CHA Emissions Control & Environmental Compliance 3 — Questions and Answers
Question 1: Under the National Emission Standards for Hazardous Air Pollutants (NESHAP), which term describes a facility that emits 10 tons/year of a single HAP or 25 tons/year of combined HAPs?
- Minor source
- Area source
- Major source (Correct answer)
- Synthetic minor source
Correct answer: Major source
A major source under NESHAP is defined as emitting 10 tons/year of any single HAP or 25 tons/year of total HAPs.
Question 2: Which control strategy hierarchy is EPA's preferred approach when addressing air emissions from industrial processes?
- Treatment → Substitution → Prevention
- Prevention → Control → Treatment (Correct answer)
- Dilution → Collection → Disposal
- Monitoring → Reporting → Mitigation
Correct answer: Prevention → Control → Treatment
EPA follows a pollution prevention hierarchy: prevent emissions at the source first, then control and treat what cannot be prevented.
Question 3: What is the purpose of a 'synthetic minor' operating permit condition?
- Allow emissions above major source thresholds with extra fees
- Voluntarily limit emissions to stay below major source thresholds and avoid Title V (Correct answer)
- Exempt the facility from all state air regulations
- Require enhanced monitoring only during high-production periods
Correct answer: Voluntarily limit emissions to stay below major source thresholds and avoid Title V
Synthetic minor conditions impose enforceable limits that keep actual emissions below major source thresholds, avoiding Title V requirements.
Question 4: During an audit, a boiler operating permit lists a NOx limit of 0.10 lb/MMBtu. Which parameter must be tracked to demonstrate continuous compliance?
- Stack opacity only
- Fuel usage and heat input rate (Correct answer)
- Ambient air quality readings at the fence line
- Employee training hours
Correct answer: Fuel usage and heat input rate
Fuel usage and heat input data allow calculation of actual NOx emissions in lb/MMBtu for comparison against the permit limit.
Question 5: EPA's Subpart DDDDD (National Emission Standards for Industrial, Commercial, and Institutional Boilers) is commonly known as the Boiler MACT. What is the primary pollutant driving compliance for large solid-fuel boilers?
- Carbon monoxide
- Hydrogen sulfide
- Mercury (Correct answer)
- Sulfur dioxide
Correct answer: Mercury
Mercury is the primary driver of Boiler MACT compliance for major source solid-fuel boilers due to its toxicity and bioaccumulation.
Question 6: What record retention period is typically required for air quality compliance records under federal regulations?
- 1 year
- 2 years
- 5 years (Correct answer)
- 10 years
Correct answer: 5 years
Most federal air regulations require retention of compliance records for at least 5 years from the date of the monitoring, report, or record.
Question 7: A facility installs a new emission control device that was not included in the operating permit. What must the facility do before startup?
- File an annual report noting the change
- Obtain a permit modification or pre-approval under the applicable NSR/PSD rules (Correct answer)
- Notify OSHA within 30 days
- Update the facility SPCC plan
Correct answer: Obtain a permit modification or pre-approval under the applicable NSR/PSD rules
Adding or modifying emission control equipment typically requires a permit modification or New Source Review approval before construction or startup.
CHA Emissions Control & Environmental Compliance 3
Under the National Emission Standards for Hazardous Air Pollutants (NESHAP), which term describes a facility that emits 10 tons/year of a single HAP or 25 tons/year of combined HAPs?