AARC Hazardous Fluid & Material Management 5 — Questions and Answers
Question 1: A state inspector finds that an auto recycler has been storing hazardous waste for 95 days without shipping it off-site. If the facility is an LQG, what violation has occurred?
- No violation; LQGs have 270-day accumulation limits
- No violation; there is no federal time limit for LQGs
- A violation; LQGs must ship hazardous waste off-site within 90 days (Correct answer)
- A violation only if the waste volume exceeds 1,000 kg
Correct answer: A violation; LQGs must ship hazardous waste off-site within 90 days
Large Quantity Generators are limited to 90 days of on-site hazardous waste accumulation under 40 CFR 262.17; exceeding this is a violation.
Question 2: Which automotive fluid is regulated as a 'listed hazardous waste' (F-list) if it is used as a solvent for degreasing parts?
- Windshield washer fluid
- Spent chlorinated solvents such as TCE or perchloroethylene (Correct answer)
- Used motor oil
- Spent antifreeze
Correct answer: Spent chlorinated solvents such as TCE or perchloroethylene
Spent chlorinated solvents used for degreasing appear on the EPA F-list (F001–F005) and are classified as listed hazardous waste regardless of contamination levels.
Question 3: Under EPA stormwater regulations, which control measure is most effective at reducing hydrocarbon contamination in runoff from a vehicle storage yard?
- Installing a gravel perimeter fence
- Using impervious paving with berms and oil-water separators (Correct answer)
- Planting grass buffer strips only
- Posting 'No Dumping' signs at storm drain inlets
Correct answer: Using impervious paving with berms and oil-water separators
Impervious surfaces prevent fluid infiltration, berms contain runoff, and oil-water separators remove petroleum before discharge—together these form an effective Best Management Practice (BMP).
Question 4: Catalytic converters removed from vehicles at an auto recycler may contain which hazardous substance that requires careful handling?
- Asbestos fibers
- Platinum group metals leaching cadmium compounds
- Chromium-6 in the substrate coating (Correct answer)
- Trace arsenic in the honeycomb ceramic
Correct answer: Chromium-6 in the substrate coating
Some catalytic converter substrates and coatings can contain hexavalent chromium (Cr-6), a known carcinogen that requires appropriate PPE and disposal precautions.
Question 5: Which scenario would disqualify used oil from being managed under EPA's less-stringent used oil rules and require it to be managed as hazardous waste?
- The used oil has a viscosity higher than fresh oil
- The used oil is mixed with a listed hazardous waste solvent (Correct answer)
- The used oil contains trace water from condensation
- The used oil was collected from more than 10 vehicles
Correct answer: The used oil is mixed with a listed hazardous waste solvent
Mixing used oil with any listed hazardous waste 'taints' it and subjects the entire mixture to full RCRA hazardous waste management requirements.
Question 6: When transporting used oil off-site using the recycler's own vehicles, EPA requires the transporter to:
- Obtain an EPA transporter ID number and carry a manifest
- Label containers 'Used Oil' and comply with applicable DOT shipping requirements (Correct answer)
- Obtain a state hazardous waste permit for every trip
- Carry a copy of the RCRA permit for the receiving facility
Correct answer: Label containers 'Used Oil' and comply with applicable DOT shipping requirements
Used oil transporters must label containers 'Used Oil' and follow DOT hazardous materials regulations; a manifest is not required unless the oil is classified as hazardous waste.
Question 7: Which of the following best describes the 'characteristic' of ignitability that would classify a waste as hazardous?
- The waste has a pH below 2.0
- A liquid waste with a flash point below 140°F (60°C) (Correct answer)
- The waste contains more than 1 mg/kg of lead
- The waste corrodes steel at a rate greater than 0.25 inches per year
Correct answer: A liquid waste with a flash point below 140°F (60°C)
Under 40 CFR 261.21, a liquid waste is ignitable (D001) if it has a flash point below 140°F (60°C), making it a hazardous waste by characteristic.
AARC Hazardous Fluid & Material Management 5
A state inspector finds that an auto recycler has been storing hazardous waste for 95 days without shipping it off-site.
If the facility is an LQG, what violation has occurred?