CEA Air Emission Monitoring & Control 5 — Questions and Answers
Question 1: Which of the following describes the 'bubble concept' in air pollution control for existing sources?
- Treating all emission points within a facility as a single source for compliance averaging purposes (Correct answer)
- An exemption from monitoring requirements for sources inside enclosed buildings
- A method of calculating dispersion from area sources using Gaussian plume modeling
- The requirement to enclose all fugitive emission sources under a containment dome
Correct answer: Treating all emission points within a facility as a single source for compliance averaging purposes
The bubble concept allows a facility to treat all its emission stacks as one imaginary bubble, enabling emissions trading among units as long as total facility emissions stay within limits.
Question 2: What does a CEMS 'daily calibration drift check' assess?
- Whether the CEMS data logger has recorded all operating hours correctly
- Whether the analyzer's response to zero and span gases has shifted since the last calibration (Correct answer)
- Whether the sample probe is free of particulate buildup
- Whether the reference method results agree with CEMS readings within 20%
Correct answer: Whether the analyzer's response to zero and span gases has shifted since the last calibration
The daily calibration drift check introduces zero and span reference gases to determine if the analyzer's response has drifted, ensuring ongoing measurement accuracy between full calibrations.
Question 3: An auditor discovers that a facility's Title V permit requires quarterly stack testing but only annual testing was conducted. This is an example of:
- A minor deviation that can be corrected through a permit revision
- A monitoring deviation/violation that must be reported under the permit's deviation reporting requirements (Correct answer)
- Acceptable practice if the annual test shows compliance
- A performance test exemption allowed when CEMS data are available
Correct answer: A monitoring deviation/violation that must be reported under the permit's deviation reporting requirements
Failure to conduct required monitoring at the specified frequency is a monitoring deviation, which must be reported to the permitting authority regardless of whether the emission measurements indicate compliance.
Question 4: What is the primary difference between 'Best Available Control Technology' (BACT) and 'Lowest Achievable Emission Rate' (LAER)?
- BACT applies in nonattainment areas and allows cost consideration; LAER applies in attainment areas without cost consideration
- BACT applies in attainment areas and allows energy/economic consideration; LAER applies in nonattainment areas without cost consideration (Correct answer)
- BACT and LAER are identical standards applied in different regulatory programs
- LAER is a technology standard while BACT is a numerical emission limit
Correct answer: BACT applies in attainment areas and allows energy/economic consideration; LAER applies in nonattainment areas without cost consideration
BACT applies under PSD (attainment areas) and allows consideration of energy, economic, and environmental impacts; LAER applies in nonattainment NSR and requires the most stringent rate achievable without cost consideration.
Question 5: Which parameter must be measured simultaneously with pollutant concentration when reporting emissions as a mass emission rate (lb/hr)?
- Ambient temperature and barometric pressure only
- Stack gas volumetric flow rate (Correct answer)
- Fuel sulfur content
- Oxygen concentration in the flue gas
Correct answer: Stack gas volumetric flow rate
Mass emission rate (lb/hr) is calculated by multiplying pollutant concentration (lb/dscf) by the stack gas volumetric flow rate (dscf/hr), so flow rate measurement is essential.
Question 6: Under EPA's Risk Management Program (RMP) for stationary sources, a facility storing chlorine above threshold quantities must:
- Install a CEMS for chlorine and report quarterly to EPA
- Develop and submit a Risk Management Plan including worst-case release scenario analysis (Correct answer)
- Obtain a NESHAP permit for chlorine as a hazardous air pollutant
- Apply for a variance from OSHA's Process Safety Management standard
Correct answer: Develop and submit a Risk Management Plan including worst-case release scenario analysis
Facilities with regulated substances above threshold quantities under 40 CFR Part 68 must develop an RMP that includes hazard assessment, prevention program, and emergency response program.
Question 7: A facility installs a new electrostatic precipitator and claims it qualifies as 'pollution control equipment' exempt from New Source Review. An auditor should verify that the project:
- Does not increase the facility's potential to emit regulated pollutants above major source thresholds (Correct answer)
- Uses the most recent vendor-certified technology available
- Was completed within the same calendar year as the permit application
- Reduces SO2 emissions by at least 50% compared to pre-project levels
Correct answer: Does not increase the facility's potential to emit regulated pollutants above major source thresholds
The pollution control exemption from NSR requires that the project does not increase the source's potential to emit above major source thresholds; the auditor must confirm net emissions do not increase significantly.
CEA Air Emission Monitoring & Control 5
Which of the following describes the 'bubble concept' in air pollution control for existing sources?