AQS Compliance Reporting & Documentation 2 — Questions and Answers
Question 1: Under 40 CFR Part 70, which of the following best describes a 'significant permit revision'?
- A minor administrative update to contact information
- A change requiring public notice and a 30-day comment period (Correct answer)
- An internal operational change with no emissions impact
- A temporary shutdown lasting fewer than 30 days
Correct answer: A change requiring public notice and a 30-day comment period
Significant permit revisions under Part 70 require a 30-day public comment period and EPA review before taking effect.
Question 2: A facility discovers it exceeded a permitted emission limit for three days due to a malfunctioning control device. What is the FIRST required action under most state Title V programs?
- File an annual compliance certification noting the deviation
- Submit an excess emissions report or deviation report to the permitting authority (Correct answer)
- Immediately shut down the affected process unit
- Request a permit revision to increase the emission limit
Correct answer: Submit an excess emissions report or deviation report to the permitting authority
Most Title V programs require prompt reporting of deviations, often within 10 days of discovery or the end of the reporting period.
Question 3: Which federal regulation establishes the requirements for stack testing (performance testing) of stationary sources?
- 40 CFR Part 60 Appendix A (Correct answer)
- 40 CFR Part 50
- 40 CFR Part 98
- 40 CFR Part 51 Appendix Y
Correct answer: 40 CFR Part 60 Appendix A
40 CFR Part 60 Appendix A contains the EPA reference test methods used for stack emission performance testing.
Question 4: An air quality specialist must certify that monitoring data submitted to the state is accurate. Who is legally responsible for signing this certification under Title V?
- The environmental consultant hired by the facility
- A responsible official of the facility (Correct answer)
- The state permit writer
- The EPA regional administrator
Correct answer: A responsible official of the facility
Title V requires a 'responsible official' (typically a senior corporate officer or plant manager) to certify the accuracy of all reports submitted.
Question 5: What is the primary purpose of the Compliance Assurance Monitoring (CAM) rule under 40 CFR Part 64?
- To set numeric emission limits for large combustion turbines
- To ensure that control devices at large sources are operating properly between stack tests (Correct answer)
- To require continuous emissions monitoring at all permitted facilities
- To establish permit fees for Title V sources
Correct answer: To ensure that control devices at large sources are operating properly between stack tests
CAM requires sources with large potential emissions and control devices to use indicator monitoring to assure proper control device operation between performance tests.
Question 6: A facility's CEMS data shows a gap of 6 hours due to a power outage. Under 40 CFR Part 75, how should this missing data typically be treated for compliance purposes?
- The hours are ignored and excluded from calculations
- Substitute data procedures are applied, often using conservative default emission values (Correct answer)
- The facility may use the prior hour's reading for all missing periods
- No action is required if the outage was caused by an external event
Correct answer: Substitute data procedures are applied, often using conservative default emission values
Part 75 substitute data procedures require facilities to use conservative substitute values during CEMS downtime to ensure emissions are not under-reported.
Question 7: Which document serves as the primary legal basis for a facility's air emission limits, monitoring requirements, and recordkeeping obligations at the state level?
- The facility's internal environmental management plan
- The State Implementation Plan (SIP)
- The facility's Title V or state operating permit (Correct answer)
- EPA's National Emission Standards Handbook
Correct answer: The facility's Title V or state operating permit
The facility's operating permit (Title V or state equivalent) is the legally enforceable document that specifies all applicable requirements for that specific source.
AQS Compliance Reporting & Documentation 2
Under 40 CFR Part 70, which of the following best describes a 'significant permit revision'?