AQS Regulatory Compliance 3 — Questions and Answers
Question 1: Under 40 CFR Part 60 (NSPS), which factor determines whether a modified source must meet new source standards?
- Whether the modification causes a significant net emission increase (Correct answer)
- Whether the modification costs more than $1 million
- Whether the facility employs more than 50 workers
- Whether the modification affects any single emission unit
Correct answer: Whether the modification causes a significant net emission increase
NSPS applicability for modifications is triggered when a physical or operational change causes a significant net increase in emissions.
Question 2: A HAP emitter's actual emissions fall below the 10 tpy single HAP threshold after installing controls. What regulatory tool can lock in this status?
- Federally Enforceable State Operating Permit (FESOP) with an operational limit (Correct answer)
- A NAAQS attainment designation
- A variance granted by OSHA
- An EPA exemption letter
Correct answer: Federally Enforceable State Operating Permit (FESOP) with an operational limit
A FESOP with enforceable operating limits caps emissions below major source thresholds, making the source a synthetic minor.
Question 3: Which of the following is a criterion pollutant for which EPA has established a primary NAAQS?
- Benzene
- Carbon monoxide (CO) (Correct answer)
- Hydrogen sulfide
- Dioxins
Correct answer: Carbon monoxide (CO)
Carbon monoxide is one of the six criteria pollutants with NAAQS; benzene, hydrogen sulfide, and dioxins are regulated as HAPs or under other provisions.
Question 4: A facility in a PM2.5 nonattainment area wants to expand. Which NSR program applies?
- Nonattainment New Source Review (NA-NSR) (Correct answer)
- Prevention of Significant Deterioration (PSD)
- Title V major modification review
- Minor source permitting only
Correct answer: Nonattainment New Source Review (NA-NSR)
NA-NSR applies when a major source proposes a significant modification in an area designated nonattainment for that pollutant.
Question 5: Under Nonattainment NSR, what is required in addition to Lowest Achievable Emission Rate (LAER) technology?
- Emission offsets greater than the increase from other sources in the region (Correct answer)
- An environmental justice assessment filed with EPA
- Installation of ambient air monitors within 500 feet of the fence line
- A risk-benefit analysis submitted to the state legislature
Correct answer: Emission offsets greater than the increase from other sources in the region
NA-NSR requires LAER plus emission offsets (at a ratio greater than 1:1) to ensure the area still moves toward attainment.
Question 6: Which EPA program specifically regulates stationary source emissions of ozone-depleting substances under Title VI of the Clean Air Act?
- Stratospheric Ozone Protection Program (Correct answer)
- Acid Rain Program
- Regional Haze Rule
- Cross-State Air Pollution Rule (CSAPR)
Correct answer: Stratospheric Ozone Protection Program
Title VI of the CAA established the Stratospheric Ozone Protection Program to phase out production and use of ozone-depleting substances.
Question 7: Under the CAA Section 112, what is the compliance timeline for existing major sources after EPA finalizes a MACT standard?
- 3 years (with possible 1-year extension) (Correct answer)
- 1 year
- 5 years
- Immediate upon promulgation
Correct answer: 3 years (with possible 1-year extension)
Existing major sources generally have 3 years to comply with a MACT standard, with a possible 1-year extension granted by the permitting authority.
AQS Regulatory Compliance 3
Under 40 CFR Part 60 (NSPS), which factor determines whether a modified source must meet new source standards?