQG), and large quantity generator (LQG), based on monthly generation rates.

LQG requirements include 90-day accumulation limits, contingency plans, personnel training, and biennial reporting; SQG limits are 180 days or 270 days if shipping over 200 miles.

Universal wastes (batteries, lamps, mercury devices, pesticides) have streamlined handling rules under 40 CFR 273.

Used oil destined for recycling is regulated separately; if it is mixed with hazardous waste, the mixture is generally managed as hazardous waste.

Land disposal restrictions (LDR) require treatment standards be met before hazardous waste can be land disposed, often via specified treatment technologies.

Manifest system: the uniform hazardous waste manifest (EPA Form 8700-22) tracks waste from generator to transporter to treatment, storage, and disposal facility (TSDF).

Secondary treatment standards for municipal wastewater: BOD5 and total suspended solids (TSS) 30-day averages of 30 mg/L, with percent removal requirements.

NPDES permits set effluent limitations, monitoring requirements, and reporting; discharge monitoring reports (DMRs) are typically submitted monthly.

Stormwater pollution prevention plans (SWPPP) require best management practices (BMPs), inspections, and recordkeeping for construction and industrial sites.

Total maximum daily load (TMDL) allocates pollutant loading among point and nonpoint sources for impaired water bodies.

Wastewater treatment train: preliminary (screening/grit), primary (settling), secondary (biological, e.g., activated sludge), and tertiary (nutrient removal, filtration, disinfection).

BOD5 measures oxygen demand over 5 days at 20 degrees C; COD is a faster chemical measure of oxygen demand that includes non-biodegradable organics.

Combined sewer overflows (CSOs) and sanitary sewer overflows (SSOs) have specific notification and reporting requirements to state agencies.

Spill Prevention, Control, and Countermeasure (SPCC) plans are required for facilities with oil storage above threshold quantities that could reach navigable waters.

New Source Review (NSR): Prevention of Significant Deterioration (PSD) applies in attainment areas; nonattainment NSR applies in areas exceeding the NAAQS.

National Ambient Air Quality Standards (NAAQS) cover six criteria pollutants: CO, Pb, NO2, O3, PM, and SO2.

Title V annual compliance certification must be submitted at least annually, signed by a responsible official.

Continuous emission monitoring systems (CEMS) require quality assurance plans and relative accuracy test audits (RATA).

Greenhouse gas reporting: facilities emitting 25,000 metric tons CO2e or more per year must report under the GHG Reporting Program (40 CFR 98).

Minor source permits (state or local) impose limits below major source thresholds; synthetic minor permits cap potential to emit.

Emission factors from AP-42 are used for estimating emissions; actual measurements and mass balance are alternatives.

Leak detection and repair (LDAR) programs require monitoring of valves, pumps, and connectors for volatile organic compound leaks at specified intervals.

Phase I Environmental Site Assessment (ESA) uses ASTM E1527 to identify recognized environmental conditions (RECs) through records review, site visit, and interviews.

Phase II ESA involves sampling to confirm or rule out contamination identified in the Phase I; it typically uses soil, groundwater, and soil vapor sampling.

Risk assessment uses the four-step framework: hazard identification, dose-response assessment, exposure assessment, and risk characterization.

Remediation technologies include soil vapor extraction, pump-and-treat, in-situ chemical oxidation, bioremediation, and thermal treatment.

Groundwater monitoring wells are installed and sampled to define contaminant plumes; low-flow purging minimizes turbidity and improves sample representativeness.

Institutional controls (e.g., deed restrictions) and engineering controls (e.g., caps, barriers) manage residual risk at contaminated sites.

Vapor intrusion assessment evaluates migration of volatile contaminants from soil or groundwater into overlying buildings.

Contaminated soil handling requires characterization, waste determination, and proper disposal or treatment per RCRA and state requirements.

OSHA permissible exposure limits (PELs) are enforceable 8-hour time-weighted averages; ACGIH TLVs are recommended but not legally enforceable.

Hazard communication (HazCom) requires safety data sheets (SDS), container labeling, and employee training under 29 CFR 1910.1200.

Respirator selection follows OSHA 29 CFR 1910.134; fit testing is required annually and for each respirator type.

Emergency response: the Incident Command System (ICS) provides a standardized organizational structure; HAZWOPER (29 CFR 1910.120) governs hazardous waste operations and emergency response training.

Personal protective equipment (PPE) selection uses hazard assessment; levels A through D define protection for chemical protective clothing.

Confined space entry requires atmospheric testing, attendant, entry permit, and rescue plan under 29 CFR 1910.146.

Exposure monitoring uses personal sampling devices; results are compared to PELs, and overexposure triggers engineering or administrative controls.

Emergency planning: EPCRA requires facilities to report releases above reportable quantities (RQs) to the National Response Center and state/local agencies.

Chain of custody documentation records sample possession from collection through analysis; each transfer must be signed and dated.

Data quality objectives (DQOs) define the type, quantity, and quality of data needed for a decision; they guide sampling design.

Quality assurance/quality control (QA/QC) includes blanks, duplicates, matrix spikes, and calibration checks to assess precision and accuracy.

Holding times specify the maximum time a sample can be held before analysis; they vary by parameter and preservation method.

Sample preservation (e.g., acidification to pH less than 2, refrigeration to 4 degrees C) maintains sample integrity during transport.

Detection limits: method detection limit (MDL) and practical quantitation limit (PQL) define the lowest measurable concentrations.

Representativeness requires proper sampling technique, equipment decontamination, and avoidance of cross-contamination.

Laboratory data validation checks for method compliance, calibration, blanks, and QC exceedances before data are used for decisions.

Regulatory reports and certifications must be accurate and complete; false statements can violate federal law (e.g., 18 U.S.C. 1001) and professional codes.

A responsible official signing a certification must have personal knowledge or a reasonable basis for the certification.

Recordkeeping retention varies: hazardous waste manifests generally 3 years, Title V records 5 years, and some permits require longer.

Data integrity: never alter, fabricate, or selectively omit monitoring data; deviations must be documented and reported as required.

Conflicts of interest must be disclosed; professional judgment should not be influenced by financial or personal interests.

Confidential business information (CBI) claims must be substantiated and submitted per regulatory procedures; not all information qualifies.

When errors are discovered in submitted reports, promptly notify the agency and submit corrections; concealment compounds liability.

Professional codes (e.g., engineering and environmental certification bodies) require protecting public health and the environment above employer interests.