AARC Environmental & Safety Compliance 5 — Questions and Answers
Question 1: What action must an automotive recycler take if a stored vehicle is found to contain a leaking PCB (polychlorinated biphenyl) capacitor?
- Dispose of the capacitor with regular solid waste if it weighs less than 1 pound
- Manage the PCB item under TSCA PCB regulations, including proper storage and disposal (Correct answer)
- Treat it as universal waste and send to any certified electronics recycler
- Leave it in place and notify the local fire department only
Correct answer: Manage the PCB item under TSCA PCB regulations, including proper storage and disposal
PCBs are regulated under TSCA, requiring that PCB-containing equipment be stored in compliant containers and disposed of through approved facilities.
Question 2: Which of the following best describes the 'conditionally exempt small quantity generator' (CESQG) threshold under current RCRA regulations (post-2016 revisions)?
- Generates less than 100 kg of hazardous waste per month
- Generates less than 100 kg per month and is now referred to as Very Small Quantity Generator (VSQG) (Correct answer)
- Generates less than 1,000 kg per month and files annual reports
- Generates less than 500 kg per month and requires a storage permit
Correct answer: Generates less than 100 kg per month and is now referred to as Very Small Quantity Generator (VSQG)
The 2016 RCRA Generator Improvements Rule renamed CESQG to Very Small Quantity Generator (VSQG), maintaining the 100 kg/month threshold with specific management options.
Question 3: An automotive recycler's facility is cited for stormwater violations after a site inspection finds automotive fluids in a drainage ditch. Which corrective measure would directly address the root cause?
- Install security cameras to monitor the drainage area
- Implement secondary containment around fluid storage and drainage areas, and train employees on spill prevention (Correct answer)
- Submit a variance request to EPA to increase discharge limits
- Hire a third-party auditor to inspect quarterly
Correct answer: Implement secondary containment around fluid storage and drainage areas, and train employees on spill prevention
Secondary containment and employee training directly prevent fluid releases from reaching stormwater systems, addressing the root cause of drainage contamination.
Question 4: Which factor determines whether antifreeze collected at an automotive recycler must be managed as hazardous waste?
- Whether it is ethylene glycol or propylene glycol based
- Whether it exhibits a hazardous characteristic or has been mixed with a listed hazardous waste (Correct answer)
- Whether it was collected from vehicles manufactured before 2000
- Whether the total volume exceeds 55 gallons
Correct answer: Whether it exhibits a hazardous characteristic or has been mixed with a listed hazardous waste
Antifreeze is not automatically hazardous; it must be tested or evaluated to determine if it exhibits RCRA characteristics or has been contaminated with listed hazardous wastes.
Question 5: What is the purpose of a Tier II report (Emergency and Hazardous Chemical Inventory) that many automotive recyclers must file annually?
- To report annual revenue and employee headcount to the state
- To notify local emergency planners and fire departments of hazardous chemicals stored on-site above threshold quantities (Correct answer)
- To document all vehicle purchases and sales for tax purposes
- To apply for renewal of the facility's stormwater permit
Correct answer: To notify local emergency planners and fire departments of hazardous chemicals stored on-site above threshold quantities
EPCRA Section 312 requires facilities storing hazardous chemicals above threshold quantities to file Tier II reports with state and local emergency planning committees and fire departments.
Question 6: A worker at an automotive recycling facility is injured while handling a battery that leaked sulfuric acid. Which OSHA standard primarily governs the employer's responsibility to have an emergency eyewash station nearby?
- 29 CFR 1910.119 (Process Safety Management)
- 29 CFR 1910.151 (Medical Services and First Aid) (Correct answer)
- 29 CFR 1910.303 (Electrical Safety)
- 29 CFR 1910.1000 (Air Contaminants)
Correct answer: 29 CFR 1910.151 (Medical Services and First Aid)
OSHA 29 CFR 1910.151 requires that where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing must be provided.
Question 7: Which document must accompany a shipment of hazardous waste leaving an automotive recycling facility for off-site disposal?
- A bill of lading and commercial invoice
- A completed Uniform Hazardous Waste Manifest signed by the generator (Correct answer)
- A Material Safety Data Sheet (MSDS) for each waste stream
- An EPA waste minimization certification only
Correct answer: A completed Uniform Hazardous Waste Manifest signed by the generator
RCRA requires that all hazardous waste transported off-site be accompanied by a properly completed and signed Uniform Hazardous Waste Manifest to track it from generator to disposal facility.
