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Hazardous Waste Generators (RCRA) questions for the ASP

ASP11 Domain 7: Environmental Management (7.5 Waste removal, treatment, classification, labeling, and disposal). 3 free questions below. Every answer quotes and links the regulation paragraph it rests on.

Regulations covered

Text pulled from the eCFR, current as of 2026-10-14.

Question 1

A small quantity generator sent letters to its local fire department and the nearest hospital offering a facility tour and information on its hazardous wastes. After two follow-up calls, neither organization has agreed to any formal arrangement. During a compliance review, the EHS manager asks what the generator must have on file for these two organizations. What is required?

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Answer: A. Documentation in the operating record confirming that attempts to make the arrangements were made

The standard requires the operating record to show either that arrangements actively exist or, where none exist, that attempts to make them were made. The 'nothing to document' choice is wrong because the lack of an arrangement still has to be documented. A waiver is only available to a facility with 24-hour response capabilities, which this generator is not described as having.

Answer A rests on

40 CFR 262.16(b)(8)(vi)(B)(opens ecfr.gov in a new tab)
“This documentation must include documentation in the operating record that either confirms such arrangements actively exist or, in cases where no arrangements exist, confirms that attempts to make such arrangements were made.”

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Question 2

A large quantity generator operates a hazardous waste tank with a continuous flow process. Waste enters every day and is withdrawn every day, so the tank is never fully emptied. During an inspection, the safety professional must show that the tank complies with the accumulation time limit. Which approach meets the requirement for this tank?

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Answer: A. Use inventory logs, monitoring equipment or other records to show that the estimated volumes of waste entering the tank each day exit the tank within 90 days of first entering

For a continuous flow tank, the standard requires records showing that the estimated volumes entering daily leave the tank within 90 days of first entering. Requiring a full emptying fits a batch process, not this tank. The accumulation start date marking applies to containers, and hazard labeling does not demonstrate time compliance.

Answer A rests on

40 CFR 262.17(a)(5)(ii)(C)(opens ecfr.gov in a new tab)
“(C) Use inventory logs, monitoring equipment or other records to demonstrate that hazardous waste has been emptied within 90 days of first entering the tank if using a batch process, or in the case of a tank with a continuous flow process, demonstrate that estimated volumes of hazardous waste entering the tank daily exit the tank within 90 days of first entering; and”

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Question 3

During the weekly inspection of a small quantity generator's hazardous waste tank, the technician finds a fixture seam actively seeping waste. The soil at the base of the dike wall is wet, and the vegetation just outside the dike is dead. The maintenance supervisor suggests logging the finding and fixing the seam during a planned shutdown three weeks away, since weekly inspections will continue until then. What does the standard require?

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Answer: D. Take remedial action immediately, because the seepage and dead vegetation show a hazard has already occurred or is imminent

Seeping waste, wet spots and dead vegetation outside the dike are signs of leakage, so a hazard has occurred or is imminent, and the standard requires immediate remedial action. Deferring the repair to a convenient shutdown would be allowed only for lesser deterioration, where the schedule ensures the problem does not lead to a hazard. Continued inspection does not replace the repair.

Answer D rests on

40 CFR 262.16(b)(3)(iii)(E)(opens ecfr.gov in a new tab)
“The generator must remedy any deterioration or malfunction of equipment or structures which the inspection reveals on a schedule which ensures that the problem does not lead to an environmental or human health hazard. Where a hazard is imminent or has already occurred, remedial action must be taken immediately.”

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