CAR Appliance Recycler Environmental Compliance 3 — Questions and Answers
Question 1: What is the maximum storage time allowed for a large-quantity generator of hazardous waste at an appliance recycling facility without a storage permit?
- 30 days
- 60 days
- 90 days (Correct answer)
- 180 days
Correct answer: 90 days
Large-quantity generators under RCRA may store hazardous waste on-site for a maximum of 90 days without needing a storage permit.
Question 2: Which refrigerant blends are classified as HFCs and therefore NOT regulated under Section 608 for ozone depletion purposes?
- R-12 and R-11
- R-22 and R-502
- R-134a and R-410A (Correct answer)
- R-113 and R-114
Correct answer: R-134a and R-410A
R-134a and R-410A are HFCs that do not deplete the ozone layer and are not regulated under Section 608's ozone-depletion provisions, though their GWP remains a concern.
Question 3: An appliance recycler discovers lead-containing solder in a large batch of discarded appliances. Under which regulatory framework is this most likely addressed?
- Clean Water Act effluent guidelines
- RCRA hazardous waste regulations for lead (Correct answer)
- TSCA lead paint rules
- Clean Air Act NESHAP standards
Correct answer: RCRA hazardous waste regulations for lead
Lead-containing materials that exhibit the toxicity characteristic under RCRA must be managed as hazardous waste if they fail the TCLP test.
Question 4: What is the purpose of a Spill Prevention, Control, and Countermeasure (SPCC) plan for an appliance recycling facility?
- To document CFC recovery procedures
- To prevent oil discharges to navigable waters and provide containment plans (Correct answer)
- To track employee chemical exposure limits
- To certify refrigerant recovery technicians
Correct answer: To prevent oil discharges to navigable waters and provide containment plans
An SPCC plan under Clean Water Act regulations is required for facilities storing large quantities of oil to prevent spills from reaching navigable waters.
Question 5: Which EPA regulatory program specifically governs air emissions from metal shredding operations at large appliance recycling facilities?
- National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Shredders (Correct answer)
- Title V Operating Permits
- New Source Performance Standards (NSPS) for Shredders
- Clean Air Act Section 112(r) Risk Management Program
Correct answer: National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Shredders
The EPA's NESHAP for shredders sets emission limits for hazardous air pollutants generated during the shredding of scrap metal including appliances.
Question 6: When a refrigerant cylinder recovered from appliances reaches 80% capacity, what must the recycler do?
- Continue filling it until completely full
- Stop filling and send it for reclamation or disposal (Correct answer)
- Vent excess pressure before continuing to fill
- Label it as full and store for 180 days
Correct answer: Stop filling and send it for reclamation or disposal
EPA regulations prohibit filling recovery cylinders beyond 80% capacity to prevent overpressure, and full cylinders must be sent for reclamation or proper disposal.
Question 7: What is the correct procedure when an appliance recycler identifies a unit suspected of containing R-11 refrigerant?
- Use standard R-22 recovery equipment since all CFCs behave similarly
- Use recovery equipment certified for the specific refrigerant and pressure range (Correct answer)
- Vent R-11 since it is no longer manufactured
- Mark the unit for direct shredding without recovery
Correct answer: Use recovery equipment certified for the specific refrigerant and pressure range
Recovery equipment must be certified and appropriate for the specific refrigerant type and operating pressures to ensure safe and complete recovery.
CAR Appliance Recycler Environmental Compliance 3
What is the maximum storage time allowed for a large-quantity generator of hazardous waste at an appliance recycling facility without a storage permit?