NESHAP Series Pt. 3, Exceptions and Testing
Now that you know what NESHAP is and how to tell if it impacts you, it’s time to see the exceptions to this regulation and how to tell if you are within compliance. Even though you may use the materials that would make you fall under Rule 6x, you might be either an exception to the rule or be within compliance and not have to make any changes to how you are currently cleaning the air in your facility. In the next section we will discuss who these exemptions are and how to test your ventilation to see if your fall within compliance.
Exceptions and Testing
There are some exceptions to Rule 6x that you could fall under. These exceptions are: military installations; NASA facilities; national nuclear security facilities; military munitions facilities; research or laboratories as defined by the Clean Air Act; tool, quality control and equipment repair facilities; and welding facilities using less than 2,000 lbs. of rod or wire that does not contain any identified hazardous materials. If you do not fall under those categories you should then preceded to using Method 22 to identify if you need to change your ventilation. Method 22 is a visual based determination of fugitive emissions from material sources. This is performed by an observer with two stopwatches and goes outside the facility to visually measure emissions. The observer must stand 15 feet or more from an exhaust stack with a clear view of the exhaust fumes, the sun at his/her back, and lines up a dark background. He/She starts the watch in his left and runs it for 15 minutes without stops. He/She then starts the watch in his/her right hand when emissions are observed and stops when they are not. If 20% or more of the 15 minute span has exhaust being visible then Rule 6x applies to you. Getting a third-party confirmation of compliance is recommended to ensure your company is under compliance of Rule 6x.