Environmental Compliance Inspector Air Quality and Emissions 3 — Questions and Answers
Question 1: Which regulation specifically governs the phase-out and management of ozone-depleting substances in the United States?
- Clean Air Act Title IV
- Clean Air Act Section 608 (SNAP Program)
- Resource Conservation and Recovery Act
- Clean Air Act Section 608 (Refrigerant Management) (Correct answer)
Correct answer: Clean Air Act Section 608 (Refrigerant Management)
Section 608 of the Clean Air Act establishes the refrigerant management program, requiring proper handling, recovery, and disposal of ozone-depleting refrigerants.
Question 2: A 'major modification' under New Source Review (NSR) Prevention of Significant Deterioration (PSD) rules triggers review when a physical change causes a significant net emissions increase. For NOx in an attainment area, the significance threshold is:
- 10 tons per year
- 40 tons per year (Correct answer)
- 100 tons per year
- 250 tons per year
Correct answer: 40 tons per year
For NOx, the PSD significance level is 40 tons per year; projects below this threshold do not trigger PSD major modification review.
Question 3: An environmental inspector reviewing a facility's CEMS data notices 10% of valid operating hours show exceedances. Under 40 CFR Part 75, excess emission reports must be submitted:
- Within 24 hours of the exceedance
- Quarterly, within 30 days after the end of each quarter (Correct answer)
- Annually with the Title V certification
- Monthly to the state agency only
Correct answer: Quarterly, within 30 days after the end of each quarter
40 CFR Part 75 requires quarterly excess emissions reports submitted within 30 days of each quarter's end to EPA's ECMPS system.
Question 4: The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Major Sources set emission limits based on:
- Best Available Control Technology (BACT)
- Maximum Achievable Control Technology (MACT) (Correct answer)
- Reasonably Available Control Technology (RACT)
- Lowest Achievable Emission Rate (LAER)
Correct answer: Maximum Achievable Control Technology (MACT)
NESHAP for major sources (also called MACT standards) require use of Maximum Achievable Control Technology, reflecting the best-performing 12% of sources.
Question 5: Under the Clean Air Act's Acid Rain Program (Title IV), what is the primary mechanism used to control SO2 emissions from power plants?
- Technology-based emission standards
- A cap-and-trade allowance system (Correct answer)
- Ambient air quality standards
- Mandatory fuel switching requirements
Correct answer: A cap-and-trade allowance system
Title IV created a national SO2 cap-and-trade program where each allowance permits emission of one ton of SO2, and sources must hold enough allowances to cover their emissions.
Question 6: When inspecting a dry cleaner for compliance with the Perchloroethylene (Perc) NESHAP, an inspector should verify the facility is NOT using which type of equipment if it is an 'existing' source installed before 2008?
- Refrigerated condenser dry-to-dry machines
- Dry-to-dry machines with carbon adsorbers
- Transfer machines (Correct answer)
- Closed-loop machines with secondary controls
Correct answer: Transfer machines
The Perc NESHAP prohibits transfer machines at all dry cleaning facilities, as they have no equivalent emission controls to dry-to-dry machines.
Question 7: A facility's Continuous Opacity Monitoring System (COMS) records 20% opacity for 7 consecutive minutes during normal operation. A state rule prohibits opacity above 20% for more than 6 consecutive minutes. This constitutes:
- A de minimis deviation with no reporting required
- A permit deviation that must be reported (Correct answer)
- A violation only if visible to the public
- No violation because 20% is at the limit, not above it
Correct answer: A permit deviation that must be reported
Opacity at or exceeding the limit (20%) for longer than the allowed consecutive period (6 minutes) constitutes a permit deviation triggering reporting requirements.
Environmental Compliance Inspector Air Quality and Emissions 3
Which regulation specifically governs the phase-out and management of ozone-depleting substances in the United States?