AARC Environmental Regulations & Compliance 4 — Questions and Answers
Question 1: Under EPA's Universal Waste Rule (40 CFR Part 273), which of the following items commonly found in vehicles is NOT listed as a universal waste?
- Lead-acid batteries
- Fluorescent lamps
- Used motor oil (Correct answer)
- Cathode ray tubes (CRTs)
Correct answer: Used motor oil
Used motor oil is managed under 40 CFR Part 279 as used oil, not under the Universal Waste Rule, which covers batteries, pesticides, lamps, and mercury-containing equipment.
Question 2: The National Emission Standards for Hazardous Air Pollutants (NESHAP) for auto recycling facilities primarily targets emissions of:
- Nitrogen oxides (NOx) from vehicle testing
- Mercury from vehicle crushing operations (Correct answer)
- Particulate matter from tire shredding
- Carbon monoxide from idling vehicles
Correct answer: Mercury from vehicle crushing operations
The NESHAP for auto recycling (40 CFR Part 63, Subpart EFFF) requires proper removal of mercury switches before vehicles are crushed to prevent mercury air emissions.
Question 3: A vehicle delivered to a recycler has a catalytic converter. The precious metals (platinum, palladium, rhodium) recovered from it are best classified as:
- Hazardous waste requiring RCRA manifest
- Recyclable commodity exempt from hazardous waste rules (Correct answer)
- Toxic substance regulated under TSCA
- Listed hazardous waste under F-codes
Correct answer: Recyclable commodity exempt from hazardous waste rules
Precious metals recovered from catalytic converters are valuable recyclable commodities and are not classified as solid or hazardous waste when legitimately recycled.
Question 4: Which regulation requires auto recyclers to notify the State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC) if they store hazardous chemicals above threshold planning quantities?
- EPCRA Section 302 (Correct answer)
- EPCRA Section 313
- RCRA Section 3002
- CWA Section 311
Correct answer: EPCRA Section 302
EPCRA Section 302 requires facilities to notify SERCs and LEPCs if they store Extremely Hazardous Substances (EHS) above threshold planning quantities.
Question 5: Antifreeze/coolant drained from vehicles at an auto recycler that is reclaimed and returned to its original use is regulated under RCRA as:
- Hazardous waste requiring manifesting
- Used oil subject to 40 CFR Part 279
- A reclaimed material excluded from solid waste (Correct answer)
- A universal waste
Correct answer: A reclaimed material excluded from solid waste
Antifreeze that is reclaimed (cleaned and returned to use) is excluded from the definition of solid waste under RCRA's reclamation exclusion.
Question 6: An auto recycler must submit a Tier II report under EPCRA Section 312 if it stores a hazardous chemical above threshold quantities. The standard reporting deadline is:
- January 31 of the following year
- March 1 of the following year (Correct answer)
- June 30 of the following year
- December 31 of the same year
Correct answer: March 1 of the following year
Tier II reports covering the previous calendar year must be submitted to the SERC, LEPC, and local fire department by March 1.
Question 7: Under the Clean Air Act, a technician at an auto recycler who knowingly vents CFC or HCFC refrigerants during vehicle servicing faces a maximum penalty of:
- $1,000 per violation
- $5,000 per violation
- $44,539 per day per violation (Correct answer)
- $10 per pound vented
Correct answer: $44,539 per day per violation
EPA's Section 608 enforcement allows civil penalties up to $44,539 per day per violation (indexed for inflation) for knowingly venting regulated refrigerants.
AARC Environmental Regulations & Compliance 4
Under EPA's Universal Waste Rule (40 CFR Part 273), which of the following items commonly found in vehicles is NOT listed as a universal waste?