Question # 351

351. Would the structural component exemption apply to welding rods used to maintain process equipment? Would the structural component exemption apply to welding rods used to maintain non-process related equipment (40 CFR Section 372.38(c)(1))?
No, welding rods used to maintain process equipment are not exempt. However, if the same rods are used solely to maintain the facility (such as in the repair of a door frame) then the facility maintenance exemption would apply.