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


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6. Remaining in the Low-Risk Subcategory

The facility must ensure that their affected source is low risk by periodically certifying the affected source is low risk, monitoring applicable HAP control device parameters, and by maintaining certain records. The facility must certify with each annual title V permit compliance certification that the basis for the affected source’s low-risk determination has not changed. The certification must consider process changes that increase HAP emissions, population shifts, and changes to dose-response values. If the affected source commences operating outside of the low-risk subcategory, it is no longer part of the low-risk subcategory.

The source must notify the permitting authority as soon as they know, or could have reasonably known, that the affected source is or will be operating outside of the low-risk subcategory. The source must be in compliance with all of the applicable requirements of 40 CFR part 63, subpart DDDD (PCWP MACT rule) beginning on the date when the affected source commences operating outside the low-risk subcategory if they had a process change that increases HAP emissions. If the source is operating outside of the low-risk subcategory due to a population shift or change to dose-response values, then they must comply with all of the applicable requirements of 40 CFR part 63, subpart DDDD no later than three years from the date the affected source commences operating outside the low-risk subcategory.


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