AQS Environmental Regulations & Policy 3 — Questions and Answers
Question 1: Which CAA section establishes the operating permit program requiring large sources to obtain comprehensive Title V permits?
- Section 110
- Section 112
- Section 502 (Correct answer)
- Section 307
Correct answer: Section 502
CAA Section 502 established the Title V operating permit program, requiring major sources to obtain permits that consolidate all applicable air quality requirements.
Question 2: An area classified as 'marginal' for ozone nonattainment must attain the standard within how many years of designation?
- 1 year
- 3 years (Correct answer)
- 5 years
- 10 years
Correct answer: 3 years
Marginal ozone nonattainment areas have 3 years from designation to attain the NAAQS, the shortest timeline of all ozone classifications.
Question 3: Which document categorizes industrial emission unit types and assigns applicable NSPS or NESHAP requirements for permitting purposes?
- Source Classification Code (SCC) table
- Code of Federal Regulations Part 60 subpart index (Correct answer)
- Air Pollution Control Technology (APCT) manual
- State Emission Inventory (SEI) guidance
Correct answer: Code of Federal Regulations Part 60 subpart index
40 CFR Part 60's subpart index organizes NSPS by source category, and permit writers reference these subparts to assign applicable standards.
Question 4: Which legal doctrine allows EPA to regulate an air pollutant if it 'may reasonably be anticipated to endanger public health or welfare,' as affirmed in Massachusetts v. EPA (2007)?
- Significant Risk Finding
- Endangerment Finding (Correct answer)
- Precautionary Principle Ruling
- Substantial Evidence Standard
Correct answer: Endangerment Finding
The Supreme Court in Massachusetts v. EPA confirmed that EPA must make an Endangerment Finding under CAA Section 202(a) before regulating GHGs from motor vehicles.
Question 5: Which CAA program specifically addresses interstate transport of air pollution affecting downwind states' ability to attain NAAQS?
- Cross-State Air Pollution Rule (CSAPR) (Correct answer)
- Regional Haze Rule
- Visibility Protection Program
- Interstate Transport SIP
Correct answer: Cross-State Air Pollution Rule (CSAPR)
CSAPR (also called the Transport Rule) requires upwind states to reduce power plant emissions of SO2 and NOx that significantly contribute to downwind NAAQS nonattainment.
Question 6: Under the Risk Management Program (RMP) in CAA Section 112(r), facilities with listed substances above threshold quantities must submit a plan to which authority?
- State environmental agency only
- EPA and local emergency planning committees (Correct answer)
- OSHA exclusively
- Department of Homeland Security
Correct answer: EPA and local emergency planning committees
RMP plans must be submitted to EPA and shared with Local Emergency Planning Committees (LEPCs) to support accident prevention and community emergency response.
Question 7: Which term describes the emissions baseline used to determine whether a physical change at an existing source constitutes a 'significant emissions increase' triggering NSR?
- Potential to emit (PTE)
- Actual-to-projected-actual emissions (Correct answer)
- Federally enforceable limit
- Allowable emissions rate
Correct answer: Actual-to-projected-actual emissions
For most modifications, NSR applicability is determined by comparing the projected actual post-change emissions to the baseline actual emissions over a representative 2-year period.
AQS Environmental Regulations & Policy 3
Which CAA section establishes the operating permit program requiring large sources to obtain comprehensive Title V permits?