Plywood and Composite Wood Products (PCWP)
NESHAP:
low risk-subcategory Summary
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1. How Does a PCWP Source Demonstrate that their Facility
is Part of the Low-Risk Subcategory?
For an affected source to be part of the delisted low-risk
subcategory, they must have a low-risk demonstration approved
by the US EPA, and they must then have federally enforceable
conditions reflecting the parameters used in their EPA-approved
demonstration incorporated into their title V permit to ensure
that the affected source remains low-risk. Facilities may
demonstrate to the US EPA that their PCWP MACT rule affected
source is low risk by using the look-up tables in appendix
B of the PCWP MACT rule [PDF] or conducting a site-specific
risk assessment as specified in appendix B of the PCWP MACT
rule.
Appendix B of the PCWP MACT also specifies which process
units and pollutants must be included in a low-risk demonstration,
emissions testing methods, the criteria for determining if
an affected source is low risk, risk assessment methodology
(look-up table analysis or site-specific risk analysis),
contents of the low-risk demonstration, schedule for submitting
and obtaining approval of a low-risk demonstration, and methods
for ensuring that the affected source remains in the low-risk
subcategory. If a facility demonstrates that their affected
source is part of the delisted low-risk subcategory of PCWP
manufacturing facilities, then the affected source is not
subject to the MACT compliance options, operating requirements,
and work practice requirements in the final PCWP MACT rule.
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