AARC Environmental & Safety Compliance 2 — Questions and Answers
Question 1: Under the Clean Air Act, which refrigerant recovery requirement applies to automotive recyclers when draining A/C systems?
- Refrigerants must be vented slowly to reduce pressure
- Certified technicians must recover refrigerant using approved equipment (Correct answer)
- Refrigerants can be released if the vehicle is more than 10 years old
- Only R-12 refrigerants require recovery; newer refrigerants are exempt
Correct answer: Certified technicians must recover refrigerant using approved equipment
The Clean Air Act Section 609 requires that only EPA-certified technicians using approved recovery equipment handle refrigerants, prohibiting intentional venting.
Question 2: What is the primary purpose of a Spill Prevention, Control, and Countermeasure (SPCC) plan at an automotive recycling facility?
- To document employee safety training records
- To prevent oil and hazardous material discharges into navigable waters (Correct answer)
- To track vehicle inventory and title transfers
- To outline fire suppression procedures
Correct answer: To prevent oil and hazardous material discharges into navigable waters
SPCC plans are required by EPA to prevent oil spills from reaching waterways and to outline containment and cleanup procedures.
Question 3: Which OSHA standard requires automotive recyclers to document and communicate chemical hazards to employees?
- 29 CFR 1910.147 (Lockout/Tagout)
- 29 CFR 1910.1200 (Hazard Communication) (Correct answer)
- 29 CFR 1910.132 (PPE General)
- 29 CFR 1910.303 (Electrical Safety)
Correct answer: 29 CFR 1910.1200 (Hazard Communication)
OSHA's Hazard Communication Standard (HazCom) at 29 CFR 1910.1200 requires Safety Data Sheets, labeling, and employee training on chemical hazards.
Question 4: When a recycler discovers an underground storage tank (UST) at a newly acquired property, what is the required first step?
- Immediately excavate and remove the tank
- Notify the appropriate state environmental agency (Correct answer)
- Fill the tank with concrete to prevent leaks
- Test the soil and report only if contamination is found
Correct answer: Notify the appropriate state environmental agency
Federal and state UST regulations require prompt notification to the appropriate regulatory agency upon discovery of an unregistered or unknown UST.
Question 5: How must automotive recyclers handle mercury switches from end-of-life vehicles to comply with environmental regulations?
- They can be discarded in standard dumpsters if sealed in plastic bags
- They must be removed and sent to a mercury recovery or recycling program (Correct answer)
- They are exempt from hazardous waste rules if fewer than 50 are collected annually
- They should be crushed with the vehicle body to minimize mercury exposure
Correct answer: They must be removed and sent to a mercury recovery or recycling program
Mercury switches must be removed before crushing and sent to approved mercury recycling programs such as the vehicle mercury switch recovery program (VMSR).
Question 6: What does a 'generator status' determination under RCRA affect for an automotive recycler?
- How many vehicles can be processed per day
- The reporting, storage time, and quantity limits for hazardous waste (Correct answer)
- Whether the facility needs a business license
- The type of insurance coverage required
Correct answer: The reporting, storage time, and quantity limits for hazardous waste
RCRA generator status (Very Small, Small, or Large Quantity Generator) determines storage time limits, quantity thresholds, reporting requirements, and training obligations.
Question 7: Which type of wastewater discharge permit is most commonly required for automotive recyclers that discharge process water to a municipal sewer system?
- NPDES general permit
- Industrial pretreatment permit (Correct answer)
- Class I injection well permit
- State groundwater discharge permit
Correct answer: Industrial pretreatment permit
Facilities discharging to municipal sewer systems typically need an industrial pretreatment permit to ensure pollutants are reduced before reaching the publicly owned treatment works (POTW).
Under the Clean Air Act, which refrigerant recovery requirement applies to automotive recyclers when draining A/C systems?