Mary
Kissell
To:
Edmond_
Toy@
omb.
eop.
gov
02/
20/
2004
06:
09
PM
cc:
Dave
Guinnup/
RTP/
USEPA/
US@
EPA,
Mike
Thrift/
DC/
USEPA/
US@
EPA,
johnsonann@
verizon.
net,
JohnB
Chamberlin/
DC/
USEPA/
US@
EPA,
Stan
Durkee/
DC/
USEPA/
US@
EPA,
Robert
Fegley/
DC/
USEPA/
US@
EPA,
Thomas
Gillis/
DC/
USEPA/
US@
EPA,
Patricia
Embrey/
DC/
USEPA/
US@
EPA,
Paul
Cort/
R9/
USEPA/
US@
EPA,
Teresa
Clemons/
RTP/
USEPA/
US@
EPA,
Sally
Shaver/
RTP/
USEPA/
US@
EPA,
Keith
Mason/
DC/
USEPA/
US@
EPA
Subject:
PCWP
­
Appendix
B
Edmond,

Latest
version
of
PCWP
risk
appendix
B.
I
don't
know
how
to
edit
the
font
for
the
compare
mode
quickly,
so
I'm
not
sure
I
complied
with
your
request
for
easy
to
read
on
black/
white
printer.
Mary
Tom
(
See
attached
file:
xxxto
OMB
pcwp
App
B
2_
20_
04.
wpd)
1
Appendix
B
to
Subpart
DDDD
of
Part
63
 
Methodology
and
Criteria
for
Demonstrating
That
an
Affected
Source
is
Part
of
the
Low­
risk
Subcategory
of
Plywood
and
Composite
Wood
Products
Manufacturing
Facilities
1.
Purpose
This
appendix
provides
the
methodology
and
criteria
for
demonstrating
that
your
affected
source
is
part
of
the
low­
risk
subcategory
of
plywood
and
composite
wood
products
(
PCWP)
manufacturing
facilities.
You
must
demonstrate
that
your
affected
source
is
part
of
the
low­
risk
subcategory
using
either
a
look­
up
table
analysis
(
based
on
the
look­
up
tables
included
in
this
appendix)
or
using
a
site­
specific
risk
assessment
performed
according
to
the
criteria
specified
in
this
appendix.
This
appendix
also
specifies
how
and
when
you
must
obtain
approval
of
the
low­
risk
demonstrations
for
your
affected
source
and
how
to
ensure
that
your
affected
source
remains
in
the
low­
risk
subcategory
of
PCWP
facilities.

2.
Who
is
eligible
to
demonstrate
that
they
are
part
of
the
lowrisk
subcategory
of
PCWP
facilities?
Each
new,
reconstructed,
or
existing
affected
source
at
a
PCWP
manufacturing
facility
may
demonstrate
that
they
are
part
of
the
low­
risk
subcategory
of
PCWP
facilities.
Section
63.2232
of
40
CFR
part
63,
subpart
DDDD,
defines
the
affected
source
and
explains
which
affected
sources
are
new,
existing,
or
reconstructed.

3.
What
parts
of
my
facility
have
to
be
included
in
the
low­
risk
demonstration?
Every
process
unit
that
is
part
of
the
PCWP
affected
source
(
as
defined
in
§
63.2292
of
40
CFR
part
63,
subpart
DDDD)
and
that
emits
one
or
more
hazardous
air
pollutant
(
HAP)
listed
in
Table
1
to
this
appendix
must
be
included
in
the
low­
risk
demonstration.
You
are
not
required
to
include
process
units
outside
of
the
affected
source
in
the
low­
risk
demonstration.

4.
What
are
the
criteria
for
determining
if
my
facility
is
low
risk?
(
a)
Determine
the
individual
HAP
emission
rates
from
each
process
unit
within
the
affected
source
using
the
procedures
specified
in
section
5
of
this
appendix.
(
b)
Perform
chronic
and
acute
risk
assessments
using
the
dose­
response
values
found
at
http://
www.
epa.
gov/
ttn/
atw/
toxsource/
summary.
html,
as
specified
in
paragraphs
(
b)(
1)
and
(
2)
of
this
section.
(
1)
For
a
look­
up
table
analysis
or
site­
specific
chronic
inhalation
risk
assessment,
you
should
use
the
cancer
and
2
noncancer
dose­
response
values
listed
on
the
Environmental
Protection
Agency
(
EPA)
Air
Toxics
website
(
http://
www.
epa.
gov/
ttn/
atw/
toxsource/
summary.
html)
to
estimate
carcinogenic
and
noncarcinogenic
chronic
inhalation
risk,
respectively.
(
2)
For
site­
specific
acute
inhalation
risk
assessment,
you
mustshould
use
the
acute
exposure
guidance
level
(
AEGL­
1)
value
for
acrolein
and
the
California
EPA
(
CalEPA)
acute
reference
exposure
level
(
REL)
value
for
formaldehyde
for
estimating
acute
inhalation
risk.
(
3)
You
may
use
dose­
response
values
more
conservative
than
those
posted
on
the
EPA
Air
Toxics
website
(
http://
www.
epa.
gov/
ttn/
atw/
toxsource/
summary.
html)
to
demonstrationfacilitate
ongoing
certification
that
your
affected
source
remains
in
the
low­
risk
subcategory,
as
required
in
section
13
of
this
appendix.
(
c)
Demonstrate
that
your
affected
source
is
part
of
the
low­
risk
subcategory
by
estimating
the
maximum
chronic
and
acute
impacts
of
your
affected
source
using
one
of
the
methods
described
in
either
section
6
of
this
appendix
(
look­
up
table
analysis)
or
section
7
of
this
appendix
(
site­
specific
risk
assessment)
and
comparing
the
results
to
the
low­
risk
criteria
presented
in
the
applicable
section.

5.
How
do
I
determine
HAP
emissions
from
my
affected
source?
(
a)
You
must
conduct
HAP
emissions
tests
according
to
the
requirements
in
paragraphs
(
b)
through
(
h)
of
this
section
and
the
methods
specified
in
Table
2
to
this
appendix
for
every
process
unit
within
the
affected
source
that
emits
one
or
more
of
the
HAP
listed
in
Table
1
to
this
appendix.
You
must
test
the
process
units
at
your
affected
source
to
obtain
the
emission
rates
in
pounds
per
hour
(
lb/
hr)
for
each
of
the
pollutants
listed
in
Table
1
to
this
appendix.
(
b)
Periods
when
emissions
tests
must
be
conducted.
(
1)
You
must
not
conduct
emissions
tests
during
periods
of
startup,
shutdown,
or
malfunction,
as
specified
in
40
CFR
63.7(
e)(
1).
(
2)
You
must
test
under
worst­
case
operating
conditions
as
defined
in
this
appendix.
You
must
describe
your
worst­
case
operating
conditions
in
your
performance
test
report
for
the
process
and
control
systems
(
if
applicable)
and
explain
why
the
conditions
are
worst­
case.
(
c)
Number
of
test
runs.
You
must
conduct
three
separate
test
runs
for
each
test
required
in
this
section,
as
specified
in
40
CFR
63.7(
e)(
3).
Each
test
run
must
last
at
least
1
hour
except
for:
testing
of
a
temporary
total
enclosure
(
TTE)
conducted
using
Methods
204A
through
204F
in
40
CFR
part
51,
appendix
M,
which
require
three
separate
test
runs
of
at
least
3
3
hours
each;
and
testing
of
an
enclosure
conducted
using
the
alternative
tracer
gas
method
in
appendix
A
to
40
CFR
part
63,
subpart
DDDD,
which
requires
a
minimum
of
three
separate
runs
of
at
least
20
minutes
each.
(
d)
Sampling
locations.
Sampling
sites
must
be
located
at
the
outlet
of
the
control
device,
including
wet
control
devices,
and
prior
to
any
releases
to
the
atmosphere.
(
e)
Collection
of
monitoring
data
for
HAP
control
devices.
During
the
emissions
test,
you
must
collect
operating
parameter
monitoring
system
or
continuous
emissions
monitoring
system
(
CEMS)
data
at
least
every
15
minutes
during
the
entire
emissions
test
and
establish
the
site­
specific
operating
requirements
(
including
the
parameter
limits
or
total
hydrocarbon
(
THC)
concentration
limit)
in
Table
2
to
40
CFR
part
63,
subpart
DDDD,
using
data
from
the
monitoring
system
and
the
procedures
specified
in
paragraphs
(
k)
through
(
o)
of
§
63.2262
of
subpart
DDDD
of
40
CFR
part
63.
(
f)
Nondetect
data.
You
may
treat
emissions
of
an
individual
HAP
as
zero
if
all
of
the
test
runs
result
in
a
nondetect
measurement
and
the
conditions
in
paragraphs
(
1)
and
(
2)
of
this
section
are
met
for
the
relevant
test
method.
Otherwise,
nondetect
data
(
as
defined
in
§
63.2292
of
40
CFR
part
63,
subpart
DDDD)
for
individual
HAP
must
be
treated
as
one­
half
of
the
method
detection
limit.
(
1)
The
method
detection
limit
is
less
than
or
equal
to
1
part
per
million
by
volume,
dry
(
ppmvd)
for
pollutant
emissions
measured
using
Method
320
in
appendix
A
to
40
CFR
part
63;
or
the
NCASI
Method
IM/
CAN/
WP­
99.02
(
incorporated
by
reference
(
IBR),
see
40
CFR
63.14(
f));
or
ASTM
D6348­
03
(
IBR,
see
40
CFR
63.14(
b)).
(
2)
For
pollutants
measured
using
Method
29
in
appendix
A
to
40
CFR
part
60,
you
analyze
samples
using
atomic
absorption
spectroscopy
(
AAS).
(
g)
For
purposes
of
your
low­
risk
demonstration,
you
must
assume
that
17
percent
of
your
total
chromium
measured
using
EPA
Method
29
in
appendix
A
to
40
CFR
part
60
is
chromium
VI.
You
must
assume
that
65
percent
of
your
total
nickel
measured
using
EPA
Method
29
in
appendix
A
to
40
CFR
part
60
is
nickel
subsulfide.
(
h)
You
may
use
emission
rates
more
conservative
than
your
measured
emission
rates
(
e.
g.,
emissions
rates
10
times
your
measured
emission
rate)
to
facilitate
ongoing
certification
that
your
affected
source
remains
in
the
low­
risk
subcategory,
as
required
in
section
13
of
this
appendix.

6.
How
do
I
conduct
a
look­
up
table
analysis?
Use
the
look­
up
tables
(
Tables
3
and
4
to
this
appendix)
to
demonstrate
that
your
affected
source
is
part
of
the
low­
risk
4
subcategory,
following
the
procedures
in
paragraphs
(
a)
through
(
d)
of
this
section.
(
a)
Using
the
emission
rate
of
each
HAP
required
to
be
included
in
your
low­
risk
demonstration,
calculate
your
total
toxicity­
weighted
carcinogen
and
noncarcinogen
emission
rates
for
each
of
your
process
units
using
Equations
1
and
2
of
this
appendix,
respectively.

TWCER
=

(
ERi
x
UREi)
Eqn.
1
TWCER
=
Toxicity­
weighted
carcinogenic
emission
rate
for
each
process
unit
(
lb/
hr)/(
µ
g/
m3)
ERi
=
Emission
rate
of
pollutant
i
(
lb/
hr)
UREi
=
Unit
risk
estimate
for
pollutant
i,
1
per
microgram
per
cubic
meter
(
µ
g/
m3)­
1
TWNER
=

(
ERi
/
RfCi)
Eqn.
2
TWNER
=
Toxicity­
weighted
noncarcinogenic
emission
rate
for
each
process
unit
(
lb/
hr)
ERi
=
Emission
rate
of
pollutant
i
(
lb/
hr)
RfCi
=
Reference
concentration
for
pollutant
i,
micrograms
per
cubic
meter
(
µ
g/
m3)

(
b)
Cancer
risk.
Calculate
the
total
toxicity­
weighted
carcinogen
emission
rate
for
your
affected
source
by
summing
the
toxicity­
weighted
carcinogen
emission
rates
for
each
of
your
process
units.
Identify
the
appropriate
maximum
allowable
toxicity­
weighted
carcinogen
emission
rate
from
Table
3
to
this
appendix
for
your
facility
using
the
average
stack
height
of
your
emission
points
and
the
minimum
distance
between
any
emission
point
at
the
facility
and
the
closestproperty
boundary.
If
one
or
both
of
these
values
do
not
match
the
exact
values
in
the
lookup
table,
then
use
the
next
lowest
table
value.
(
Note:
If
your
average
stack
height
is
less
than
5
m,
you
must
use
the
5
m
row.)
The
EPA
may
approve
your
facility
as
low
risk
for
carcinogenic
effects
if
your
toxicity­
weighted
carcinogen
emission
rate,
determined
using
the
methods
specified
in
this
appendix,
does
not
exceed
the
values
specified
in
Table
3
to
this
appendix.
(
c)
Noncancer
risk.
Calculate
the
total
central
nervous
system
(
CNS)
and
respiratory
target
organ
specific
toxicityweighted
noncarcinogen
emission
rate
for
your
affected
source
by
summing
the
toxicity­
weighted
emission
rates
for
each
of
your
process
units.
Identify
the
appropriate
maximum
allowable
toxicity­
weighted
noncarcinogen
emission
rate
from
Table
4
to
this
appendix
for
your
facility
using
the
average
stack
height
of
5
your
emission
points
and
the
minimum
distance
between
any
emission
point
at
the
facility
and
the
closest
property
boundary.
If
one
or
both
of
these
values
do
not
match
the
exact
values
in
the
lookup
table,
then
use
the
next
lowest
table
value.
The
EPA
may
approve
your
facility
as
low
risk
for
noncarcinogenic
effects
if
your
toxicity­
weighted
noncarcinogen
emission
rate,
determined
using
the
methods
specified
in
this
appendix,
does
not
exceed
the
values
specified
in
Table
4
to
this
appendix.
(
d)
Low­
risk
demonstration.
The
EPA
may
approve
your
facility
as
eligible
for
membership
in
the
low­
risk
subcategory
of
PCWP
facilities
if
it
determines
that
your
affected
source
is
low
risk
for
both
carcinogenic
and
noncarcinogenic
effects
using
the
look­
up
table
analysis
described
in
this
section,
and
you
meet
the
criteria
specified
in
Section
11
of
this
appendix.

7.
How
do
I
conduct
a
site­
specific
risk
assessment?
(
a)
Perform
a
site­
specific
risk
assessment
following
the
procedures
specified
in
this
section.
You
may
use
any
scientifically­
accepted
peer­
reviewed
assessment
methodology
for
your
site­
specific
risk
assessment.
An
example
of
one
approach
tofor
performing
a
site­
specific
risk
assessment
for
air
toxics
that
may
be
appropriate
for
your
facility
providedcan
be
found
in
the
"
Air
Toxics
Risk
Assessment
Guidance
Reference
Library,
Volume
2,
Site­
Specific
Risk
Assessment
Technical
Resource
Document."
However,
this
approach
may
not
be
appropriate
for
all
facilities,
and
EPA
may
require
that
any
specific
facility
use
an
alternative
approach.
You
may
obtain
a
copy
of
the
"
Air
Toxics
Risk
Assessment
Reference
Library"
fromthrough
EPA's
air
toxics
website
at
www.
epa.
gov/
ttn/
atw.
(
b)
Your
site­
specific
risk
assessment
must:
(
1)
Estimate
the
long­
term
inhalation
exposures
through
the
estimation
of
annual
or
multi­
year
average
ambient
concentrations
for
the
chronic
portion
of
the
assessment.
(
2)
Estimate
the
acute
exposures
through
the
estimation
of
maximum
1­
hour
average
ambient
concentrations
for
the
acute
portion
of
the
assessment.
(
3)
Estimate
the
inhalation
exposure
of
the
individual
most
exposed
to
the
facility's
emissions.
(
4)
Estimate
the
maximum
individual
risk
over
a
lifetime
for
the
chronic
cancer
risk
assessment.
(
5)
Use
site­
specific,
quality­
assured
data
wherever
possible.
(
6)
Use
health­
protective
default
assumptions
wherever
site­
specific
data
are
not
available.
(
7)
DocumentContain
adequate
documentation
of
the
data
and
methods
used
for
the
assessment
so
that
it
is
transparent
and
can
be
reproduced
by
an
experienced
risk
assessor.
(
c)
Your
site­
specific
risk
assessment
need
not:
6
(
1)
Assume
any
attenuation
of
exposure
concentrations
due
to
the
penetration
of
outdoor
pollutants
into
indoor
exposure
areas.
(
2)
Assume
any
reaction
or
deposition
of
the
emitted
pollutants
during
transport
from
the
emission
point
to
the
point
of
exposure.
(
d)
The
EPA
may
approve
your
facility
as
low
risk
for
carcinogenic
chronic
inhalation
effects
if
your
site­
specific
risk
assessment
demonstrates
that
maximum
off­
site
individual
lifetime
cancer
risk
at
a
location
where
people
live
is
less
than
1
in
1
million.
(
e)
The
EPA
may
approve
your
facility
as
low
risk
for
noncarcinogenic
chronic
inhalation
effects
if
your
site­
specific
risk
assessment
demonstrates
that
every
maximum
off­
site
targetorgan
specific
hazard
index
(
TOSHI)
at
a
location
where
people
live
is
less
than
or
equal
to
1.0.
(
f)
The
EPA
may
approve
your
facility
as
low
risk
for
noncarcinogenic
acute
inhalation
effects
if
your
site­
specific
risk
assessment
demonstrates
that
the
maximum
off­
site
acute
hazard
quotients
for
both
acrolein
and
formaldehyde
are
less
than
or
equal
to
1.0.
(
g)
The
EPA
may
approve
your
facility
as
eligible
for
membership
in
the
low­
risk
subcategory
of
PCWP
facilities
if
it
determines
that
your
affected
source
is
low
risk
for
all
of
the
applicable
effects
listed
in
paragraphs
(
d)
through
(
f)
of
this
section,
and
you
meet
the
criteria
specified
in
section
11
of
this
appendix.

8.
What
information
must
I
submit
for
the
low­
risk
demonstration?
(
a)
Your
low­
risk
demonstration
must
include
at
a
minimum
the
information
specified
in
paragraphs
(
a)(
1)
through
(
5)
of
this
section
and
the
information
specified
in
either
paragraph
(
b)
or
(
c)
of
this
section.
(
1)
Identification
of
each
process
unit
at
the
affected
source.
(
2)
Stack
parameters
for
each
emission
point
including,
but
not
limited
to,
the
parameters
listed
in
paragraphs
(
a)(
2)(
i)
through
(
iv)
below:
(
i)
Emission
release
type.
(
ii)
Stack
height,
stack
area,
stack
gas
temperature,
and
stack
gas
exit
velocity.
(
iii)
Plot
plan
showing
all
emission
points,
nearby
residences,
and
fenceline.
(
iv)
Identification
of
any
HAP
control
devices
used
to
reduce
emissions
from
each
process
unit.
(
3)
Emission
test
reports
for
each
process
unit
based
on
the
test
methods
specified
in
Table
2
to
this
appendix,
including
7
a
description
of
the
process
parameters
identified
as
being
worst
case.
(
4)
Identification
of
the
dose­
response
values
used
in
your
risk
analysis
(
look­
up
table
analysis
or
site­
specific
risk
assessment),
according
to
section
4(
b)
of
this
appendix.
(
5)
Identification
of
the
controlling
process
factors
(
including,
but
not
limited
to,
production
rate,
annual
emission
rate,
type
of
control
devices,
process
parameters
documented
as
worst­
case
conditions
during
the
emissions
testing
used
for
your
low­
risk
demonstration)
that
will
become
Federally
enforceable
permit
conditions
used
to
show
that
your
facility
remains
in
the
low­
risk
subcategory.
(
b)
If
you
use
the
look­
up
table
analysis
in
section
6
of
this
appendix
to
demonstrate
that
your
facility
is
low
risk,
your
low­
risk
demonstration
must
contain
at
a
minimum
the
information
in
paragraphs
(
a)
and
(
b)(
1)
through
(
4)
of
this
section.
(
1)
Identification
of
the
stack
heights
for
each
emission
point
included
in
the
calculation
of
average
stack
height.
(
2)
Identification
of
the
emission
point
with
the
nearest
distance
to
areathe
nearest
property
boundary.
(
3)
Calculations
used
to
determine
the
toxicity­
weighted
carcinogen
and
noncarcinogen
emission
rates
according
to
section
6(
a)
of
this
appendix.
(
4)
Comparison
of
the
values
in
the
look­
up
tables
(
Tables
3
and
4
to
this
appendix)
to
your
toxicity­
weighted
emission
rates
for
carcinogenic
and
noncarcinogenic
HAP.
(
c)
If
you
use
a
site­
specific
risk
assessment
as
described
in
section
7
of
this
appendix
to
demonstrate
that
your
facility
is
low
risk
(
for
carcinogenic
and
noncarcinogenic
chronic
inhalation
and
acute
inhalation
risks),
your
low­
risk
demonstration
must
contain
at
a
minimum
the
information
in
paragraphs
(
a)
and
(
c)(
1)
through
(
8)
of
this
section.
(
1)
Identification
of
the
risk
assessment
methodology
used.
(
2)
Documentation
of
the
fate
and
transport
model
used.
(
3)
Documentation
of
the
fate
and
transport
model
inputs,
including
the
information
described
in
paragraphs
(
a)(
1)
through
(
4)
of
this
section
converted
to
the
dimensions
required
for
the
model
and
all
of
the
following
that
apply:
meteorological
data;
building,
land
use,
and
terrain
data;
receptor
locations
and
population
data;
and
other
facility­
specific
parameters
input
into
the
model.
(
4)
Documentation
of
the
fate
and
transport
model
outputs.
(
5)
Documentation
of
exposure
assessment
and
risk
characterization
calculations.
(
6)
Comparison
of
the
maximum
off­
site
individual
lifetime
cancer
risk
at
a
location
where
people
live
to
1
in
1
million,
as
required
in
section
7(
d)
of
this
appendix
for
carcinogenic
chronic
inhalation
risk.
8
(
7)
Comparison
of
the
maximum
off­
site
TOSHI
for
respiratory
effects
and
CNS
effects
to
the
limit
of
1,
as
required
in
section
7(
e)
of
this
appendix
for
noncarcinogenic
chronic
inhalation
risk.
(
8)
Comparison
of
the
maximum
off­
site
acute
inhalation
hazard
quotient
(
HQ)
for
both
acrolein
and
formaldehyde
to
the
limit
of
1,
as
required
in
section
7(
f)
of
this
appendix
for
noncancinogenic
acute
inhalation
effects.
(
d)
The
EPA
may
request
any
additional
information
it
determines
is
necessary
or
appropriate
to
evaluate
a
facility's
low­
risk
demonstration.

9.
Where
do
I
send
my
low­
risk
demonstration?
You
must
submit
your
low­
risk
demonstration
to
the
EPA
for
review
and
approval.
Send
your
low­
risk
demonstration
to
U.
S.
EPA,
Risk
and
Exposure
Assessment
Group,
Emission
Standards
Division
(
C404­
01),
Attn:
Group
Leader,
Research
Triangle
Park,
NC
27711.
Your
affected
source
is
not
part
of
the
low­
risk
subcategory
of
PCWP
facilities
unless
and
until
EPA
notifies
you
that
it
has
determined
that
you
meet
the
requirements
of
section
11
of
this
appendix.

10.
When
do
I
submit
my
low­
risk
demonstration?
(
a)
If
you
have
an
existing
affected
source,
you
must
complete
and
submit
for
approval
your
low­
risk
demonstration
no
later
than
[
INSERT
DATE
14
MONTHS
AFTER
DATE
OF
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER].
(
b)
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
[
INSERT
DATE
60
DAYS
AFTER
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER],
then
you
must
AFTERcomplete
and
submit
for
approval
your
low­
risk
demonstration
no
later
than
[
INSERT
DATE
14
MONTHS
AFTER
DATE
OF
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER].
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
after
[
INSERT
DATE
60
DAYS
AFTER
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER],
then
you
must
complete
and
submit
for
approval
preliminaryyour
low­
risk
demonstration
thatno
later
than
12
months
after
you
become
a
major
source
or
after
initial
startup
of
your
affected
source
as
a
major
source,
whichever
is
later.
(
c)
If
you
have
a
new
or
reconstructed
affected
source
Youyou
must
conduct
the
emission
tests
specified
in
section
5
of
this
appendix
upon
initial
startup
and
use
the
results
of
these
emissions
tests
to
complete
and
submit
your
low­
risk
demonstration
within
180
days
following
your
initial
startup
date.
FIf
your
new
or
reconstructed
affected
source
starts
up
9
before
[
INSERT
DATE
60
DAYS
AFTER
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER],
for
EPA
to
find
that
you
are
included
in
the
low­
risk
subcategory,
youyour
low­
risk
demonstration
must
show
that
you
were
eligible
to
meet
the
criteria
in
section
11
of
this
appendix
followingno
later
than
[
INSERT
DATE
60
DAYS
AFTER
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER].
If
your
new
or
reconstructed
source
starts
up
after
[
INSERT
DATE
60
DAYS
AFTER
PUBLICATION
OF
THE
FINAL
RULE
IN
THE
FEDERAL
REGISTER],
for
EPA
to
find
that
you
are
included
in
the
low­
risk
subcategory,
your
low­
risk
demonstration
must
show
that
you
were
eligible
to
meet
the
criteria
in
section
11
of
this
appendix
upon
initial
startup
of
your
affected
source.

11.
How
does
my
affected
source
become
part
of
the
low­
risk
subcategory
of
PCWP
facilities?
To
be
included
in
the
low­
risk
subcategory,
EPA
must
find
that
you
meet
the
criteria
in
paragraphs
(
a)
and
(
b)
of
this
section.
Unless
and
until
EPA
finds
that
you
meet
these
criteria,
your
affected
source
is
subject
to
the
applicable
compliance
options,
operating
requirements,
and
work
practice
requirements
in
40
CFR
part
63,
subpart
DDDD.
(
a)
Your
demonstration
of
low
risk
must
be
approved
by
EPA.
(
b)
TFollowing
EPA
approval,
the
parameters
that
defined
your
affected
source
as
part
of
the
low­
risk
subcategory
(
including,
but
not
limited
to,
production
rate,
annual
emission
rate,
type
of
control
devices,
process
parameters
documented
as
worst­
case
conditions
during
the
emissions
testing
used
for
your
low­
risk
demonstration)
must
be
incorporated
as
federally
enforceable
terms
and
conditions
into
your
title
V
permit.
You
must
submit
an
application
for
a
significant
permit
modification
to
reopen
your
title
V
permit
to
incorporate
such
terms
and
conditions
according
to
the
procedures
and
schedules
of
40
CFR
part
71
or
the
EPA­
approved
program
in
effect
under
40
CFR
part
70,
as
applicable.

12.
What
must
I
do
to
ensure
my
affected
source
remains
in
the
low­
risk
subcategory
of
PCWP
facilities?
(
a)
You
must
meet
the
requirements
in
Table
2
to
40
CFR
part
63,
subpart
DDDD,
for
each
HAP
control
device
used
at
the
time
when
you
completed
your
low­
risk
demonstration.
You
must
monitor
and
collect
data
according
to
§
63.2270
of
subpart
DDDD
to
show
continuous
compliance
with
your
control
device
operating
requirements.
You
must
demonstrate
continuous
compliance
with
the
control
device
operating
requirements
that
apply
to
you
by
collecting
and
recording
the
monitoring
system
data
listed
in
Table
2
to
this
subpart
for
the
process
unit
according
to
§
§
63.2269(
a),
(
b),
and
(
d)
of
subpart
DDDD;
and
reducing
the
monitoring
system
data
to
the
specified
averages
in
units
of
the
10
applicable
requirement
according
to
calculations
in
§
63.2270
of
subpart
DDDD;
and
maintaining
the
average
operating
parameter
at
or
above
the
minimum,
at
or
below
the
maximum,
or
within
the
range
(
whichever
applies)
established
according
to
section
5(
e)
of
this
appendix.

13.
What
happens
if
the
criteria
used
in
the
risk
determination
change?
(
a)
You
must
certify
with
each
annual
title
V
permit
compliance
certification
that
the
basis
for
your
affected
source's
low­
risk
determination
has
not
changed.
You
must
submit
this
certification
to
the
permitting
authority.
You
must
consider
the
changes
in
paragraphs
(
a)(
1)
through
(
4)
of
this
section.
(
1)
Process
changes
that
increase
HAP
emissions,
including,
but
not
limited
to,
a
production
rate
increase,
an
annual
emission
rate
increase,
a
change
in
type
of
control
device,
changes
in
process
parameters
documented
as
worst­
case
conditions
during
the
emissions
testing
used
for
your
approved
low­
risk
demonstration.
(
2)
Population
shifts.

(
3)
Unit
risk
estimate
increases
posted
on
the
EPA
website
(
http://
www.
epa.
gov/
ttn/
atw/
toxsource/
summary.
html)
for
the
pollutants
included
in
Table
1
to
this
appendix.
(
4)
Reference
concentration
decreases
posted
on
the
EPA
website
(
http://
www.
epa.
gov/
ttn/
atw/
toxsource/
summary.
html)
for
the
pollutants
included
in
Table
1
to
this
appendix.
(
b)
anyIf
your
facility
commences
operating
outside
of
the
low­
risk
subcategory,
it
is
no
longer
part
of
the
low­
risk
subcategory.
You
must
be
in
complince
with
40
CFR
part
63,
subpart
DDDD
as
specified
in
paragraphs
(
b)(
1)
through
(
3)
of
this
section.
Operating
outside
of
the
low­
risk
subcategory
means
that
one
of
the
changes
listed
in
paragraphs
(
a)(
1)
through
(
4)
of
this
section
has
occurred
and
that
the
change
is
inconsistent
with
your
facility's
title
V
permit
terms
and
conditions
reflecting
EPA's
approval
of
the
parameters
used
in
your
low
risk
demonstration.
(
1)
You
must
notify
the
permitting
authority
partas
soon
as
you
know,
or
could
have
reasonably
known,
that
your
facility
is
or
will
be
operating
outside
of
the
low­
risk
subcategory.
(
2)
applicableYou
must
be
in
compliance
with
the
requirements
of
40
CFR
part
63,
subpart
DDDD
as
specified
in
paragraph
(
b)(
2)(
i)
or
(
ii)
of
this
section,
whichever
applies.
(
i)
If
you
are
operating
outside
of
the
low­
risk
subcategory
due
to
a
change
described
in
paragraph
(
a)(
1)
of
this
section
11
that
was
within
your
control,
then
you
must
comply
with
40
CFR
part
63,
subpart
DDDD
beginning
on
the
date
when
your
facility
commences
operating
outside
the
low­
risk
subcategory.
(
ii)
If
you
are
operating
outside
of
the
low­
risk
subcategory
due
to
a
change
described
in
paragraphs
(
a)(
2)
through
(
3)
of
this
section
that
was
out
of
your
control,
then
you
may
submit
a
plan
to
the
permitting
authority
requesting
approval
of
a
compliance
date
no
later
than
three
years
from
the
date
your
facility
commences
operating
outside
the
low­
risk
subcategory.
The
permitting
authority
may
grant
such
an
extension
if
he/
she
finds
that
such
additional
period
is
necessary
for
the
installation
of
controls
and
that
steps
will
be
taken
during
the
period
of
extension
to
assure
that
the
health
of
persons
will
be
protected
from
imminent
endangerment.
You
must
document
why
your
facility
needs
additional
time
to
comply
with
40
CFR
part
63,
subpart
DDDD.
(
3)(
i)
You
must
conduct
performance
tests
no
later
than
180
calendar
days
after
the
applicable
date
specified
in
paragraph
(
b)(
2)
of
this
section.
(
ii)
You
must
conduct
initial
compliance
demonstrations
that
do
not
require
performance
tests
30
calendar
days
after
the
applicable
date
specified
in
paragraph
(
b)(
2)
of
this
section.
(
iv)
For
the
purposes
of
facilities
affected
by
this
section,
you
must
refer
to
the
requirements
in
paragraph
(
b)
of
this
section
instead
of
the
requirements
of
§
63.2233
when
complying
with
40
CFR
part
63,
subpart
DDDD.

14.
What
records
must
I
keep?
(
a)
You
must
keep
records
of
the
information
used
in
developing
the
low­
risk
demonstration
for
your
affected
source,
including
all
of
the
information
specified
in
section
8
of
this
appendix.
(
b)
You
must
keep
the
records
required
in
section
12(
a)
of
this
appendix
to
show
continuous
compliance
with
the
operating
requirements
for
control
devices.
(
c)
For
each
THC
CEMS,
you
must
keep
the
records
specified
in
§
63.2282(
c)
of
40
CFR
part
63,
subpart
DDDD.

15.
Definitions.
The
definitions
in
§
63.2292
of
40
CFR
part
63,
subpart
DDDD,
apply
to
this
appendix.
Additional
definitions
applicable
for
this
appendix
are
as
follows:

Direct­
fired
process
unit
means
a
process
unit
that
is
heated
by
the
passing
of
combustion
exhaust
directly
through
the
process
unit
such
that
the
process
material
is
contacted
by
the
combustion
exhaust.
12
Emission
point
means
an
individual
stack
or
vent
from
a
process
unit
that
emits
HAP
required
for
inclusion
in
the
lowrisk
demonstration
specified
in
this
appendix.
Process
units
may
have
multiple
emission
points.

Hazard
Index
(
HI)
means
the
sum
of
more
than
one
hazard
quotient
for
multiple
substances
and/
or
multiple
exposure
pathways.

Hazard
Quotient
(
HQ)
means
the
ratio
of
the
predicted
media
concentration
of
a
pollutant
to
the
media
concentration
at
which
no
adverse
effects
are
expected.
For
inhalation
exposures,
the
HQ
is
calculated
as
the
air
concentration
divided
by
the
reference
concentration
(
RfC).

Lifetime
means
Look­
up
table
analysis
means
a
risk
screening
analysis
based
on
comparing
the
toxicity­
weighted
HAP
emission
rate
from
the
affected
source
to
the
maximum
allowable
toxicity­
weighted
HAP
emission
rates
specified
in
Tables
3
and
4
to
this
appendix.

Reference
Concentration
(
RfC)
means
an
estimate
(
with
uncertainty
spanning
perhaps
an
order
of
magnitude)
of
a
continuous
inhalation
exposure
to
the
human
population
(
including
sensitive
subgroups)
that
is
likely
to
be
without
an
appreciable
risk
of
deleterious
effects
during
a
lifetime.
It
can
be
derived
from
various
types
of
human
or
animal
data,
with
uncertainty
factors
generally
applied
to
reflect
limitations
of
the
data
used.

Target
organ
specific
hazard
index
(
TOSHI)
means
the
sum
of
hazard
quotients
for
individual
chemicals
that
affect
the
same
organ
or
organ
system
(
e.
g.,
respiratory
system,
central
nervous
system).

Unit
Risk
Estimate
(
URE)
means
the
upper­
bound
excess
lifetime
cancer
risk
estimated
to
result
from
continuous
exposure
to
an
agent
at
a
concentration
of
1
microgram
per
cubic
meter
(
µ
g/
m3)
in
air.

Worst­
case
operating
conditions
means
operation
of
a
process
unit
during
emissions
testing
under
the
conditions
that
result
in
the
highest
HAP
emissions
or
that
result
in
the
emissions
stream
composition
(
including
HAP
and
non­
HAP)
that
is
most
challenging
for
the
control
device
if
a
control
device
is
used.
For
example,
worst
case
conditions
could
include
operation
of
the
process
unit
at
maximum
throughput,
at
its
highest
temperature,
with
the
wood
species
mix
likely
to
produce
the
most
HAP,
and/
or
with
the
resin
13
formulation
containing
the
greatest
HAP.
14
Table
1
to
Appendix
B
to
Subpart
DDDD
of
40
CFR
Part
63.
HAP
That
Must
be
Included
in
the
Demonstration
of
Eligibility
for
the
Low­
risk
PCWP
Subcategory.

For
your
analysis
of
the
following
effects...
You
must
include
the
following
HAP...

(
1)
Chronic
inhalation
carcinogenic
effects
acetaldehyde,
benzene,
arsenic,
beryllium,
cadmium,
chromium,
lead,
nickel,
and
formaldehyde.

(
2)
Chronic
inhalation
noncarcinogenic
respiratory
effects
acetaldehyde,
acrolein,
cadmium,
formaldehyde,
and
methylene
diphenyl
diisocyanate
(
MDI).

(
3)
Chronic
inhalation
noncarcinogenic
CNS
effects
manganese,
lead,
and
phenol.

(
4)
Acute
inhalation
acrolein
and
formaldehyde.
15
Table
2
to
Appendix
B
to
Subpart
DDDD
of
40
CFR
part
63.
Emission
Test
Methods.

For...
You
must...
Using...

(
1)
each
process
unit
select
sampling
ports'
location
and
the
number
of
traverse
points
Method
1
or
1A
of
40
CFR
part
60,
appendix
A
(
as
appropriate).

(
2)
each
process
unit
determine
velocity
and
volumetric
flow
rate;
Method
2
in
addition
to
Method
2A,
2C,
2D,
2F,
or
2G
in
appendix
A
to
40
CFR
part
60
(
as
appropriate).

(
3)
each
process
unit
conduct
gas
molecular
weight
analysis
Method
3,
3A,
or
3B
in
appendix
A
to
40
CFR
part
60
(
as
appropriate).

(
4)
each
process
unit
measure
moisture
content
of
the
stack
gas
Method
4
in
appendix
A
to
40
CFR
part
60.

(
5)
each
process
unit
measure
emissions
of
the
following
HAP:
acetaldehyde,
acrolein,
formaldehyde,
and
phenol
NCASI
Method
IM/
CAN/
WP­
99.02
(
IBR,
see
40
CFR
63.14(
f));
OR
Method
320
in
appendix
A
to
40
CFR
part
63;
OR
ASTM
D6348­
03
(
IBR,
see
40
CFR
63.14(
b))
provided
that
percent
R
as
determined
in
Annex
A5
of
ASTM
D6348­
03
is
equal
or
greater
than
70
percent
and
less
than
or
equal
to
130
percent.

(
6)
each
process
unit
measure
emissions
of
benzene
Method
320
in
appendix
A
to
40
CFR
part
63;
OR
ASTM
D6348­
03
(
IBR,
see
40
CFR
63.14(
b))
provided
that
percent
R
as
determined
in
Annex
A5
of
ASTM
D6348­
03
is
equal
or
greater
than
70
percent
and
less
than
or
equal
to
130
percent.

(
7)
each
press
that
processes
board
containing
MDI
resin
measure
emissions
of
MDI
Method
320
in
appendix
A
to
40
CFR
part
63;
OR
Conditional
Test
Method
(
CTM)
031
which
is
posted
on
http://
www.
epa.
gov/
ttn/
emc
/
ctm.
html
(
8)
each
direct­
fired
process
unit
measure
emissions
of
the
following
HAP
metals:
arsenic,
beryllium,
cadmium,
chromium,
lead,
manganese,
and
nickel.
Method
29
in
appendix
A
to
40
CFR
part
60.
16
(
9)
each
reconstituted
wood
product
press
or
reconstituted
wood
product
board
cooler
with
a
HAP
control
device
meet
the
design
specifications
included
in
the
definition
of
wood
products
enclosure
in
§
63.2292
of
subpart
DDDD
of
40
CFR
part
63
OR
determine
the
percent
capture
efficiency
of
the
enclosure
directing
emissions
to
an
add­
on
control
device
Methods
204
and
204A
through
204F
of
40
CFR
part
51,
appendix
M
to
determine
capture
efficiency
(
except
for
wood
products
enclosures
as
defined
in
§
63.2292).
Enclosures
that
meet
the
definition
of
wood
products
enclosure
or
that
meet
Method
204
requirements
for
a
PTE
are
assumed
to
have
a
capture
efficiency
of
100
percent.
Enclosures
that
do
not
meet
either
the
PTE
requirements
or
design
criteria
for
a
wood
products
enclosure
must
determine
the
capture
efficiency
by
constructing
a
TTE
according
to
the
requirements
of
Method
204
and
applying
Methods
204A
through
204F
(
as
appropriate).
As
an
alternative
to
Methods
204
and
204A
through
204F,
you
may
use
the
tracer
gas
method
contained
in
appendix
A
to
subpart
DDDD.

(
10)
each
reconstituted
wood
product
press
or
reconstituted
wood
product
board
cooler
determine
the
percent
capture
efficiency
a
TTE
and
Methods
204
and
204A
through
204F
(
as
appropriate)
of
40
CFR
part
51,
appendix
M.
As
an
alternative
to
installing
a
TTE
and
using
Methods
204
and
204A
through
204F,
you
may
use
the
tracer
gas
method
contained
in
appendix
A
to
subpart
DDDD.

(
11)
each
process
unit
with
a
HAP
control
device
establish
the
sitespecific
operating
requirements
(
including
the
parameter
limits
or
THC
concentration
limits)
in
Table
2
to
subpart
DDDD
data
from
the
parameter
monitoring
system
or
THC
CEMS
and
the
applicable
performance
test
method(
s).
17
Table
3
to
Appendix
B
to
Subpart
DDDD
of
40
CFR
part
63.
Maximum
Allowable
Toxicity­

Weighted
Carcinogen
Emission
Rate
(
lb/
hr)/(
µ
g/
m3)

Distance
to
Property
Boundary
(
m)

Stack
height
(
m)
0
50
100
150
200
250
500
1000
1500
2000
3000
5000
5
8.72E­
07
8.72E­
07
8.72E­
07
9.63E­
07
1.25E­
06
1.51E­
06
2.66E­
06
4.25E­
06
4.39E­
06
4.39E­
06
4.39E­
06
5.00E­
06
10
2.47E­
06
2.47E­
06
2.47E­
06
2.47E­
06
2.47E­
06
2.61E­
06
3.58E­
06
5.03E­
06
5.89E­
06
5.89E­
06
5.89E­
06
6.16E­
06
20
5.81E­
06
5.81E­
06
5.81E­
06
5.81E­
06
5.81E­
06
5.81E­
06
5.90E­
06
7.39E­
06
8.90E­
06
9.97E­
06
9.97E­
06
1.12E­
05
30
7.74E­
06
7.74E­
06
7.74E­
06
7.74E­
06
7.74E­
06
7.74E­
06
8.28E­
06
9.49E­
06
1.17E­
05
1.35E­
05
1.55E­
05
1.61E­
05
40
9.20E­
06
9.20E­
06
9.20E­
06
9.20E­
06
9.20E­
06
9.20E­
06
9.24E­
06
1.17E­
05
1.34E­
05
1.51E­
05
1.98E­
05
2.22E­
05
50
1.02E­
05
1.02E­
05
1.02E­
05
1.02E­
05
1.02E­
05
1.02E­
05
1.02E­
05
1.36E­
05
1.53E­
05
1.66E­
05
2.37E­
05
2.95E­
05
60
1.13E­
05
1.13E­
05
1.13E­
05
1.13E­
05
1.13E­
05
1.13E­
05
1.13E­
05
1.53E­
05
1.76E­
05
1.85E­
05
2.51E­
05
3.45E­
05
70
1.23E­
05
1.23E­
05
1.23E­
05
1.23E­
05
1.23E­
05
1.23E­
05
1.23E­
05
1.72E­
05
2.04E­
05
2.06E­
05
2.66E­
05
4.07E­
05
80
1.34E­
05
1.34E­
05
1.34E­
05
1.34E­
05
1.34E­
05
1.34E­
05
1.34E­
05
1.92E­
05
2.15E­
05
2.31E­
05
2.82E­
05
4.34E­
05
100
1.52E­
05
1.52E­
05
1.52E­
05
1.52E­
05
1.52E­
05
1.52E­
05
1.52E­
05
1.97E­
05
2.40E­
05
2.79E­
05
3.17E­
05
4.49E­
05
200
1.76E­
05
1.76E­
05
1.76E­
05
1.76E­
05
1.76E­
05
1.76E­
05
1.76E­
05
2.06E­
05
2.94E­
05
3.24E­
05
4.03E­
05
5.04E­
05
MIR=
1E­
06
Emission
rates
in
table
expressed
as
equivalents
normalized
to
theoretical
HAP
with
URE
=
1(
µ
g/
m3)­
1
18
Table
4
to
Appendix
B
to
Subpart
DDDD
of
40
CFR
part
63.
Maximum
Allowable
Toxicity­

Weighted
Noncarcinogen
Emission
Rate
(
lb/
hr)

Distance
to
Property
Boundary
(
m)

Stack
height
(
m)
0
50
100
150
200
250
500
1000
1500
2000
3000
5000
5
2.51E­
01
2.51E­
01
3.16E­
01
3.16E­
01
3.16E­
01
3.16E­
01
3.16E­
01
3.46E­
01
4.66E­
01
6.21E­
01
9.82E­
01
1.80E+
00
10
5.62E­
01
5.62E­
01
5.62E­
01
5.62E­
01
5.62E­
01
5.62E­
01
5.62E­
01
5.70E­
01
6.33E­
01
7.71E­
01
1.13E+
00
1.97E+
00
20
1.43E+
00
1.43E+
00
1.43E+
00
1.43E+
00
1.43E+
00
1.43E+
00
1.43E+
00
1.43E+
00
1.68E+
00
1.83E+
00
2.26E+
00
3.51E+
00
30
2.36E+
00
2.36E+
00
2.36E+
00
2.36E+
00
2.36E+
00
2.36E+
00
2.53E+
00
3.04E+
00
3.04E+
00
3.33E+
00
4.45E+
00
5.81E+
00
40
3.11E+
00
3.11E+
00
3.11E+
00
3.11E+
00
3.11E+
00
3.11E+
00
3.42E+
00
4.04E+
00
5.07E+
00
5.51E+
00
6.39E+
00
9.63E+
00
50
3.93E+
00
3.93E+
00
3.93E+
00
3.93E+
00
3.93E+
00
3.93E+
00
4.49E+
00
4.92E+
00
6.95E+
00
7.35E+
00
8.99E+
00
1.25E+
01
60
4.83E+
00
4.83E+
00
4.83E+
00
4.83E+
00
4.83E+
00
4.83E+
00
5.56E+
00
6.13E+
00
7.80E+
00
1.01E+
01
1.10E+
01
1.63E+
01
70
5.77E+
00
5.77E+
00
5.77E+
00
5.77E+
00
5.77E+
00
5.77E+
00
6.45E+
00
7.71E+
00
8.83E+
00
1.18E+
01
1.36E+
01
1.86E+
01
80
6.74E+
00
6.74E+
00
6.74E+
00
6.74E+
00
6.74E+
00
6.74E+
00
7.12E+
00
9.50E+
00
1.01E+
01
1.29E+
01
1.72E+
01
2.13E+
01
100
8.87E+
00
8.87E+
00
8.87E+
00
8.87E+
00
8.87E+
00
8.87E+
00
8.88E+
00
1.19E+
01
1.37E+
01
1.55E+
01
2.38E+
01
2.89E+
01
200
1.70E+
01
1.70E+
01
1.70E+
01
1.70E+
01
1.70E+
01
1.70E+
01
1.70E+
01
2.05E+
01
2.93E+
01
3.06E+
01
4.02E+
01
4.93E+
01
HI=
1.
However,
EPA
may
require
a
more
stringent
level
in
specific
cases,
which
will
correspondingly
render
the
emission
rates
in
the
table
more
stringent.

Emission
rates
in
table
expressed
in
lbs/
hr
as
equivalents
normalized
to
theoretical
HAP
with
RfC
=
1.0
µ
g/
m3
