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Module 7: Regulatory Requirements - Title III - Practice Problems

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Instructions:
Answer these questions on a sheet of paper and check your responses against those provided below.

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Q icon #1
How many air toxics are presently included in Title III?

  1. 7
  2. 112
  3. 188
  4. 189

A icon
Answer: c. 188

In 1970 EPA designated seven compounds or groups of compounds as air toxics. The 1990 CAAA increased this number to 189 under Title III. One air toxic has been removed from this list leaving presently 188 compounds or group of compounds designated under NESHAPs.

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Q icon #2
What pollutants are not covered by NESHAPs?

  1. Non-criteria pollutants
  2. Criteria pollutants
  3. Hazardous air pollutants
  4. Air toxics

A icon
Answer: b. Criteria pollutants

The National Emission Standards for Hazardous Air Pollutants includes a list of hazardous air pollutants, also known as air toxics or non-criteria pollutants. Criteria pollutants are covered by NAAQS.

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Q icon #3
What is MACT?

  1. The most stringent emissions limitation achieved in practice.
  2. Practical limitations set on hazardous air pollutants.
  3. The most up-to-date control methods taking into account economic factors for new or modified sources.
  4. Health-based concentration limits on criteria pollutants established by EPA that apply to outside air

A icon
Answer: b. Practical limitations set on hazardous air pollutants.

Practical limitations set on hazardous air pollutants refers to MACT. Cost considerations can be taken into account when establishing emission limitations.

The other answer options are incorrect for the following reasons. The most stringent emission limits achieved in practice [Option a] refers to LAER. LAER is required under the NSR program. The most up-to-date control methods taking into account economic factors for new or modified sources [Option c] are BACT. Health-based concentration limits on criteria pollutants established by EPA that apply to outside air [Option d] are covered by NAAQS..

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Q icon #4
Do the following plants qualify as major sources of hazardous air pollutants?

  1. A plant has the potential to emit the following amounts of hazardous air pollutants (HAPs):
    HAP A = 5 tons
    HAP B = 6 tons
    HAP C = 7 tons
    HAP D = 9 tons

  2. A plant has the potential to emit nine tons of a hazardous pollutant per year.

A icon
Answer: i. Yes

Although the annual mass emission rate for each hazardous air pollutant does not exceed 10 tons/year, this facility qualifies as a major source because the sum of the quantities exceeds the 25 ton per year standard.

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Answer: ii. No

This facility does not qualify as a major source because its potential to emit the hazardous air pollutant is less than the 10 tons per year standard.

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Q icon #5
How will EPA establish emission limits for each source category specified in Section 112?

A icon
Answer: For source categories with 30 or more sources, EPA will implement emission limits of no higher than the average emission standards achieved by the best performing 12 percent in each category. For source categories containing fewer than 30 sources, EPA will make the determination based on the top five facilities in the category.

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