AQS Compliance Reporting & Documentation 3 — Questions and Answers
Question 1: 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?
- January 31
- March 31
- September 30 (Correct answer)
- December 31
Correct 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.
Question 2: 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?
- A Best Available Control Technology (BACT) analysis for each regulated pollutant (Correct answer)
- A health risk assessment for all surrounding counties
- Documentation of state legislative approval
- An offset ratio calculation for non-attainment pollutants only
Correct 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.
Question 3: What does the term 'synthetic minor' source mean in air quality permitting?
- A source that exclusively emits synthetic chemicals
- A source that accepts enforceable permit limits to remain below major source thresholds (Correct answer)
- A source with fewer than 10 employees operating air emission equipment
- A portable source that operates at multiple locations
Correct 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.
Question 4: 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?
- Correct the emission factor going forward and make no mention of past reports
- Disclose the error in the current certification and submit corrected past reports (Correct answer)
- Wait until the next formal audit to address the discrepancy
- Report the error only if it resulted in an exceedance
Correct 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.
Question 5: 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?
- 1 year
- 3 years
- 5 years (Correct answer)
- 10 years
Correct 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.
Question 6: Which EPA program requires facilities to report annual criteria pollutant and precursor emissions to support air quality modeling and State Implementation Plan development?
- Greenhouse Gas Reporting Program (GHGRP)
- National Emissions Inventory (NEI) (Correct answer)
- Toxic Release Inventory (TRI)
- Compliance and Emissions Data Reporting Interface (CEDRI)
Correct 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.
Question 7: Under NESHAP regulations, what is a 'startup, shutdown, and malfunction' (SSM) plan, and why is it significant post-2015?
- A required emergency response plan that exempts facilities from all emission limits during SSM events
- Historically, an affirmative defense document; post-2015 EPA ruled SSM exemptions in SIPs must be removed as they violate the CAA (Correct answer)
- A schedule for planned equipment upgrades during low-production periods
- A permit condition allowing higher emissions during cold weather months
Correct 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.
AQS Compliance Reporting & Documentation 3
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?