CAR Environmental Regulatory Compliance 2 — Questions and Answers
Question 1: Under the Clean Air Act, which refrigerant recovery requirement applies to automotive recyclers when dismantling end-of-life vehicles?
- Refrigerants must be vented to atmosphere before crushing
- Certified technicians must recover refrigerants using EPA-approved equipment (Correct answer)
- Only R-12 refrigerant requires recovery; newer refrigerants are exempt
- Refrigerant recovery is only required if the vehicle is being resold
Correct answer: Certified technicians must recover refrigerants using EPA-approved equipment
EPA Section 609 of the Clean Air Act requires certified technicians to recover all refrigerants using approved equipment before vehicle dismantling.
Question 2: Which federal law primarily governs the management and disposal of hazardous waste generated at automotive recycling facilities?
- Clean Water Act (CWA)
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
- Resource Conservation and Recovery Act (RCRA) (Correct answer)
- Toxic Substances Control Act (TSCA)
Correct answer: Resource Conservation and Recovery Act (RCRA)
RCRA establishes the framework for managing hazardous waste from generation through disposal, directly governing auto recycler operations.
Question 3: A Spill Prevention, Control, and Countermeasure (SPCC) plan is required for automotive recyclers that store oil in aboveground tanks exceeding what aggregate capacity?
- 660 gallons
- 1,320 gallons (Correct answer)
- 2,500 gallons
- 5,000 gallons
Correct answer: 1,320 gallons
Facilities with aggregate aboveground oil storage capacity greater than 1,320 gallons are required to prepare and implement an SPCC plan under 40 CFR Part 112.
Question 4: Which document must accompany hazardous waste when it leaves an automotive recycling facility for off-site disposal?
- Bill of lading
- Uniform Hazardous Waste Manifest (Correct answer)
- Material Safety Data Sheet
- EPA Form 8700-12
Correct answer: Uniform Hazardous Waste Manifest
The Uniform Hazardous Waste Manifest (EPA Form 8700-22) must accompany all hazardous waste shipments to track the waste from generator to disposal.
Question 5: What is the EPA's definition of a 'small quantity generator' (SQG) of hazardous waste in terms of monthly generation?
- Less than 100 kg per month
- 100 to 1,000 kg per month (Correct answer)
- 1,000 to 10,000 kg per month
- More than 10,000 kg per month
Correct answer: 100 to 1,000 kg per month
Small quantity generators produce between 100 and 1,000 kg of hazardous waste per month and face intermediate regulatory requirements under RCRA.
Question 6: Which stormwater permit program requires automotive recyclers with industrial activity to obtain coverage and implement Best Management Practices (BMPs)?
- National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (Correct answer)
- Safe Drinking Water Act Underground Injection Control permit
- Resource Conservation and Recovery Act Part B permit
- Title V Air Operating Permit
Correct answer: National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit
The NPDES Multi-Sector General Permit (MSGP) covers stormwater discharges from industrial facilities including auto recyclers under Sector M.
Question 7: Lead-acid batteries removed from end-of-life vehicles at an automotive recycling facility are regulated under which exemption pathway when sent for reclamation?
- Universal Waste Rule (Correct answer)
- Used Oil Management Standards
- Bevill Amendment exemption
- Scrap Metal exemption
Correct answer: Universal Waste Rule
Lead-acid batteries managed for reclamation qualify under the Universal Waste Rule, simplifying storage and transport requirements compared to full hazardous waste regulations.
CAR Environmental Regulatory Compliance 2
Under the Clean Air Act, which refrigerant recovery requirement applies to automotive recyclers when dismantling end-of-life vehicles?