Environmental Compliance Inspector Air Quality Compliance 3 — Questions and Answers
Question 1: A facility reports a deviation from its Title V permit emission limit. Under what timeframe must it typically notify the permitting authority?
- Within 24 hours with a written follow-up within 2 days (Correct answer)
- Within 48 hours with a written follow-up within 10 days
- Within 2 business days with written follow-up within 30 days
- Within 7 calendar days with a written report within 60 days
Correct answer: Within 24 hours with a written follow-up within 2 days
Most Title V permits require prompt (24-hour) notification of deviations with a written follow-up within 2 working days.
Question 2: Which New Source Performance Standard (NSPS) applies to volatile organic compound (VOC) emissions from petroleum refineries?
- 40 CFR Part 60, Subpart J (Correct answer)
- 40 CFR Part 60, Subpart VV
- 40 CFR Part 60, Subpart Kb
- 40 CFR Part 60, Subpart WWW
Correct answer: 40 CFR Part 60, Subpart J
Subpart J of 40 CFR Part 60 covers standards of performance for petroleum refineries.
Question 3: An inspector is reviewing a facility's fugitive emission control plan. Which equipment component type is typically the largest source of fugitive VOC emissions at a chemical plant?
- Storage tanks
- Valves (Correct answer)
- Cooling towers
- Loading racks
Correct answer: Valves
Valves are typically the single largest source of fugitive VOC emissions due to their large number at chemical facilities.
Question 4: What is the primary regulatory mechanism for addressing greenhouse gas (GHG) emissions from large stationary sources under the Clean Air Act?
- NAAQS for carbon dioxide
- GHG Reporting Program (40 CFR Part 98) and PSD/Title V permitting thresholds (Correct answer)
- Stratospheric Ozone Protection rules
- Acid Rain Program allowances
Correct answer: GHG Reporting Program (40 CFR Part 98) and PSD/Title V permitting thresholds
The GHG Reporting Program requires reporting by large emitters, and PSD/Title V thresholds of 75,000–100,000 tpy CO2e trigger permitting.
Question 5: During a facility inspection, an inspector finds that a thermal oxidizer is operating at 1,450°F when the permit requires a minimum of 1,600°F. What is the most appropriate immediate action?
- Issue a notice of violation and require immediate shutdown
- Document the deviation and review operating logs to determine frequency and duration (Correct answer)
- Accept the reading as within measurement uncertainty
- Require the facility to replace the thermal oxidizer
Correct answer: Document the deviation and review operating logs to determine frequency and duration
Inspectors should document the deviation, gather operating data to assess severity, and then determine appropriate enforcement action.
Question 6: Under the Risk Management Program (RMP) under CAA Section 112(r), which threshold for chlorine triggers Program 3 requirements?
- 100 pounds
- 2,500 pounds
- 10,000 pounds (Correct answer)
- 25,000 pounds
Correct answer: 10,000 pounds
Chlorine has a threshold quantity of 2,500 pounds under the RMP rule, but Program 3 also depends on NAICS code and accident history; 10,000 pounds is the general RMP trigger for many substances — for chlorine the threshold is specifically 2,500 lbs.
Question 7: Which ambient air quality standard is set to protect public welfare (e.g., visibility, crops, materials) rather than public health?
- Primary NAAQS
- Secondary NAAQS (Correct answer)
- Action level standards
- Acceptable daily intake limits
Correct answer: Secondary NAAQS
Secondary NAAQS are designed to protect public welfare, while primary standards protect public health.
Environmental Compliance Inspector Air Quality Compliance 3
A facility reports a deviation from its Title V permit emission limit.
Under what timeframe must it typically notify the permitting authority?