Plywood and Composite Wood Products (PCWP)
NESHAP:
low risk-subcategory Summary
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5. When Must the Source Submit Risk Demonstrations to the US
EPA?
The source must submit their low-risk demonstration to the US
EPA for approval. If the source has an existing affected source,
they must submit their low-risk demonstration no later than July
31, 2006. To facilitate the review and approval process, the US
EPA encourages facilities to submit their assessments as soon as
possible. If you have an affected source that is an area source
that increases its emissions or its potential to emit such that
it becomes a major source of HAP before the effective date of the
PCWP MACT (subpart DDDD), then the source must complete and submit
for US EPA approval their low-risk demonstration no later than
July 31, 2006. If a facility has an affected source that is an
area source that increases its emissions or its potential to emit
such that it becomes a major source of HAP after the effective
date of the PCWP MACT (subpart DDDD), then they must complete and
submit for approval their low-risk demonstration no later than
12 months after they become a major source or after initial startup
of their affected source as a major source, whichever is later.
If a facility has a new or reconstructed affected source, they
must conduct the emission tests upon initial startup and use the
results of these emissions tests to complete and submit their low-risk
demonstration within 180 days following their initial startup date.
If a facility's new or reconstructed affected source starts up
before the effective date of the PCWP MACT (subpart DDDD), for
the US EPA to find that they are included in the low-risk subcategory,
the low-risk demonstration must show that they were eligible for
the low-risk subcategory no later than the effective date of the
PCWP MACT (subpart DDDD). If a new or reconstructed source starts
up after the effective date of the PCWP MACT (subpart DDDD), for
the US EPA to find that they are included in the low-risk subcategory,
the low-risk demonstration must show that the source was eligible
for the low-risk subcategory upon initial startup of the affected
source.
Affected sources that are not part of the low-risk subcategory
within 3 years after the effective date of the PCWP MACT (subpart
DDDD) must comply with the requirements of 40 CFR part 63, subpart
DDDD. Facilities may not request compliance extensions from the
permitting authority if they fail to demonstrate they are part
of the low-risk subcategory or to request additional time to install
controls to become part of the low-risk subcategory. All approved
low risk sources must then obtain title V air emissions operations
permit revisions including terms and conditions reflecting the
parameters used in their approved demonstrations, according to
the schedules in their applicable title V permit programs.
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