AARC Environmental Regulations & Compliance 5 — Questions and Answers
Question 1: When crushing vehicles, an auto recycler is required to drain and properly manage all fluids BEFORE crushing. Which fluid is specifically addressed by NESHAP Subpart EFFF?
- Engine oil
- Transmission fluid
- Mercury from light switches (Correct answer)
- Windshield washer fluid
Correct answer: Mercury from light switches
NESHAP Subpart EFFF specifically mandates removal of mercury convenience light switches from end-of-life vehicles prior to crushing to prevent mercury air emissions.
Question 2: A recycler stores 500 gallons of used oil in an aboveground tank. Under 40 CFR Part 279, the secondary containment requirement applies to:
- All indoor used oil storage tanks regardless of size
- Aboveground tanks with capacity of 110 gallons or more (Correct answer)
- Only tanks holding more than 5,000 gallons
- Tanks located within 500 feet of a waterway only
Correct answer: Aboveground tanks with capacity of 110 gallons or more
Under 40 CFR Part 279.22, aboveground used oil storage tanks with capacity of 110 gallons or more must have secondary containment sufficient to hold the tank's contents.
Question 3: Lead-acid batteries removed from vehicles at an auto recycler are classified as universal waste. The maximum accumulation time for a small quantity handler of universal waste (SQHUW) is:
- 90 days
- 180 days
- 270 days
- 365 days (Correct answer)
Correct answer: 365 days
Small quantity handlers of universal waste (generating less than 5,000 kg per year) may accumulate universal waste for up to one year (365 days).
Question 4: Which EPA program provides auto recyclers with a structured approach to evaluate and reduce pollution through voluntary environmental management systems?
- Brownfields Program
- Environmental Management System (EMS) under ISO 14001 (Correct answer)
- RCRA Corrective Action Program
- Superfund Alternative Approach
Correct answer: Environmental Management System (EMS) under ISO 14001
ISO 14001 Environmental Management Systems provide a voluntary framework for systematic identification, management, monitoring, and control of environmental impacts.
Question 5: A vehicle arrives at a recycler with a full gasoline tank. Before crushing, the fuel must be drained to prevent fire hazards and environmental contamination. Gasoline stored in bulk above what quantity triggers federal aboveground storage tank (AST) considerations?
- 55 gallons in any single container
- 110 gallons aggregate
- 660 gallons in a single tank
- 1,320 gallons aggregate aboveground (Correct answer)
Correct answer: 1,320 gallons aggregate aboveground
SPCC rule thresholds are triggered when a facility stores more than 1,320 gallons of oil (including gasoline) in aggregate aboveground containers of 55 gallons or more.
Question 6: Under the Clean Water Act's NPDES stormwater permit for auto recyclers (Sector M of the Multi-Sector General Permit), which practice is required to minimize pollutant discharge?
- Paving all outdoor areas with impermeable asphalt
- Implementing Best Management Practices (BMPs) including good housekeeping and spill prevention (Correct answer)
- Discharging all wastewater to a Publicly Owned Treatment Works (POTW)
- Installing tertiary wastewater treatment on all drains
Correct answer: Implementing Best Management Practices (BMPs) including good housekeeping and spill prevention
The MSGP Sector M requires auto recyclers to develop and implement Stormwater Pollution Prevention Plans (SWPPPs) with BMPs including good housekeeping, preventive maintenance, and spill response.
Question 7: If an auto recycler's facility is located on a brownfield site previously used for industrial operations, which program provides liability protections and funding for cleanup and redevelopment?
- RCRA Corrective Action Program
- EPA Brownfields Program under CERCLA Section 128(a) (Correct answer)
- EPCRA Emergency Planning Program
- Safe Drinking Water Act Wellhead Protection Program
Correct answer: EPA Brownfields Program under CERCLA Section 128(a)
EPA's Brownfields Program under CERCLA Section 128(a) provides grants, loans, and liability protections to encourage the assessment and cleanup of brownfield properties.
AARC Environmental Regulations & Compliance 5
When crushing vehicles, an auto recycler is required to drain and properly manage all fluids BEFORE crushing.
Which fluid is specifically addressed by NESHAP Subpart EFFF?