Risk Based Corrective Action Case Study

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Question#1 The major differences between a Conditionally Exempt Small-Quantity Generator (CESQG) and a Small-Quantity Generator (SQG) mostly deals with the amount of hazardous waste that is generated. “SQGs are required to notify the EPA of their activities, CESQGs are not required to notify the EPA of their activities and do not have to obtain an EPA ID number” (Haight, 2012, p. 11). “When it comes to accumulating waste on site if the facility is classified as a CESQG, they have no accumulation time requirement. But if you have SQGs, hazardous waste can be accumulated on site for 180 days or less without a permit, or up to 270 days if the hazardous waste must be transported, stored, or treated at a distance of 200 miles or more” (Haight, 2012, p. 13). Unfortunately, you …show more content…
29). RBCA may allow contamination to stay in place as long as it remains under certain threshold levels. However, “the state may require engineering controls as well as ongoing sampling and monitoring activities” (Haight, 2012, p. 29).
Remediation
“A determination must be made based on the impact of contamination levels at the site. RBCA allows the state to establish limits of contamination for specific chemicals/contamination that has a limited threat to human health and the environment” (Haight, 2012, p. 27). This process may involve “digging up contaminated soil and transporting it to a landfill or a pump-and-treat method may be utilized to remove contaminated groundwater. The levels of contamination may be further mitigated by the implementation of engineering controls or administrative work practices” (Haight, 2012, p. 27).

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