CAR Environmental Compliance & Sustainability 3 — Questions and Answers
Question 1: Which federal law primarily regulates the management and disposal of solid and hazardous waste at automotive recycling facilities?
- Clean Water Act (CWA)
- Resource Conservation and Recovery Act (RCRA) (Correct answer)
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
- Safe Drinking Water Act (SDWA)
Correct answer: Resource Conservation and Recovery Act (RCRA)
RCRA is the primary federal law governing how solid and hazardous waste must be generated, stored, treated, and disposed of at facilities like automotive recyclers.
Question 2: An automotive recycler discovers a previously unknown underground fuel tank on the property. The FIRST regulatory step should be to:
- Excavate and remove the tank immediately without notification
- Notify the state UST program and follow required assessment procedures (Correct answer)
- Seal the fill pipe and vent and resume normal operations
- Pour concrete over the area to prevent any leak migration
Correct answer: Notify the state UST program and follow required assessment procedures
Discovering an unregistered UST triggers mandatory reporting to the state underground storage tank regulatory agency and an assessment of potential releases.
Question 3: Storm water runoff from an automotive recycling yard that drains to a municipal separate storm sewer system (MS4) is regulated under:
- RCRA Subtitle C
- Clean Water Act NPDES industrial storm water permit (Correct answer)
- CERCLA emergency response provisions
- Safe Drinking Water Act UIC program
Correct answer: Clean Water Act NPDES industrial storm water permit
Industrial storm water discharges, including those from auto recyclers, require coverage under an NPDES Multi-Sector General Permit or individual permit under the Clean Water Act.
Question 4: Lead-acid batteries removed from end-of-life vehicles are classified under federal regulations as:
- Hazardous waste requiring manifest and licensed disposal
- Universal waste, allowing simplified management standards (Correct answer)
- Solid waste with no special handling required
- Exempt waste if stored less than 90 days
Correct answer: Universal waste, allowing simplified management standards
Lead-acid batteries are managed as universal waste under 40 CFR Part 273, which provides streamlined requirements compared to full hazardous waste regulations.
Question 5: A recycler must retain hazardous waste manifests for a minimum of:
- 1 year
- 2 years
- 3 years (Correct answer)
- 5 years
Correct answer: 3 years
Generators must keep copies of signed manifests for at least 3 years from the date the waste was accepted by the initial transporter.
Question 6: Which component of an end-of-life vehicle is classified as a persistent bioaccumulative toxic (PBT) pollutant and requires special handling?
- Engine coolant
- Mercury in convenience light switches and ABS sensors (Correct answer)
- Brake fluid
- Windshield washer fluid
Correct answer: Mercury in convenience light switches and ABS sensors
Mercury is classified as a PBT pollutant and is found in convenience light switches, ABS sensors, and other vehicle components requiring targeted removal before crushing.
Question 7: The EPA's automotive recycler conditional exemption for used oil filters requires that the filters be:
- Punctured and hot-drained for 12 hours (Correct answer)
- Crushed without draining in a closed container
- Incinerated on-site within 90 days
- Neutralized with solvent and landfilled
Correct answer: Punctured and hot-drained for 12 hours
Used oil filters are exempt from hazardous waste rules if they are gravity hot-drained for at least 12 hours or crushed, punctured, or dismantled to remove remaining oil.
CAR Environmental Compliance & Sustainability 3
Which federal law primarily regulates the management and disposal of solid and hazardous waste at automotive recycling facilities?