CAR Environmental Compliance & Sustainability 2 — Questions and Answers
Question 1: Under the Clean Air Act, automotive recyclers must manage refrigerants from vehicle A/C systems by:
- Venting them directly to the atmosphere
- Recovering them with EPA-certified equipment before crushing (Correct answer)
- Neutralizing them with baking soda solution
- Transferring them to landfill-approved containers
Correct answer: Recovering them with EPA-certified equipment before crushing
EPA Section 608 prohibits venting refrigerants and requires recovery using certified equipment before any vehicle is crushed or dismantled.
Question 2: Which document must accompany a shipment of hazardous waste from an automotive recycling facility?
- Bill of lading
- Uniform Hazardous Waste Manifest (Correct answer)
- Material Safety Data Sheet only
- Certificate of Destruction
Correct answer: Uniform Hazardous Waste Manifest
The Uniform Hazardous Waste Manifest (EPA Form 8700-22) must accompany all hazardous waste shipments from the point of generation to the disposal facility.
Question 3: A Spill Prevention, Control, and Countermeasure (SPCC) plan is required when an automotive recycler stores:
- More than 1,000 gallons of oil in aboveground containers (Correct answer)
- Any amount of used motor oil
- More than 55 gallons of oil indoors
- More than 500 gallons total oil capacity
Correct answer: More than 1,000 gallons of oil in aboveground containers
SPCC plans are required for facilities with aboveground oil storage capacity exceeding 1,320 gallons or underground storage exceeding 42,000 gallons.
Question 4: When mercury switches are removed from end-of-life vehicles, the best practice is to:
- Dispose of them in the general trash
- Crush them with the vehicle body to contain mercury
- Send them to a mercury recovery program such as the NVMSRP (Correct answer)
- Store them indefinitely on-site until a recycler is found
Correct answer: Send them to a mercury recovery program such as the NVMSRP
The National Vehicle Mercury Switch Recovery Program (NVMSRP) provides a free collection system for properly managing mercury switches removed from ELVs.
Question 5: Which RCRA generator category applies to a recycler that generates between 100 and 1,000 kg of hazardous waste per month?
- Very Small Quantity Generator (VSQG)
- Small Quantity Generator (SQG) (Correct answer)
- Large Quantity Generator (LQG)
- Exempt Quantity Generator (EQG)
Correct answer: Small Quantity Generator (SQG)
Generators producing 100–1,000 kg/month of hazardous waste are classified as Small Quantity Generators (SQG) under RCRA regulations.
Question 6: Antifreeze collected from drained vehicles that is NOT recycled on-site must be managed as:
- Non-hazardous solid waste suitable for drain disposal
- Used oil under 40 CFR Part 279
- Hazardous waste unless tested and confirmed non-hazardous (Correct answer)
- Universal waste under 40 CFR Part 273
Correct answer: Hazardous waste unless tested and confirmed non-hazardous
Spent antifreeze may be hazardous due to lead, benzene, or other contaminants and must be tested or managed as hazardous waste unless recycled.
Question 7: Secondary containment around oil storage tanks at an automotive recycling yard must be capable of holding:
- 10% of the largest tank's volume
- 25% of total storage capacity
- 110% of the largest single tank's capacity (Correct answer)
- 50% of all tanks' combined volume
Correct answer: 110% of the largest single tank's capacity
EPA and most state regulations require secondary containment to hold at least 110% of the largest tank's volume to prevent spills from reaching the environment.
CAR Environmental Compliance & Sustainability 2
Under the Clean Air Act, automotive recyclers must manage refrigerants from vehicle A/C systems by: