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Plywood and Composite Wood Products (PCWP) NESHAP:
low risk-subcategory Summary


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2. Low-Risk Criteria

The US EPA may approve an affected source as eligible for membership in the delisted low-risk subcategory of PCWP sources if it is determine that it is low risk for both carcinogenic and noncarcinogenic effects. To be considered low risk, the PCWP affected source must meet the following criteria:
  1. The maximum off-site individual lifetime cancer risk at a location where people live is less than one in one million for carcinogenic chronic inhalation effects;
  2. Every maximum off-site target-organ specific hazard index (TOSHI) (or, alternatively, an appropriately site-specific set of hazard indices based on similar or complementary mechanisms of action that are reasonably likely to be additive at low dose or dose-response data for your affected source’s HAP mixture) at a location where people live is less than or equal to 1.0 for noncarcinogenic chronic inhalation effects; and
  3. The maximum off-site acute hazard quotients for acrolein and formaldehyde are less than or equal to 1.0 for noncarcinogenic acute inhalation effects.
These criteria are built into the look-up tables included in appendix B to the PCWP MACT rule (subpart DDDD). Facilities conducting site-specific risk assessments must explicitly demonstrate that they meet these criteria. Facilities need not perform site-specific multipathway human health risk assessments or ecological risk assessments since EPA performed a source category-wide screening assessment which demonstrates that these risks are insignificant for all sources.


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