CAR Environmental Regulatory Compliance 3 — Questions and Answers
Question 1: Under RCRA, used oil that is mixed with a listed hazardous waste becomes subject to which regulation?
- Used Oil Management Standards only (40 CFR Part 279)
- Full hazardous waste regulations as a listed hazardous waste (Correct answer)
- Universal Waste Rule requirements
- No additional regulation if the mixture is less than 10% hazardous waste
Correct answer: Full hazardous waste regulations as a listed hazardous waste
When used oil is mixed with a listed hazardous waste, the mixture is classified as listed hazardous waste and must be managed under full RCRA Subtitle C regulations.
Question 2: Which EPA regulation specifically governs the management of used oil at automotive recycling facilities and sets standards for storage containers?
- 40 CFR Part 261
- 40 CFR Part 279 (Correct answer)
- 40 CFR Part 302
- 40 CFR Part 355
Correct answer: 40 CFR Part 279
40 CFR Part 279 establishes the Used Oil Management Standards, including requirements for storage containers, labeling, and record-keeping at generator facilities.
Question 3: An automotive recycler discovers that a crushed vehicle hull contains residual gasoline in the fuel tank. Under which regulation must this fuel be managed?
- RCRA hazardous waste regulations if it exhibits ignitability (Correct answer)
- Used Oil Management Standards automatically
- Clean Air Act Section 112 air toxics rules
- TSCA inventory reporting requirements
Correct answer: RCRA hazardous waste regulations if it exhibits ignitability
Residual gasoline exhibiting the ignitability characteristic (flash point below 140°F) must be managed as a hazardous waste under RCRA Subtitle C.
Question 4: What is the maximum number of days a Very Small Quantity Generator (VSQG) can accumulate hazardous waste on-site without a storage permit?
- 90 days
- 180 days
- 270 days
- There is no time limit for VSQGs (Correct answer)
Correct answer: There is no time limit for VSQGs
VSQGs (generating less than 100 kg/month) have no time limit for on-site accumulation as long as they never exceed the 1,000 kg accumulation limit.
Question 5: Which Clean Water Act permit mechanism controls direct discharges of wastewater from automotive recycling operations to surface waters?
- SPCC Plan
- NPDES individual or general permit (Correct answer)
- Section 404 dredge-and-fill permit
- Underground Injection Control (UIC) permit
Correct answer: NPDES individual or general permit
Direct discharges of wastewater to surface waters (point source discharges) require an NPDES permit issued under Section 402 of the Clean Water Act.
Question 6: When airbags in end-of-life vehicles are not deployed, they must be managed as hazardous waste unless the recycler deploys them using which method?
- Remote in-vehicle deployment before crushing (Correct answer)
- Off-site incineration at a licensed facility
- Puncturing the inflator module to neutralize it
- Burying the airbag units in a designated landfill cell
Correct answer: Remote in-vehicle deployment before crushing
Undeployed airbags can be deployed in-vehicle using a remote deployment tool, after which the spent units are no longer hazardous and can be managed as scrap metal.
Question 7: The Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313 requires Toxic Release Inventory (TRI) reporting for automotive recyclers that meet which threshold?
- Any facility that handles listed toxic chemicals regardless of quantity
- Facilities with 10 or more full-time employees that manufacture, process, or otherwise use listed chemicals above threshold quantities (Correct answer)
- Only facilities with annual revenues exceeding $1 million
- Facilities located within 1 mile of a residential area
Correct answer: Facilities with 10 or more full-time employees that manufacture, process, or otherwise use listed chemicals above threshold quantities
TRI reporting under EPCRA Section 313 applies to facilities with 10+ full-time employees in covered SIC codes that exceed chemical activity thresholds (e.g., 25,000 lbs manufactured/processed or 10,000 lbs otherwise used).
CAR Environmental Regulatory Compliance 3
Under RCRA, used oil that is mixed with a listed hazardous waste becomes subject to which regulation?