Compliance Reporting & Documentation Flashcards

Under the Greenhouse Gas Reporting Program (40 CFR Part 98), facilities that emit 25,000 metric tons CO2e or more per year must submit reports by what date each year?

Answer: September 30

Facilities covered by 40 CFR Part 98 must submit their annual GHG reports to EPA's electronic reporting system by March 31 of the following year.

A new source subject to New Source Review (NSR) must submit a Prevention of Significant Deterioration (PSD) permit application. Which of the following must be included in the application?

Answer: A Best Available Control Technology (BACT) analysis for each regulated pollutant

PSD permit applications require a BACT analysis demonstrating that the most stringent technically and economically feasible emission controls will be used.

What does the term 'synthetic minor' source mean in air quality permitting?

Answer: A source that accepts enforceable permit limits to remain below major source thresholds

A synthetic minor source voluntarily accepts enforceable emission caps in its permit to keep actual or potential emissions below the major source threshold.

When conducting an annual compliance certification under Title V, a facility discovers that it has been using an incorrect emission factor for two years. What is the appropriate response?

Answer: Disclose the error in the current certification and submit corrected past reports

Title V requires accurate and complete reporting; discovering past errors obligates the facility to disclose and correct the record to maintain regulatory credibility.

A facility operating under a state air permit is required to maintain emission records. What is the minimum retention period for these records under most EPA rules?

Answer: 5 years

Most EPA air quality regulations, including Title V, require facilities to retain emission monitoring and compliance records for a minimum of 5 years.

Which EPA program requires facilities to report annual criteria pollutant and precursor emissions to support air quality modeling and State Implementation Plan development?

Answer: National Emissions Inventory (NEI)

The National Emissions Inventory (NEI) is EPA's comprehensive data compilation of air emissions from all source categories, submitted by states and tribes every three years.

Under NESHAP regulations, what is a 'startup, shutdown, and malfunction' (SSM) plan, and why is it significant post-2015?

Answer: Historically, an affirmative defense document; post-2015 EPA ruled SSM exemptions in SIPs must be removed as they violate the CAA

In 2015, EPA issued a SIP call requiring states to remove SSM exemptions that automatically excused excess emissions, as the CAA requires emission standards to apply at all times.