CCP EPA & Clean Air Act Compliance 2 — Questions and Answers
Question 1: Under the Clean Air Act, what is the primary purpose of the National Emission Standards for Hazardous Air Pollutants (NESHAP)?
- Set ozone layer recovery targets
- Regulate emissions of toxic air pollutants from stationary sources (Correct answer)
- Establish fuel economy standards for vehicles
- Control greenhouse gas emissions from power plants
Correct answer: Regulate emissions of toxic air pollutants from stationary sources
NESHAP regulates emissions of hazardous air pollutants (HAPs) from stationary sources such as industrial facilities under CAA Section 112.
Question 2: Which EPA program requires facilities that emit 25,000 metric tons or more of CO2e per year to report their greenhouse gas emissions?
- Toxic Release Inventory
- Greenhouse Gas Reporting Program (GHGRP) (Correct answer)
- National Pollutant Discharge Elimination System
- Acid Rain Program
Correct answer: Greenhouse Gas Reporting Program (GHGRP)
The EPA's GHGRP (40 CFR Part 98) requires large emitters of 25,000 mt CO2e/year or more to report annual GHG emissions.
Question 3: What does 'Prevention of Significant Deterioration' (PSD) permitting under the Clean Air Act primarily protect?
- Urban air quality in nonattainment zones
- Air quality in areas already meeting NAAQS standards (Correct answer)
- Ozone layer from CFC releases
- Indoor air quality in commercial buildings
Correct answer: Air quality in areas already meeting NAAQS standards
PSD permits protect air quality in attainment areas by setting incremental limits on new pollution above baseline concentrations.
Question 4: A facility undergoes a 'major modification' under the Clean Air Act New Source Review (NSR) program. What must it obtain before construction begins?
- A Title V operating permit only
- An NSR pre-construction permit incorporating BACT or LAER (Correct answer)
- An EPA variance waiver
- A state emission reduction credit
Correct answer: An NSR pre-construction permit incorporating BACT or LAER
NSR requires major new sources or major modifications to obtain a pre-construction permit requiring Best Available Control Technology (BACT) or Lowest Achievable Emission Rate (LAER).
Question 5: Under the Clean Air Act's Acid Rain Program (Title IV), electric utilities must comply with sulfur dioxide emission limits primarily by:
- Installing scrubbers on all units mandatorily
- Surrendering SO2 allowances equal to actual emissions (Correct answer)
- Reporting emissions to NESHAP authorities
- Meeting BACT requirements for each boiler
Correct answer: Surrendering SO2 allowances equal to actual emissions
Title IV uses a cap-and-trade system where utilities must hold and surrender SO2 allowances equal to their actual annual emissions.
Question 6: Which section of the Clean Air Act authorizes EPA to regulate greenhouse gases from new motor vehicles following the Supreme Court's Massachusetts v. EPA decision?
- Section 111
- Section 202 (Correct answer)
- Section 112
- Section 110
Correct answer: Section 202
Section 202 authorizes EPA to set emission standards for new motor vehicles, and the Supreme Court confirmed this covers GHGs after Massachusetts v. EPA (2007).
Question 7: What is the 'Tailoring Rule' that EPA issued in 2010 related to Clean Air Act GHG permitting?
- A rule requiring tailored BACT for each pollutant
- A rule raising permitting thresholds so only the largest GHG emitters needed PSD/Title V permits (Correct answer)
- A rule limiting GHG reporting to the top 100 emitters
- A rule defining the social cost of carbon for permitting decisions
Correct answer: A rule raising permitting thresholds so only the largest GHG emitters needed PSD/Title V permits
The Tailoring Rule set higher emission thresholds (100,000 tpy for new sources) to phase in GHG permitting requirements and avoid overwhelming regulatory agencies.
CCP EPA & Clean Air Act Compliance 2
Under the Clean Air Act, what is the primary purpose of the National Emission Standards for Hazardous Air Pollutants (NESHAP)?