AARC Environmental & Safety Compliance 4 — Questions and Answers
Question 1: An automotive recycler operating in a designated wetland buffer zone must primarily comply with which federal law when expanding their storage yard?
- Resource Conservation and Recovery Act (RCRA)
- Section 404 of the Clean Water Act (Correct answer)
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
- Toxic Substances Control Act (TSCA)
Correct answer: Section 404 of the Clean Water Act
Section 404 of the Clean Water Act regulates discharge of dredged or fill material into wetlands and requires a permit from the Army Corps of Engineers.
Question 2: Which condition would cause a used oil tank at a recycling facility to be reclassified as containing hazardous waste?
- The tank has been in use for more than five years
- Halogen content exceeds 1,000 parts per million (ppm) (Correct answer)
- The oil was drained from vehicles more than one year old
- The tank holds more than 500 gallons
Correct answer: Halogen content exceeds 1,000 parts per million (ppm)
EPA regulations presume used oil with halogen content above 1,000 ppm has been mixed with listed hazardous solvents, reclassifying it as hazardous waste.
Question 3: What is the purpose of a Job Safety Analysis (JSA) at an automotive recycling yard?
- To calculate workers' compensation premiums
- To identify hazards associated with specific tasks and establish safe work procedures (Correct answer)
- To document vehicle inventory for insurance purposes
- To comply with EPA stormwater reporting requirements
Correct answer: To identify hazards associated with specific tasks and establish safe work procedures
A JSA systematically examines each step of a job task to identify potential hazards and determine the safest way to perform the work.
Question 4: Under EPA regulations, catalytic converters removed from salvage vehicles are subject to which requirement if they contain platinum group metals?
- They must be destroyed on-site to prevent theft
- They may be sold as scrap without special handling requirements (Correct answer)
- They must be manifested as hazardous waste before transport
- They require registration with the Department of Transportation
Correct answer: They may be sold as scrap without special handling requirements
Intact used catalytic converters are not classified as hazardous waste and can be sold as scrap metal for precious metal recovery without hazardous waste manifests.
Question 5: When a vehicle contains a sodium azide-based airbag that cannot be safely removed, what is the preferred environmental compliance option?
- Crush the vehicle with the airbag in place and document it
- Use a certified airbag disposal service or deploy the airbag in a controlled setting (Correct answer)
- Remove and store in a 55-gallon drum as hazardous waste indefinitely
- Sell the vehicle as-is to an overseas exporter
Correct answer: Use a certified airbag disposal service or deploy the airbag in a controlled setting
Sodium azide is toxic; airbags that cannot be removed for resale should be deployed in a controlled, safe manner or handled by a certified airbag disposal service.
Question 6: Stormwater discharges from automotive recycling facilities are regulated under which permit program?
- RCRA corrective action permit
- NPDES Multi-Sector General Permit (MSGP) for industrial stormwater (Correct answer)
- Clean Air Act Title V operating permit
- TSCA inventory reporting permit
Correct answer: NPDES Multi-Sector General Permit (MSGP) for industrial stormwater
Automotive recyclers that discharge stormwater associated with industrial activity must obtain coverage under EPA's NPDES Multi-Sector General Permit (MSGP) or an equivalent state permit.
Question 7: Which OSHA requirement mandates that automotive recyclers develop written procedures for controlling hazardous energy before performing maintenance on vehicle-crushing equipment?
- OSHA 29 CFR 1910.119 (Process Safety Management)
- OSHA 29 CFR 1910.147 (Control of Hazardous Energy / Lockout-Tagout) (Correct answer)
- OSHA 29 CFR 1910.178 (Powered Industrial Trucks)
- OSHA 29 CFR 1910.23 (Walking-Working Surfaces)
Correct answer: OSHA 29 CFR 1910.147 (Control of Hazardous Energy / Lockout-Tagout)
The Lockout/Tagout standard at 29 CFR 1910.147 requires written energy control procedures to protect workers from unexpected startup of machinery during maintenance.
AARC Environmental & Safety Compliance 4
An automotive recycler operating in a designated wetland buffer zone must primarily comply with which federal law when expanding their storage yard?