Plywood and Composite Wood Products (PCWP)
NESHAP:
low risk-subcategory Summary
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4. Low-Risk Demonstrations
Once the source has conducted emissions testing, they may perform
a lookup table analysis or site-specific risk analysis. Regardless
of the type of risk analysis used, sources must use the most recent
US EPA approved dose-response values as posted
on the US EPA Air Toxics Website to demonstrate that their affected
source may be part of the low-risk subcategory. If the source can
demonstrate that their affected source is low-risk based on the look-up
table analysis, then they need not complete a site-specific risk
analysis. If the affected source is not low-risk based on the look-up
table analysis, then they may elect to proceed with site-specific
risk analysis. Appendix
B to the PCWP MACT rule (subpart DDDD) specifies what the
low-risk demonstration must contain.
Look-up table analysis
The source may use the look-up tables
(Tables 3 and 4 to 40 CFR part 63, subpart DDDD, appendix
B) to
determine if their affected source may be part of the low-risk
subcategory. Table 3 to appendix B to subpart DDDD provides the
maximum allowable toxicity-weighted carcinogen emission rate, and
Table 4 to appendix B to subpart DDDD provides the maximum allowable
toxicity-weighted noncarcinogen mission rate that an affected source
can emit. To use the look-up tables, the source must determine
their toxicity-weighted carcinogen and noncarcinogen emission rates
using the equations in appendix B to subpart DDDD; the average
stack height of all PCWP emission points at your affected source;
and the minimum distance from any emission point to the nearest
property boundary. If the total toxicity-weighted carcinogen and
noncarcinogen emission rates for the affected source are less than
or equal to the values in both look-up tables, then EPA may approve
the affected source as part of the low-risk subcategory of PCWP
affected sources.
Site-specific risk assessment
The source may
use any scientifically-accepted peer-reviewed risk assessment methodology
to demonstrate to EPA that the affected source ay be low risk.
An example approach to performing a site-specific risk assessment
for air toxics that may be appropriate for an affected source can
be found in the Air
Toxics Risk Assessment Reference Library. However, this
approach may not be appropriate for all affected sources, and EPA
may require that any specific affected source use an alternative
approach.
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