The MPCA is proposing that maximum emission rates be applied during these investigations since the company may legally emit this amount in the future. In a situation like this, Georgia Pacific would typically be required to conduct more refined analysis in order to determine whether formaldehyde and acrolein are above the HRVs beyond their property line as a result of plant emissions. Currently, Georgia Pacific is not legally required to do this. Children are at greater risk than adults from certain kinds of exposures to hazardous substances. They are more likely to be exposed because they play outdoors and they often bring food into contaminated areas.
Children are also smaller, resulting in higher doses of chemical exposure per body weight.
The developing organ systems of children can sustain permanent damage if toxic exposures occur during critical growth stages. Most importantly, children depend completely on adults for risk identification and management decisions, housing decisions, and access to medical care. The draft HRVs are meant to protect sensitive sub-populations, including children who may live near the facility. MDH used plant emissions data provided by Georgia Pacific with an EPA screening model. MDH notes that there may be some uncertainty in the actual reported emissions given the limited stack testing, but that modeling was performed using the best available data.