AARC Environmental Regulations & Compliance 3 — Questions and Answers
Question 1: When a vehicle delivered to an auto recycler still contains airbag inflators with sodium azide propellant, these inflators are regulated as:
- Universal waste under 40 CFR Part 273
- Hazardous waste under 40 CFR Part 261 (Correct answer)
- Non-hazardous solid waste
- Inert solid waste exempt from RCRA
Correct answer: Hazardous waste under 40 CFR Part 261
Unexploded airbag inflators containing sodium azide are classified as reactive hazardous waste (D003) under RCRA if disposed, not recycled.
Question 2: The Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313 requires facilities to report releases of toxic chemicals via:
- Biennial Hazardous Waste Report
- Toxics Release Inventory (TRI) Form R (Correct answer)
- Tier II Chemical Inventory Report
- RCRA Annual Report
Correct answer: Toxics Release Inventory (TRI) Form R
EPCRA Section 313 requires eligible facilities to submit Toxics Release Inventory (TRI) Form R annually to the EPA and state.
Question 3: A Small Quantity Generator (SQG) auto recycler generates between what quantities of hazardous waste per calendar month?
- Less than 100 kg
- 100 kg to 1,000 kg (Correct answer)
- 1,000 kg to 2,200 kg
- More than 2,200 kg
Correct answer: 100 kg to 1,000 kg
SQGs generate between 100 kg and less than 1,000 kg of hazardous waste per calendar month under RCRA regulations.
Question 4: Which document must accompany a hazardous waste shipment from an auto recycler to a licensed treatment, storage, and disposal facility (TSDF)?
- Bill of Lading
- Uniform Hazardous Waste Manifest (Correct answer)
- Material Safety Data Sheet only
- EPA Form 8700-12
Correct answer: Uniform Hazardous Waste Manifest
A Uniform Hazardous Waste Manifest (EPA Form 8700-22) must accompany all off-site hazardous waste shipments from generators to TSDFs.
Question 5: Under the Clean Water Act, what is the term for any point source discharge of pollutants to navigable waters of the US without an NPDES permit?
- An incidental discharge
- A non-point source release
- An illegal discharge (Correct answer)
- A de minimis release
Correct answer: An illegal discharge
Discharging pollutants from a point source to waters of the US without a valid NPDES permit is an illegal discharge and a violation of the Clean Water Act.
Question 6: Which EPA program specifically addresses the proper end-of-life management of vehicle mercury switches, and what is the preferred disposition?
- Universal Waste Rule — disposal in municipal solid waste
- National Vehicle Mercury Switch Recovery Program (NVMSRP) — recycling (Correct answer)
- RCRA Land Disposal Restrictions — deep well injection
- TSCA Section 6 — incineration only
Correct answer: National Vehicle Mercury Switch Recovery Program (NVMSRP) — recycling
The NVMSRP is a voluntary industry program that ensures mercury convenience light switches are properly removed and sent to mercury retorters for recycling.
Question 7: If an auto recycler's used oil storage tank leaks and contaminates soil, the recycler's primary obligation under federal law is to:
- Notify the local fire department only
- Assess and clean up the contamination and report to EPA if thresholds are met (Correct answer)
- Cover the contaminated soil with gravel
- Wait 30 days before taking any action
Correct answer: Assess and clean up the contamination and report to EPA if thresholds are met
Spill response obligations require immediate containment and cleanup, and reporting to the National Response Center if reportable quantities of regulated substances are released.
AARC Environmental Regulations & Compliance 3
When a vehicle delivered to an auto recycler still contains airbag inflators with sodium azide propellant, these inflators are regulated as: